In significant parallel actions this week, the EU and US imposed new sanctions on Russia. While the EU’s 19th sanctions package is much broader in scope, the measures overlap in their focus on the Russian energy sector, with the US imposing full blocking sanctions on Russia’s two largest oil majors, OJSC Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) and the EU imposing a full ban on Russia-origin liquified natural gas (“LNG”), among other energy sector…
On 13 October 2025, the Office of Trade Sanctions Implementation (“OTSI”) published a blog post highlighting a recent case involving suspected breach reports from a UK branch of a multinational bank, under the Russia (Sanctions) (EU Exit) Regulations 2019. OTSI’s blog post notes that the UK branch of the bank identified payments linked to the trade of sanctioned goods from Russia to a third country, between April and June 2025. The blog post notes that…
On 18 July 2025, the UK Government announced a lowering of the Oil Price Cap (“OPC”) to further inhibit Russia’s ability to use oil revenues to finance its illegal invasion of Ukraine. The OPC was first introduced in December 2022 to reduce Russia’s oil revenues in response to the invasion of Ukraine that same year. The OPC prevents G7 companies from shipping, insuring or servicing any Russian crude oil sold above the OPC price of…
On 21 July 2025, the UK government issued the General Trade Licence: Russia Sanctions – Sectoral Software and Technology (the “Sectoral Software Licence”) under Regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations”). The Sectoral Software Licence came into force on 21 July 2025 and will expire on 20 October 2025. The Sectoral Software Licence authorises providers located in or operating from within the UK and UK persons to transfer…