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Ben Smith (UK)

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On 21 January 2026, the EU’s restrictions on the import of refined petroleum products deriving from Russian-origin crude oil entered into force. The restrictions, introduced as part of the EU’s 18th package of sanctions targeting Russia under Article 3ma of EU Regulation 833/2014 (as previously summarised in our blog post here), prohibit the direct or indirect purchase, import or transfer into the EU of refined petroleum products obtained from third countries that derive from Russian-origin…

On 4 December 2025, the UK Office of Trade Sanctions Implementation (“OTSI”) published a corporate report marking the first year since its launch in October 2024 (see here). Our previous blog post providing more background on OTSI’s powers and jurisdiction can be found here. The corporate report summarises OTSI’s activities during this first year, including licensing and enforcement activity, efforts to engage with businesses, collaboration with international partners and other government functions, as well as…

The EU and UK have recently updated their respective lists of items subject to dual-use export controls, introducing important changes covering emerging technologies. In this blog post, we summarise the key updates under both the EU and UK regimes, and we highlight key steps that exporters can take in response to the changes. EU updates to the EU Dual-Use Regulation On 14 November 2025, the EU published Delegated Regulation (EU) 2025/2003, amending Annex I of…

Following the EU’s 18th sanctions package and the latest developments of the UK’s sanctions against Russia, the Governments of Australia and Japan also introduced additional measures against Russia respectively on 18 and 12 September 2025. Among other measures, they have agreed with other G7 countries to phase out Russian oil imports in response to the 2022 invasion of Ukraine, indicating aligned efforts within the G7 with respect to the imposition of sanctions against Russia. This…