Partner and Head of White Collar Crime and Investigations, Chris Roberts, has provided comment in Citywealth on the evolving UK and US sanctions landscape, providing his advice for clients with assets on both sides of the Atlantic.

Providing recent context on both jurisdictions’ approaches, Chris said: “The past year has reinforced that a country’s sanctions regime reflects its foreign and domestic policy concerns. In the UK, OFSI has announced it will double the maximum penalty it can impose to the full value of a breach, and the Citibank fine in September shows it is willing to use that power. In the US, waivers such as General License 134 have temporarily allowed Russian oil to flow again on a limited basis, even though the underlying sanctions remain in place.

“In practice, clients with assets or structures on both sides of the Atlantic need to consider UK and US advice together. In the case of Russian oil permitted under US General License 134, the same activity may still be caught by UK sanctions.”

Chris’ comments were published in Citywealth, 16 September 2026.