Search
Contact
Logo - Linkilaw
Search for something...
Searching...
Linkilaw Search
 
Home / Insights
Sanctions and Regulatory

Sanctions law in flux: what High-Net-Worth clients must know in 2025

29th Apr 2025
Share
  • Linkilaw
  • Linkilaw
  • Linkilaw
  • Linkilaw

Sanctions Compliance for High-Net-Worth Individuals has never been more urgent.

 

In the wake of geopolitical upheavals and shifting global alliances, international sanctions law has undergone a transformation unlike any in recent history. For high-net-worth individuals (HNWI), particularly those with complex asset portfolios, international connections, or dual-national exposure, the stakes are higher than ever.

At Linkilaw Solicitors, we work with clients navigating the increasingly intricate terrain of UK, EU, US, and UN sanctions regimes. Whether you are facing direct designation, seeking a license from the Office of Financial Sanctions Implementation (OFSI), or attempting to protect wealth from exposure risks, understanding the modern sanctions landscape is vital.

 

The 2025 sanctions landscape: a complex web

Sanctions are no longer reserved to States that fall under international scrutiny or criminal networks. In today’s environment, designations often target private individuals, including prominent business leaders, investors, and even their relatives based on associations that may be several degrees removed from the original political concern.

In the United Kingdom (UK), OFSI has ramped up its efforts and oversight, with a significant rise in enforcement action against both direct violators and those who fail to report relevant transactions. Simultaneously, the US Office of Foreign Assets Control (OFAC) and the EU Commission’s restrictive measures are expanding in scope and aligning themselves more frequently with each other’s vetting processes and ultimate designations.

What we are increasingly seeing now in 2025 is the convergence of regimes: an individual sanctioned in one jurisdiction often faces mirrored restrictions in others. While the thresholds for designations differ, the impact it carries for the individuals concerned is cumulative and devastating if not handled proactively.

 

What Is at Stake in Sanctions Compliance for High-Net-Worth Individuals?

For HWNIs, the consequences of being listed on a sanctions register are not merely reputational – they are existential. Here are a few ways sanctions could affect you:

  • Asset freezes: when an individual or a company is listed on a given sanctions register, their assets held in UK, US or EU-based banks and financial institutions are immediately frozen. This also spans to other economic resources, such as investments, properties, and shares. Without access to these assets, individuals may be unable to conduct business, meet financial obligations, and face severe and long-lasting consequences that undermine their ability to effectively manage their wealth.
  • Travel restrictions: sanctions can limit freedom of movement across the UK, EU, and other cooperative jurisdictions. These restrictions can disrupt business as well as personal travel, consequently limiting opportunities for international expansion, and in some cases, preventing individuals from attending critical meetings or events.
  • Contractual fallout: commercial partners may sever ties with a sanctioned individual, terminate contracts or refuse to continue their dealings due to “reputational risk.” All of this jeopardises the sanctioned individual’s business and leads to significant losses of current and future revenue streams. The legal and financial repercussions of such fallouts sometimes result in lengthy negotiations or litigation.
  • Family and trust structures: sanctions may reach into trusts, corporate holdings, or familial arrangements depending on ownership and control thresholds. Consequences range from indefinite restrictions to liquidation, depending on the level of involvement of the sanctioned person. This could seriously disrupt wealth transmission and significantly affect future generations.
  • Criminal liability: non-compliance or misrepresentation can trigger criminal prosecution in the UK under the Sanctions and Anti-Money Laundering Act 2018. Individuals may face prosecution, fines, and in extreme cases, imprisonment. Therefore, staying compliant with sanctions regulations becomes not only a legal necessity but a crucial part of protecting personal and corporate reputation.

Therefore, for those holding multinational assets, operating across financial centres, or managing significant fiduciary structures, the risk is exponential.

 

Sanctions Compliance Pitfalls for High-Net-Worth Individuals: What Many Get Wrong

Too often, clients approach lawyers after attempting to navigate sanctions-related issues alone or relying on generalist legal advice that fails to account for the unique intricacies of sanctions law. Here are some common missteps:

1.     Assuming past advice still applies

Sanctions regimes evolve fast. Guidance issued even six months ago may now be outdated due to amendments or new case law. Clients can be relying on obsolete structures that were once compliant but are now legally vulnerable.

2.     Overlooking the need for licenses

OFSI (in the UK) and OFAC (in the US) issue licenses allowing certain transactions or uses of frozen assets. These licenses are vital for basic living expenses, legal costs, and even business operations. Many clients either do not know they need one or fail to apply early enough, which may lead to delays, penalties, or even criminal liability.

