UK amends divest investor definition in financial sanctions guidance

18 November 2025

The UK has updated its general financial sanctions guidance to explain when the Office of Financial Sanctions Implementation (OFSI) can grant licences involving Russian divest investors. Under the guidance, divest investors can include:

• People designated under UK Russia sanctions;

• The Russian Government; and

• Anyone facilitating another person’s divestment from these investors.

OFSI may grant licences for entities acquiring an interest from a divest investor if:

• The only consideration is a transfer of funds to the designated person or the Russian Government, and

• Those funds are either credited to a frozen account or paid into an account in a jurisdiction with equivalent sanctions controls and licensing provisions.

Previously, the definition referred broadly to divestment from designated persons or the Russian Government under these conditions. The amended definition now makes clear that UK entities can acquire interests held by a designated person or the Russian Government in that UK entity, rather than leaving the scope of “divestment” undefined. See our UK Guidance pages for more guidance on sanctions licencing from OFSI.