On 24 February 2026, the UK imposed a wide range of Designated Person restrictions, to mark the fourth anniversary of Russia’s full-scale invasion of Ukraine. In summary, the UK imposed Designed Person restrictions on 240 entities and 7 individuals, and specified 50 ships. The measures are particularly focused on Russia’s energy sector and the “shadow fleet” of vessels. The designations include the following noteworthy parties:
- PJSC Transneft, which is one of Russia’s most prominent oil pipeline companies.
- 175 companies in the ‘2Rivers’ oil network, which the UK Government has described as “one of the largest shadow fleet operators globally and a major trader of Russian crude oil”.
- Three civil nuclear energy companies, including Rosatom Energy Projects Joint Stock Company and JSC Rusatom Overseas.
- A number of companies in Russia’s Liquified Natural Gas (LNG) industry, “including ships, traders and Russia’s Portovaya and Vysotsk terminals responsible for exporting Russian LNG”.
- A number of Russian banks that process cross-border payments, including:
- Avers Bank Joint-Stock Company
- Limited Liability Company Bank Tochka
- Post Bank
- Joint-Stock Company Commercial Bank Lanta-Bank
- Sinara Bank Joint Stock Company
- Public Joint Stock Company “Transcapitalbank”
- Joint-Stock Commercial Bank “Absolut Bank” (Public Joint-Stock Company)
- Joint-Stock Commercial Bank “AK BARS” (Public Joint-Stock Company)
- Joint-Stock Commercial Bank Fora-Bank (Joint-Stock Company)
- Maritime Mutual Insurance Association (NZ) Ltd
- Various international companies involved in supplying goods, components and technology for use in Russian drones and other weapons.
The UK Government’s press release for the sanctions is available here, and the full list of designations is available here.
Alongside these measures, the UK has also published two new wind-down general licences, as follows:
- General Licence INT/2026/8893924, Maritime Mutual Re-Insurance Wind Down. This licence allows for the winding down of insurance policies written by Maritime Mutual entities and their subsidiaries before their designation. The licence expires at 23:59 on 09 April 2026.
- General Licence INT/2026/8889196, PJSC Transneft Wind Down. This allows for winding down of transactions involving PJSC Transneft. The licence expires at 23:59 on 09 April 2026.
Furthermore, to reflect the designation of PJSC Transneft, General Licence INT/2025/5635700, Russian Oil Exempt Projects was amended to include any entity owned or controlled, directly or indirectly, by PJSC Transneft. Schedule 1 of the General Licence was also amended to add the Druzhba Pipeline.
Separately, on 25 February 2026, UK General Licence INT/2025/8257372 relating to the continuation of business with Lukoil International Entities was also extended, with a new expiry date of 25 August 2026. Companies would need to carefully review and ensure compliance with all terms of the relevant General Licences in seeking to rely on these.