3.     Misjudging “ownership and control” Tests

In the UK, even if you are not directly designated, OFSI can freeze your assets if they believe a company is “owned or controlled” (50% or more) by a sanctioned individual. This test can apply to indirect ownership—through offshore companies, trusts, or layered holdings. Sophisticated structuring is no longer sufficient on its own; it must be backed by sound legal risk assessment.

 

 

Effective Legal Strategies for Sanctions Compliance for HNWIs

At Linkilaw Solicitors, we guide clients through a multi-pronged, proactive approach to sanctions law. Our tailored approach to sanctions compliance for HNWIs ensures both legal and reputational protection. Here is what it looks like in practice:

🔹 Challenging a designation

Being listed by OFSI or a foreign regulator is not always the end of the road. Designations can be challenged on procedural grounds (e.g. improper notification or flawed evidence), legal merits (e.g. mistaken identity or political bias), or through diplomatic representations. A well-argued case, often supported by expert witness statements and cross-jurisdictional evidence, can result in a delisting.

🔹 Securing a license

We help clients prepare comprehensive applications for OFSI licenses to allow for necessary transactions, whether it’s to pay legal fees, manage property, or fund dependents. The key lies in precision and a thorough explanation of necessity and proportionality.

🔹 Risk-proofing assets

For those not yet designated but operating in high-risk areas, we provide pre-emptive reviews of trusts, corporate structures, and personal arrangements. Ensuring legal robustness and documentation that can withstand scrutiny can be the difference between continuity and chaos.

🔹 Managing reputational fallout

Legal remedies are only one piece of the puzzle. Sanctions designations come with media coverage, blocked accounts, and social stigma. Our team works alongside PR and risk professionals to contain reputational exposure and control the narrative.

The Future of Sanctions Compliance for High-Net-Worth Individuals

In today’s volatile global environment, sanctions compliance for HNWIs is not optional, but is essential. Sanctions law is no longer a side topic—it is central to international law, business, and asset management. As 2025 unfolds, we expect even more aggressive enforcement, closer alignment between international regulators, and increasing reliance on AI-led financial surveillance.

For high-net-worth individuals, this means only one thing: you cannot afford to be unprepared.

 

Need help navigating sanctions risk?

Linkilaw Solicitors offers discreet, expert-led representation in all matters of sanctions law—from OFSI licensing to designation challenges. Schedule a confidential consultation with our sanctions team today.

Legal strategy for HNWI under sanctions law - Linkilaw

Sanctions Compliance for High-Net-Worth Individuals has never been more urgent.

 

In the wake of geopolitical upheavals and shifting global alliances, international sanctions law has undergone a transformation unlike any in recent history. For high-net-worth individuals (HNWI), particularly those with complex asset portfolios, international connections, or dual-national exposure, the stakes are higher than ever.

At Linkilaw Solicitors, we work with clients navigating the increasingly intricate terrain of UK, EU, US, and UN sanctions regimes. Whether you are facing direct designation, seeking a license from the Office of Financial Sanctions Implementation (OFSI), or attempting to protect wealth from exposure risks, understanding the modern sanctions landscape is vital.

 

The 2025 sanctions landscape: a complex web

Sanctions are no longer reserved to States that fall under international scrutiny or criminal networks. In today’s environment, designations often target private individuals, including prominent business leaders, investors, and even their relatives based on associations that may be several degrees removed from the original political concern.

In the United Kingdom (UK), OFSI has ramped up its efforts and oversight, with a significant rise in enforcement action against both direct violators and those who fail to report relevant transactions. Simultaneously, the US Office of Foreign Assets Control (OFAC) and the EU Commission’s restrictive measures are expanding in scope and aligning themselves more frequently with each other’s vetting processes and ultimate designations.

What we are increasingly seeing now in 2025 is the convergence of regimes: an individual sanctioned in one jurisdiction often faces mirrored restrictions in others. While the thresholds for designations differ, the impact it carries for the individuals concerned is cumulative and devastating if not handled proactively.

 

What Is at Stake in Sanctions Compliance for High-Net-Worth Individuals?

