On July 7, 2026, OFAC revoked Iran General License X (GL X) and replaced it with General License X1 (GL X1). The waiver, which had been due to run until August 21, lasted barely two weeks. GL X1 is not a continuation; it is a narrow wind-down authorization that expires on July 17, 2026.
OFAC General Licence — Iranian-origin petroleum products
On 21 June 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorising certain transactions relating to the production, sale, delivery and offloading of Iranian-origin crude oil, petrochemical products and petroleum products. This represents a remarkable — if temporary — departure from the comprehensive United
UK imposes new Russia sanctions – mirroring of EU position on the maritime transport of LNG and refined petroleum products derived from Russian crude
Key takeaways
- Ban on the import of CN 2710 products derived from Russian crude and refined in third countries – subject to diesel and jet fuel exceptions.
- Prohibition on the maritime transportation of Russian LNG – subject to carve-outs for: (i) pre-existing long-term LNG contracts until 1 January 2027; and (ii) Sakhalin and Yamal 2 projects.
- Expansion of specified “shadow-fleet” vessel restrictions, with wide-ranging measures prohibiting provision of all principal services to specified ships. These will not automatically apply to pre-existing specified ships.
- The LNG and refined product restrictions follow announcements in late 2025 by the UK government of an intention to introduce such measures. These largely align with existing EU measures under Council Regulation (EU) 833/2014.
UK issues General Trade Licence for import of diesel and jet fuel derived from Russian crude oil
On 19 May 2026, the Department for Business and Trade (DBT) issued General Trade Licence GBSAN0004 (the Licence), authorising the import into the United Kingdom of certain processed oil products derived from Russian crude oil. The Licence, which comes into force on 20 May 2026, marks a notable relaxation of the UK’s otherwise comprehensive sanctions
EU’s 20th Sanctions Package on Russia
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.
Temporary U.S. sanctions relief for Russian seaborne oil products
The U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued Russia-related General License 134 (“GL 134”) yesterday, which temporarily authorizes the delivery and sale of Russian-origin crude oil and petroleum products that are already on the water as of March 12, 2026. It is understood the policy intent
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.
UK Sanctions – Rosneft, Lukoil and others
In continuation of the UK’s sanctions restrictions against Russia, on 15 October 2025, the UK imposed further sanctions on various entities and vessels.
The headline designations include:
- PJSC Rosneft Oil Company
- Nayara Energy Limited (which was already subject to EU asset freeze restrictions)
- Alghaf Marine DMCC
- PJSC Lukoil
In some regards, these designations mirror the intent of the EU (noting their upcoming 19th sanctions package is intended to impose a full transaction ban on Russian oil majors), signaling joint efforts on the sanctions efforts against Russia between the UK and EU in recent months.
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