UK’s latest Russia sanctions: Impacts and compliance takeaways
A breakdown of the latest developments is as follows:
Key highlights of the new sanctions
Targeting Russian oil giants:
- The UK has sanctioned Rosneft and Lukoil, Russia's two largest oil companies, which collectively export 3.1 million barrels of oil daily. This follows earlier sanctions on Gazprom Neft and Surgutneftegas.
- These measures aim to cut off significant revenue streams for Russia, which heavily relies on oil exports for funding.
Crackdown on the "Shadow Fleet":
- 44 tankers involved in transporting Russian oil, along with four oil terminals in China and an Indian refinery (Nayara Energy Ltd), have been sanctioned.
- Seven specialised LNG tankers and the Chinese Beihai LNG terminal, linked to Arctic LNG2, a disrupted Russian project, are also targeted.
Broader economic measures:
- This package is aimed at tightening enforcement of existing restrictions and at neutralising circumvention channels in global oil flows — which is why the UK has targeted the “shadow fleet”, relevant terminals and LNG infrastructure.
- Sanctions on businesses supplying critical electronics for Russian drones and missiles, spanning countries including Thailand, Singapore, Turkey, and China.
Financial impact:
- Since February 2022, UK sanctions have frozen £28.7 billion of Russian assets (as of May 2025) under the UK’s Russia sanctions regime, showcasing the UK's role in enforcing financial restrictions.
Legal Services General Licence (GL) expansion:
- OFSI in the UK clarified the scope of the new GL, effective 29 October 2025 which requires reporting payments to OFSI within 14 days and runs (as published) until 28 April 2026. The GL now applies to most UK autonomous sanctions regimes, expanding beyond its previous focus on Russia and Belarus. The GL can be found here and OFSI’s publication notice here.
- Law firms, legal advisors, counsel, and providers of expenses can receive payments from designated persons under these regimes, provided all conditions of the licence are met.
- Payments are permitted from abroad into UK bank accounts or certain non-UK accounts, but the GL does not allow payments to or for the benefit of individuals designated under United Nations sanctions.
Jurisdictional extent:
UK sanctions measures apply in the UK Overseas Territories (UKOTs) (through Orders in Council) and implemented in the Crown Dependencies (CDs) through their own domestic legislation, which aligns with UK sanctions policy. The changes referred to above automatically apply in the UKOTs and in practice in the CDs with the exception of the GL which applies only in the UK.
The UK's latest sanctions against Russia represent a significant escalation in the economic and political pressure on the Kremlin. While these measures are expected to have an impact on Russia's economy, they also reinforce the UK's commitment to supporting Ukraine and upholding international law.
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