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.
Sanctions
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.
RePowerEU Update: Six Countries Cleared for Simplified Gas Imports
The European Commission has granted six countries – Algeria, Nigeria, Norway, Qatar, the United Kingdom and the United States – an exemption from prior authorisation requirements for natural gas imports under the RePowerEU Regulation.
What does this mean?
Gas sourced from these six countries will no longer require prior authorisation under Article 5(3) or evidence…
From oil price cap to maritime services ban: A shift in sanctions strategy
By Alexander Brandt on
I was recently quoted in TradeWinds on the growing number of tankers going dark as the EU considers expanding restrictions on maritime services connected to Russia’s oil trade.
It now looks increasingly certain that the EU, and likely the UK, will move to a comprehensive maritime services ban on the carriage of Russian crude…
EU LNG and Pipeline Gas Import Ban – Timing under EU Sanctions (Article 3ra) vs RePowerEU
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
The effectiveness of OFAC’s sanctions on China’s independent teapot refineries
By Tan Albayrak on
- SDN designations have immediate commercial
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 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…
EU introduces safeguard measures on ferro-alloys imports
By Philippe Heeren & Nevfel Conkus on
Yesterday, the European Union adopted safeguard measures (C/2025/7842) to curb imports of manganese- and silicon-based ferro-alloys, key alloying inputs for the European steel industry. The decision follows a surge in imports and forms part of a broader policy response to global overcapacity and shifting trade flows in the steel sector. The measures take…