Overview
On May 19, 2026, the UK introduced a new package of Russia sanctions through an amendment to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The package is wide-ranging and contains new trade sanctions measures targeting oil products processed in third countries from Russian oil, the maritime transportation of liquefied natural gas (“LNG”), uranium, and ships and aircraft detained in the UK. Existing trade sanctions measures have also been meaningfully expanded through the addition of new items and services to the scope of pre-existing restrictions. The measures came into force on May 20, 2026. Businesses required to comply with UK financial sanctions should promptly familiarize themselves with these changes, consider their impact on current business operations, and consider whether they necessitate updates or enhancements to existing sanctions risk assessments, policies, procedures, and controls.
Import Sanctions on Processed Oil Products
Part 5, Chapter 4IB of the Russia Regulations introduces an import ban on oil and oil products falling within commodity code 2710 that have been processed in a third country from oil and oil products falling within commodity code 2709 that originate in Russia (“Processed Oil Products”). The new prohibition also extends to the direct or indirect provision of technical assistance relating to the import into the United Kingdom of these Processed Oil Products, as well as the provision of financial services, funds, or brokering services in connection with an arrangement with the object or effect of importing these Processed Oil Products.
The Office of Trade Sanctions Implementation (“OTSI”) has issued a General Trade Licence, which authorizes activity otherwise prohibited by these sanctions where products fall within commodity codes 2710 19 42 or 2710 19 44 (i.e., diesel) or 2710 19 21 (i.e., jet fuel). This licence effectively delays the implementation of these new sanctions in respect of these particular products, likely in response to the ongoing global energy crisis related to the situation in the Strait of Hormuz.
Maritime Transportation of LNG
Part 5, Chapter 4LA of the Russia Regulations introduces a ban on the transportation by ship of LNG falling within commodity code 2711 11 00 that originates in, or is consigned from, Russia (“Russian LNG”) from a place in Russia to a third country, or between two third countries. The new prohibition also extends to the direct or indirect provision of financial services, funds, or brokering services relating to these activities.
Three exceptions have been created to authorize any activity that would otherwise be prohibited under these sanctions: (i) in connection with an obligation arising under a contract for the supply of Russian LNG concluded before June 17, 2025, provided that the contract exceeds one year, the terms of the contract are not amended after June 17, 2025 save in certain specified ways, and the activity is carried out on or before January 1, 2027; (ii) by a derivatives trader, derivatives broker, or certain specified financial institutions processing payments in relation to the foregoing derivatives activities; or (iii) where a justification is provided to the Department for Business and Trade (“DBT”) within five working days that the act was undertaken to deal with an emergency.
OTSI has also issued a General Trade Licence, which authorizes activity otherwise prohibited by these sanctions where the activity is undertaken in fulfillment of a contract with a duration of one year or less and the maritime transportation of Russian LNG involves LNG originating at the Sakhalin-2 or Yamal LNG terminals. This licence will expire on January 1, 2027.
Uranium
Part 5, Chapter 4KA of the Russia Regulations introduces a ban on the import into the United Kingdom, acquisition, or the supply or delivery to a third country of uranium from Russia falling within commodity codes 2844 10, 2844 20, or 2844 30. The new prohibition also extends to the direct or indirect provision of technical assistance, financial services, funds, or brokering services relating to these activities.
One exception has been created to authorize any activity undertaken to deal with an emergency that would otherwise be prohibited under these sanctions, provided that a justification is provided to DBT within five working days of the act. An exception has also been created to authorize certain activity by a person that is necessary for the continued operation of a nuclear installation in a third country, where the installation was operational on May 20, 2026. A further exception has been created to authorize the acquisition of Russian origin uranium, as well as the provision of technical assistance, financial services, funds, or brokering services relating to such an acquisition when the uranium in question was exported from Russia before May 20, 2026, and stored in a third country.
