Articles Posted in Russia Sanctions

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On July 23, 2026, the Council of the European Union adopted its 21st sanctions package against Russia and parallel measures concerning Belarus. Across the two asset-freeze regimes, the package added 48 individuals and 170 entities. Beyond the new listings, the package also amends Regulation (EU) No 833/2014 and the corresponding Belarus sectoral regime, introducing new transaction bans, trade controls and other restrictions. The new asset-freeze listings and amendments to Regulation (EU) No 269/2014 took effect on July 23, 2026, and many of the principal sectoral amendments took effect on July 24, 2026, although several measures have later application dates.

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On April 23, 2026, the EU adopted its 20th sanctions package targeting Russia and Belarus in connection with the Russia-Ukraine conflict.

 The latest package significantly expands the EU’s restrictive measures across the energy, finance and crypto, trade, services and maritime and transport sectors, with a core focus on anti-circumvention and energy measures. A summary of the key updates follows.

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On 18 December 18, 2025, the European Union (EU) added 41 vessels to its sanctions list, targeting Russia’s so-called “shadow fleet,” an opaque network of tankers used to circumvent restrictions on Russian oil exports. The measure forms part of the EU’s broader effort to degrade the Kremlin’s war financing and address persistent enforcement challenges at sea.

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In May 2025, the UK government published the Cross-Government Review of Sanctions Implementation and Enforcement policy paper (“Cross-Government Review”). Led by the Foreign, Commonwealth and Development Office (FCDO), and supported by key sanctions departments and agencies across the UK government, the Cross-Government Review identifies steps to improve and facilitate compliance with sanctions, increase the deterrent effect of enforcement, and strengthen the government’s enforcement toolkit.

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On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions for Russia’s energy sector, designating Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil) under Executive Order (EO) 14024 as Specially Designated Nationals (SDNs), along with dozens of directly named subsidiaries.

These designations prohibit transactions with and services related to Rosneft, Lukoil, any entity that they or other SDNs own 50 percent or more, or any property in which such entities have an interest, directly or indirectly, for U.S. persons and where U.S. primary sanctions jurisdiction otherwise applies.

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On August 6, 2025, President Trump published a new Executive Order imposing secondary tariffs on India in response to its continued importation of Russian-origin crude oil. This marks both an escalation in U.S. trade negotiations with India and the first major Russia-related enforcement action of his second term. It also reflects the Trump Administration’s novel use of trade measures to enforce U.S. sanctions policy.

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On February 24, 2025, the EU adopted its 16th package of sanctions against Russia, Belarus and non-government-controlled areas of Ukraine, symbolically marking the third anniversary of the start of Russia’s invasion of Ukraine and constituting the largest set of updates that we have seen in the past two years. On the same day, the UK also issued new designations under its Russia sanctions regime impacting 107 entities, individuals and ships. See a summary of the updates below.

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On December 16, 2024, the EU issued its 15th package of sanctions against Russia, new designations under the Belarus sanctions regime, and the first designations under the hybrid threats sanctions regime adopted in October 2024. These updates are summarized below.

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On September 23, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released for public inspection a Notice of Proposed Rulemaking that seeks to prohibit the sale or import of connected vehicles (CVs) with certain hardware and software that have a sufficient nexus to the People’s Republic of China (PRC) or Russia. If the Vehicle Connectivity System (VCS) hardware and the VCS and Automated Driving System (ADS) software are designed, developed, manufactured or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of the PRC or Russia, the transactions outlined below would be prohibited.

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On September 12, 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), granting the UK’s trade sanctions enforcement body, the Office of Trade Sanctions Implementation (OTSI), new implementation and enforcement powers effective from 10 October 2024. The Regulations also grant the Department for Transport (DfT) corresponding powers in relation to aircraft and shipping sanctions (i.e., sanctions relating to the movement, registration and ownership of aircrafts and ships).

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