To help businesses and stakeholders comply with these expanded regulations, the Office of Financial Sanctions Implementation (OFSI) has issued two new guidance documents, providing practical support for navigating the new rules.

Expanded export prohibitions

The updated sanctions broaden restrictions on the export, supply, and delivery of goods to Russia. These include specific prohibitions on chemicals, electronics, machinery, plastics, and metals essential to Russia's industrial and military activities. These newly sanctioned items have been added to existing categories within the 2019 Regulations, such as:

• Schedule 2A (critical-industry goods and technology)
• Schedule 3C (defence and security goods and technology)
• Schedule 3I (Russia’s vulnerable goods and technology)

The inclusion of these goods ensures that UK sanctions cover key materials that could directly support Russia's ongoing war efforts.

Restrictions on technology transfers

One of the most notable additions is the restriction on certain technology transfers. These measures aim to close loopholes that previously allowed Russia access to sensitive technological expertise and intellectual property. The sanctions now cover areas such as advanced manufacturing, industrial design, and software related to oil and gas operations.

To assist organisations in understanding these regulations, OFSI has published the following guidance documents:

1. Complying with Technology Transfer Sanctions: This document clarifies how businesses should manage restrictions on technologies linked to sanctioned goods, ensuring compliance with regulatory requirements.
2. Complying with Sectoral Software Sanctions: This guide highlights rules for restricting the transfer of sectoral software to or for use in Russia, including intangible transfers like downloads or cloud-based services.

These resources are essential for navigating the complex provisions, particularly for companies dealing with sensitive technology or software.

Import bans on revenue-generating goods

New import restrictions target synthetic diamonds processed in third countries, as well as helium and Helium-3. These items, included under Schedule 3DA (revenue-generating goods), are designed to disrupt potential alternative revenue streams for Russia, complementing existing bans on natural diamonds and other goods.

Synthetic diamonds measuring 0.5 carats or more are subject to sanctions, aligning with the weight thresholds for natural diamonds. Similarly, the ban on helium imports reflects the UK’s proactive stance in addressing the potential rise of this resource as a revenue generator for Russia.

Alignment with international sanctions

To maximise impact, the UK’s sanctions are harmonised with those of the US, EU, and other G7 allies. This unified effort is critical to minimising Russia’s capacity to use alternative supply chains through third-party countries. New chapters like Chapter 4N (sectoral software and technology) aim to address these vulnerabilities directly.

The addition of G7 dependency goods to the sanctions list also ensures consistency with measures already in place among international allies.

While exceptions and licenses are allowed for certain restricted goods and activities, these are granted under strictly limited circumstances to maintain the overall efficacy of the sanctions.

Supporting compliance

To fully understand and comply with these regulations, organisations are strongly encouraged to review the new OFSI guidance documents. These tools provide clarity on managing compliance obligations, particularly surrounding technology and software transfers. Here are the relevant links again for easy reference:

• Complying with Technology Transfer Sanctions
• Complying with Sectoral Software Sanctions

A call to action

UK businesses and stakeholders must stay informed about these sanction updates and the available compliance tools. With the new measures in effect, adhering to these regulations is not only a legal obligation but also a contribution to global efforts for peace and stability.

UK Overseas Territories

Under the 2020 amendments to the Russian Sanctions (Overseas Territories) Order, which extend the EU Exit Regulations 2019, these provisions are automatically applicable to the UK Overseas Territories (UKOT), including the British Virgin Islands and the Cayman Islands. However, additional legislation will be required to fully implement the provisions within each UKOT jurisdiction. These changes will be reflected in updates to the 2020 Order in Council.

Bermuda will implement the legislation in line with the approach taken by other UKOTs and in accordance with the International Sanctions Regulations 2013.

For further details on the legislative changes, refer to the full text of the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, here.

The Notice to Exporters NTE 2025 can be found here.

OFSI published a General Trade Licence for sanctioned Russian synthetic diamonds processed in third countries and can be accessed here and a Guidance on third country processed Russian synthetic diamonds measures, here. Also an updated Notice NTI 2953: Russia import sanctions was issued and can be found here.