For HWNIs, the consequences of being listed on a sanctions register are not merely reputational – they are existential. Here are a few ways sanctions could affect you:

  • Asset freezes: when an individual or a company is listed on a given sanctions register, their assets held in UK, US or EU-based banks and financial institutions are immediately frozen. This also spans to other economic resources, such as investments, properties, and shares. Without access to these assets, individuals may be unable to conduct business, meet financial obligations, and face severe and long-lasting consequences that undermine their ability to effectively manage their wealth.
  • Travel restrictions: sanctions can limit freedom of movement across the UK, EU, and other cooperative jurisdictions. These restrictions can disrupt business as well as personal travel, consequently limiting opportunities for international expansion, and in some cases, preventing individuals from attending critical meetings or events.
  • Contractual fallout: commercial partners may sever ties with a sanctioned individual, terminate contracts or refuse to continue their dealings due to “reputational risk.” All of this jeopardises the sanctioned individual’s business and leads to significant losses of current and future revenue streams. The legal and financial repercussions of such fallouts sometimes result in lengthy negotiations or litigation.
  • Family and trust structures: sanctions may reach into trusts, corporate holdings, or familial arrangements depending on ownership and control thresholds. Consequences range from indefinite restrictions to liquidation, depending on the level of involvement of the sanctioned person. This could seriously disrupt wealth transmission and significantly affect future generations.
  • Criminal liability: non-compliance or misrepresentation can trigger criminal prosecution in the UK under the Sanctions and Anti-Money Laundering Act 2018. Individuals may face prosecution, fines, and in extreme cases, imprisonment. Therefore, staying compliant with sanctions regulations becomes not only a legal necessity but a crucial part of protecting personal and corporate reputation.

Therefore, for those holding multinational assets, operating across financial centres, or managing significant fiduciary structures, the risk is exponential.

 

Sanctions Compliance Pitfalls for High-Net-Worth Individuals: What Many Get Wrong

Too often, clients approach lawyers after attempting to navigate sanctions-related issues alone or relying on generalist legal advice that fails to account for the unique intricacies of sanctions law. Here are some common missteps:

1.     Assuming past advice still applies

Sanctions regimes evolve fast. Guidance issued even six months ago may now be outdated due to amendments or new case law. Clients can be relying on obsolete structures that were once compliant but are now legally vulnerable.

2.     Overlooking the need for licenses

OFSI (in the UK) and OFAC (in the US) issue licenses allowing certain transactions or uses of frozen assets. These licenses are vital for basic living expenses, legal costs, and even business operations. Many clients either do not know they need one or fail to apply early enough, which may lead to delays, penalties, or even criminal liability.

3.     Misjudging “ownership and control” Tests

In the UK, even if you are not directly designated, OFSI can freeze your assets if they believe a company is “owned or controlled” (50% or more) by a sanctioned individual. This test can apply to indirect ownership—through offshore companies, trusts, or layered holdings. Sophisticated structuring is no longer sufficient on its own; it must be backed by sound legal risk assessment.

 

 

Effective Legal Strategies for Sanctions Compliance for HNWIs

At Linkilaw Solicitors, we guide clients through a multi-pronged, proactive approach to sanctions law. Our tailored approach to sanctions compliance for HNWIs ensures both legal and reputational protection. Here is what it looks like in practice:

🔹 Challenging a designation

Being listed by OFSI or a foreign regulator is not always the end of the road. Designations can be challenged on procedural grounds (e.g. improper notification or flawed evidence), legal merits (e.g. mistaken identity or political bias), or through diplomatic representations. A well-argued case, often supported by expert witness statements and cross-jurisdictional evidence, can result in a delisting.

🔹 Securing a license

We help clients prepare comprehensive applications for OFSI licenses to allow for necessary transactions, whether it’s to pay legal fees, manage property, or fund dependents. The key lies in precision and a thorough explanation of necessity and proportionality.

🔹 Risk-proofing assets

For those not yet designated but operating in high-risk areas, we provide pre-emptive reviews of trusts, corporate structures, and personal arrangements. Ensuring legal robustness and documentation that can withstand scrutiny can be the difference between continuity and chaos.

🔹 Managing reputational fallout

Legal remedies are only one piece of the puzzle. Sanctions designations come with media coverage, blocked accounts, and social stigma. Our team works alongside PR and risk professionals to contain reputational exposure and control the narrative.

The Future of Sanctions Compliance for High-Net-Worth Individuals

In today’s volatile global environment, sanctions compliance for HNWIs is not optional, but is essential. Sanctions law is no longer a side topic—it is central to international law, business, and asset management. As 2025 unfolds, we expect even more aggressive enforcement, closer alignment between international regulators, and increasing reliance on AI-led financial surveillance.

For high-net-worth individuals, this means only one thing: you cannot afford to be unprepared.

 

Need help navigating sanctions risk?

Linkilaw Solicitors offers discreet, expert-led representation in all matters of sanctions law—from OFSI licensing to designation challenges. Schedule a confidential consultation with our sanctions team today.