On 23 April 2026, the EU adopted its 20th package of sanctions against Russia. These measures are contained in (i) Council Regulation (EU) 2026/506 (see here), (ii) Council Implementing Regulation (EU) 2026/509 (see here), and (iii) Council Regulation (EU) 2026/511 (see here), as published in the Official Journal of the EU.
Carrot over the Stick? Reforms to OFSI Civil Enforcement Processes incentivise early engagement and settlement
Key Takeaways
- OFSI has published updated enforcement guidance introducing a new case assessment matrix, discount structures, a settlement scheme, and fixed penalties for procedural breaches.
- The new framework allows for cumulative discounts for voluntary disclosure (up to 30%), settlement (20%), and the Early Account Scheme (up to 20%), which can reduce penalties by up to 70%.
- Fixed penalties of £5,000 or £10,000 will apply to information, reporting, and licensing breaches.
- OFSI plans to double maximum penalties to £2 million/100% of breach value.
How sanctions transformed the shipping industry in 2025
Key takeaways:
- EU and UK sanctions now increasingly target the full maritime logistics chain, including third country actors
- Shadow-fleet measures have intensified scrutiny on vessels and operators
- Compliance has become central to commercial decision-making
New requirements for importing CN code 2710 cargo into the EU from 21 January 2026
Key Takeaways
- The measure seeks to close remaining ‘loopholes’ in the EU’s Russian oil embargo and maintain consistency with allied sanctions.
- The safe-harbour country presumption eases compliance for imports from established crude exporters but can be rebutted by competent Member State authorities.
- Risk-based due diligence remains essential: importers must be ready to demonstrate non-Russian origin if challenged.
- Companies should now review supply chains, update contractual clauses, and ensure they can substantiate origin claims in due course.
- On 15 October 2025, the UK announced intent to impose similar measures in due course.
EU 14th Sanctions Package against Russia
On 24 June 2024, the EU agreed the long-awaited 14th package of sanctions against Russia. These latest measures introduce several new thematic restrictions and imposed asset freeze measures on an additional 116 individuals and entities including Sovcomflot and the Volga Dnepr Group.
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