New Aircraft and Ship-related Sanctions
Part 5, Chapter 4A of the Russia Regulations has been expanded to include a prohibition on the direct or indirect provision of a range of services in relation to specified ships (i.e., vessels individually named and subjected to sanctions), including in relation to the acquisition, sale, transfer or supply of a specified ship, as well as technical assistance, crew, operating, chartering, brokering, and financial services. The direct or indirect procurement of services relating to a specified ship, including its use, is also prohibited. An exception to these prohibitions has been created to authorize activity necessary to protect or avoid endangering the safety of any ship or life of any person.
Part 6 of the Russia Regulations has also been expanded to prohibit the chartering, operation, or UK registration of specified ships, with limited exceptions, subject to any transport sanctions licensing granted by the Department for Transport. The grounds for specifying ships have also been extended to include ships that carry Russian LNG or Russian coal and coal products to or between third countries.
Part 5, Chapter 4O of the Russia Regulations also introduces a prohibition on the direct or indirect (purported) acquisition from or for the benefit of a UK-designated person or person connected with Russia of aircraft detained at an airport, or ships detained at a port or anchorage in the United Kingdom, pursuant to a direction issued by the Secretary of State for Transport (“Detained Transport Assets”). Under the Russia Regulations, unlicensed acquisitions in contravention of this prohibition will be considered void and ineffective for all purposes, including as a matter of contract and property law, regardless of the applicable law of the agreement to acquire the Detained Transport Asset.
Additional Items Added to Pre-Existing Trade Sanctions Measures
New items have been brought within the scope of existing trade sanctions measures. Specifically, the list of items classified as:
- “critical-industry goods and technology” has been expanded to include various ancillary chemicals used in advanced chip production, as well as certain constituent chemicals for propellants;
- “quantum computing and advanced materials goods and technology” has been expanded to include an additional 27 items;
- “defence and security goods and technology” has been expanded to include an extensive new list of chemicals, as well as so-called “engineering biology” items, including cell cultures, enzymes, and gene editing tools; and
- “G7 dependency and further goods and technology” has been expanded to add new items.
An exception has been created to authorize certain activity in satisfaction of an obligation arising under a contract (or related ancillary contract) concluded before May 20, 2026 that would otherwise be prohibited because it relates to the newly sanctioned items classified as ancillary chemicals used in advanced chip production, quantum computing and related goods, and engineering biology – ancillary goods, provided that the activity is concluded before November 21, 2026 and notified to DBT by the same deadline. A further exception has been created to authorize certain otherwise prohibited activity in relation to engineering biology – ancillary goods and quantum computing and related goods where a justification is provided to DBT within five working days that the act was undertaken to deal with an emergency.
A small number of items have also been removed from the lists of items subject to trade sanctions that previously were classified as: (i) luxury goods; (ii) defence and security goods and technology; (iii) G7 dependency and further goods and technology; and (iv) Russia’s vulnerable goods and technology.
The scope of existing professional and business services sanctions prohibiting the direct or indirect provision of in scope services to a person connected with Russia under Part 5, Chapter 6B of the Russia Regulations have been expanded to include construction services, which are defined as services falling within codes 511 to 518 of the 1991 Central Product Classification. Two exceptions have been created to allow the provision of construction services (i) in satisfaction of an obligation under a contract (or related ancillary contract) concluded before May 20, 2026, provided the services are provided before August 21, 2026, and the provision of services is reported to DBT by the same deadline or (ii) where the service provider provides a justification to DBT within five working days of the service provision commencing that it was necessary for essential maintenance.
Conclusion
Businesses that are required to comply with UK sanctions should assess how the new package of Russia-related sanctions affect their operations, including whether any exceptions or licences may be available. As the new measures do not generally benefit from transitional arrangements, it is imperative an assessment is conducted promptly. Additionally, consideration should be given to the continued adequacy of existing sanctions risk assessments, policies, procedures, and controls in light of the new measures. Steps also should be taken to enhance sanctions controls, where necessary. For more information on these developments and assistance in complying with the new requirements, contact the author of this post, Alexandra Melia, in Steptoe’s Economic Sanctions team in London.
