On 19 May 2026, the UK Government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (the “Amendment Regulations“), introducing numerous amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations“). The Amendment Regulations introduce certain new trade prohibitions and expand existing controls across the Russia sanctions regime.
The Amendment Regulations come into force on 20 May 2026 and, in short, include:
- Import-related restrictions on both the import into the UK of refined oil products processed outside Russia from Russian-origin crude oil, and on the import/acquisition of Russian/Russian-origin uranium;
- Export-related restrictions on a range of goods including industrial products, chemicals, metals, carbon fibre, and items related or ancillary to quantum, AI, semiconductor, and engineering biology technologies;
- Sanctions on construction services and on maritime services relating to Russian Liquefied Natural Gas (“LNG“); and
- Additional shipping sector sanctions.
Supplementing this, the Office of Trade Sanctions Implementation (“OTSI“) issued General Licences permitting certain activities otherwise restricted under the Regulations. These are in relation to: (i) the maritime transportation of Russian LNG under contracts relating to certain projects; and (ii) diesel and jet fuel processed outside Russia. Both licences come into force on 20 May 2026 (found here and here).
We set out further detail on certain of these measures below.
New prohibition on LNG maritime transportation
The Amendment Regulations insert a new Chapter 4LA, imposing prohibitions on the maritime transportation of Russian LNG, whether from Russia to third countries, or between two third countries, and certain associated ancillary services. These measures follow similar measures previously introduced by the EU.
In parallel, OTSI has issued a General Trade Licence authorising the transportation of Russian LNG and related services, specific to certain projects and under certain contracts. The licence comes into force on 20 May 2026 and is valid until 1 January 2027, with a transitional carve-out for services until January 2027 under certain pre-existing contracts concluded before 17 June 2025.
Further exceptions permit: (i) trading in derivatives related to the supply or delivery of Russian LNG; and (ii) acts necessary to address urgent risks to human health, safety, infrastructure, or the environment.
New prohibition on processed oil products
The Amendment Regulations introduce a new Chapter 4IB, imposing prohibitions on the import into the UK of (and provision of certain related services regarding) certain oil and oil products refined in third countries from Russian-origin crude oil.
These measures follow similar measures introduced by the EU and are intended to close indirect import routes into the UK and address circumvention risk where Russian crude oil is processed outside Russia and subsequently re-entered into global markets.
Alongside this, OTSI has issued a General Trade Licence (GBSAN0004) authorising the import of specified products processed outside Russia – namely diesel and jet fuel of defined HS Codes. The licence comes into force on 20 May 2026 (found here).
New prohibition on construction services
The Amendment Regulations add certain construction services to the list of prohibited professional and business services that cannot be provided to persons connected with Russia, complementing existing restrictions on architecture and engineering services.
Two exceptions are introduced:
- To permit acts performed in satisfaction of pre-existing contractual obligations (subject to conditions); and
- To permit essential maintenance activities where justified to the Secretary of State, mitigating risks to infrastructure, property and public safety.
New export prohibitions
The Amendment Regulations introduce a range of new export prohibitions targeting goods critical to Russia’s military-industrial capabilities and economic development. These measures apply to the export, making available, supply or delivery of goods, as well as to related ancillary services.
The new controls fall broadly into four categories:
- EU-aligned items, including certain industrial chemicals and metals with potential battlefield applications and machinery;
- Ukraine-recommended goods, including carbon fibre products commonly used in drone manufacturing and additional forms of metals;
- Riot control agent chemicals, expanding controls on chemicals and precursors that may be used for internal repression; and
- Emerging technology goods, including items connected with quantum technologies, AI, semiconductors, and engineering biology.
These prohibitions broaden the scope of existing restrictions across Schedules 2A, 2E, 3C and 3E – including the expansion of defence and security goods controls (notably chemicals and related materials) – and are intended to further limit Russia’s access to strategically important goods and technologies.
The Amendment Regulations also expand the breadth of controls of certain HS Codes, meaning certain HS Codes are now caught at the chapter rather than sub-heading level.
Further new trade prohibition chapters
The Amendment Regulations insert two additional chapters into the Regulations:
- Chapter 4KA (Uranium) introduces prohibitions on the import, acquisition, supply and delivery of uranium originating in or consigned from Russia, as well as the provision of related technical assistance, financial services and brokering services. The scope of controlled products is defined by reference to a new Schedule 3HA.
- Chapter 4O (Detained transport assets) prohibits the acquisition of “detained transport assets” from or for the benefit of designated persons or persons connected with Russia. Notably, any such acquisition is expressly declared void and ineffective for all purposes, including as a matter of contract and property law, regardless of the governing law of the arrangement.
Both sets of prohibitions are subject to the standard exceptions and licensing framework under Part 7 of the Regulations.
Amendments to existing provisions
In addition to the new prohibitions, the Amendment Regulations make a number of further changes, including:
- Shipping provisions: expanding the UK’s ship specification regime (including via the new regulation 57ZA and amendments to regulations 57E and 57F, which broaden the criteria for specifying ships under the Russia regime), introducing a new ships licensing regime alongside prohibitions on the provision and procurement of services to specified ships and the operation or chartering of such ships, and broadening designation criteria (including vessels transporting Russian-origin LNG or coal).
- Exceptions and licensing: a new trade exception at regulation 60J (in relation to pre-existing contracts concerning certain now-controlled chemical, quantum computing and engineering biology goods and associated ancillary services), a new licensing provision at regulation 61ZB (concerning services for specified ships), and amendments to existing exception and licensing provisions (regulations 60DA – to include construction services in the professional and business services exception and 61 – to include additional now controlled categories of goods in the exception for emergencies in certain cases);
- Enforcement: amendments to regulations 65, 66, 75, 80, 82, 85 and 89, and insertion of new regulations 65ZA and 68ZA, strengthening enforcement and reporting obligations; and
- Civil enforcement: consequential amendments to the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, extending civil enforcement tools to the new prohibitions
We are closely monitoring these developments and will provide further updates as additional guidance is published. For further background on OTSI’s expanding licensing remit, see our blog post here.
