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Overview

On 1 October 2026, the UK government announced a significant new package of 31 sanctions against Russia. The package comprises 23 new designations of individuals and entities and eight ship specifications, representing a further intensification of the UK’s economic pressure on Russia ahead of winter. The measures target revenue streams critical to sustaining Russia’s war effort – particularly in the LNG and Arctic shipping sectors – alongside those responsible for serious human rights abuses in occupied Ukrainian territories and those engaged in pro-Kremlin disinformation campaigns.

The package comes against a backdrop of continued Russian aggression, with over 3,100 drone strikes launched into Ukraine in September 2026 alone, and follows sham elections held in temporarily occupied territories of Ukraine that same month. The UK has now imposed over 3,400 designations under the Russia sanctions regime, including more than 500 in 2026, and has sanctioned nearly 600 tankers in connection with Russia’s shadow fleet.

Continue Reading UK sanctions update: new Russia package targets LNG shadow fleet, propagandists, and human rights abusers

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.
Continue Reading UK imposes new Russia sanctions – mirroring of EU position on the maritime transport of LNG and refined petroleum products derived from Russian crude

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…

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

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 

On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a sweeping set of actions to further reduce Russian revenues from energy, including blocking two major Russian oil producers, Gazprom Neft and Surgutneftegas, and imposing sanctions on a very significant number of oil-carrying vessels, opaque traders of Russian oil located in jurisdictions like Hong Kong and the UAE, Russia-based oilfield service providers, and Russian energy officials.  The U.S. Department of State also took steps to block two active liquefied natural gas projects, a large Russian oil project, and third-country entities supporting Russia’s energy exports. Lastly, the United Kingdom also joined the U.S. in sanctioning Gazprom Neft and Surgutneftegas – which, coupled with the joint Memorandum of Understanding issued by OFAC and OFSI on January 13, is a testament to the increased cooperation between the U.S. and UK authorities. Although there are wind-downs in place for most of these entities, this round of designations is likely to cause major disruptions in the market. We summarize the new restrictions in turn below:

Continue Reading U.S. and UK Intensify Sanctions Against Russia’s Oil Sector in one of the Largest Rounds of Designations Since the Outbreak of the War

The sudden collapse of the Assad regime in Syria has led to a rapidly evolving sanctions landscape. Notably, on January 6, 2025, the United States relaxed sanctions on certain transactions with Syria when the Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24), “Authorizing Transactions with Governing…

  • In October 2024 the UK government will launch the Office of Trade Sanctions Implementation (OTSI) to bolster the enforcement of UK trade sanctions.
  • On 12 September 2024 the UK government laid before Parliament the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations). They were accompanied by new statutory guidance –
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A UK Court of Appeal decision in June 2024 has heightened the UK’s focus on the potential for money laundering offences within global supply chains. There is now a greater risk that UK law enforcement may recover assets from companies that fail to perform adequate due diligence on their supply chain, even if adequate consideration…

On Tuesday 23rd July, energy and natural resources partners Sachin Kerur and James Willn, along with international trade partner Leigh Hansson, hosted the highly anticipated webinar “Sanction Strategies: Focus on India, China, and the Middle East.” During this insightful session, the team delved into the latest sanctions decisions, explored the implications for companies in these…