As a follow-up to our previous client alerts on the EU’s Russian gas phase-out (available here), we have prepared an infographic summarising how the EU sanctions framework (Regulation 833/2014) interacts with the RePowerEU phase-out Regulation (Regulation 2026/261), including the key contract cut-off and phase-out dates for both LNG and pipeline
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
Continue Reading How sanctions transformed the shipping industry in 2025
New EU deal fast-tracks the permanent phase-out of Russian gas
The European Parliament and Council have reached a provisional political agreement to permanently end all imports of Russian natural gas into the EU on an accelerated timetable. The deal brings forward key deadlines for LNG and pipeline gas, tightens limits on contract amendments, enhances anti-circumvention and origin-tracking rules, and strengthens enforcement with significant penalties. Member
Regulation to phase out Russian gas imports backed by EU Council
Following the EU’s existing embargo on Russian crude oil and petroleum products, the European Commission has proposed, and the Council has now agreed in principle, a complementary Regulation designed to end the remaining inflows of Russian natural gas into the Union. The measure gives legal effect to the Commission’s May 2025 Roadmap towards ending Russian
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.
Continue Reading New requirements for importing CN code 2710 cargo into the EU from 21 January 2026
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.Continue Reading UK Sanctions – Rosneft, Lukoil and others
Refusing voyage orders: Sanctions risk assessments must be based on evidence, not speculation
Tonzip Maritime Ltd v. 2Rivers Pte Ltd (formerly Coral Energy Pte Ltd) [2025] EWHC 2036 (Comm)
A. Key facts
On 5 November 2021, Tonzip Maritime Ltd (Owners), owner of the vessel CATALAN SEA (the Vessel), entered into a voyage charterparty with 2Rivers Pte Ltd (formerly Coral Energy Pte Ltd) (2Rivers) for the carriage of oil from Primorsk, Russia, to Aliaga, Turkey (the Charterparty).Continue Reading Refusing voyage orders: Sanctions risk assessments must be based on evidence, not speculation
EU-nough Russian Oil – EU’s 18th Sanctions Package
On 18 July 2025, the EU announced the 18th sanctions package against Russia and Belarus. The legislative texts were published on 19 July 2025. As of this date, the latest restrictions indicate a misalignment between the EU / UK, and other G7 members, including the United States.Continue Reading EU-nough Russian Oil – EU’s 18th Sanctions Package
OFAC announces implementation of executive order providing for the revocation of Syria sanctions
As anticipated, on June 30, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the implementation of President Trump’s Executive Order, “Providing for the Revocation of Syria Sanctions.” This action adds to General License 25 and removes the broad U.S. sanctions previously in place against Syria and the former regime
U.S. section 301 strikes back: Additional U.S. port service fees on vessels with China nexus; potential far-reaching implications for leaseback arrangements
U.S. concerns surrounding the proliferation of the Chinese shipbuilding industry pre-date the current tariff wars. Under the previous Biden administration, on March 12, 2024, various U.S. labor unions filed a petition requesting an investigation into the acts, policies, and practices of China targeting the maritime, logistics, and shipbuilding sectors for dominance.
Following a year-long investigation, including input from industry and a public consultation, the United States Trade Representative (“USTR”) determined that China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance is unreasonable and burdens or restricts U.S. commerce and is therefore actionable under Sections 301(b) and 304(a) of the Trade Act.Continue Reading U.S. section 301 strikes back: Additional U.S. port service fees on vessels with China nexus; potential far-reaching implications for leaseback arrangements