On 23 April 2025, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 24 April 2025. These new regulations amended the Russia (Sanctions) (EU Exit) Regulations 2019 to introduce additional trade restrictions, focusing on export and import prohibitions, technology, and software transfers. We have set out summaries of the key new measures below.
Sectoral Software
The amending regulations introduce prohibitions on making available and transferring “sectoral software” to persons connected with Russia or for use in Russia. The amending regulation’s accompanying explanatory memorandum clarifies that this includes when in-scope software is provided as Software as a Service (SaaS). This largely aligns the UK position with the EU position on enterprise resource planning (“ERP”) software.
Sectoral software and technology are defined in Schedule 3IA to include:
- Business enterprise software and technology (e.g. ERP, CRM, business intelligence, supply chain management etc.).
- Industrial design software and technology (e.g. CAD, CAM, and engineer-to-order software etc.).
- Oil and gas related software and technology.
Software in the public domain or used for basic scientific research is excluded, whilst exceptions include pre-existing contracts concluded before 23 April 2025 until 22 July 2025 and non-commercial or personal use software and technology.
The UK has published guidance on complying with these sectoral software measures and has also updated its Russia sanctions statutory guidance to reflect the available licensing grounds for these measures.
Additional controls on transferring technology related to controlled goods
The amending regulations also introduce additional restrictions on transferring technology “required” for the “development,” “production,” or “use” of a broad range of controlled goods, including those listed as energy-related goods, G7 dependency and further goods, and Russia’s vulnerable goods.
“Technology” is defined very broadly and means information (including information comprised in software) that is capable of use in connection with (a) the development, production or use of any goods or software, or (b) the development of, or the carrying out of, an industrial or commercial activity or an activity of any other kind whatsoever. The amending regulation’s explanatory memorandum clarifies that this can include intellectual property, industrial know-how, trade secrets and information contained in blueprints and designs, largely aligning with the EU’s restrictions on providing IP and trade secrets related to controlled goods and technology.
Expanded lists of controlled goods and technologies
Further, the amending regulations add a number of additional goods and technologies to the schedules of restricted items that it is prohibited to export, supply, transfer or supply and deliver to persons connected with Russia or for use in Russia (as well as providing associated services such as technical assistance). These include, but are not limited to, a range of electronics, machinery, agricultural items, metals, industrial components, raw materials, chemical compounds, minerals, tools, machinery parts.
If you have questions regarding this regulatory development, please contact our Trade team for more information.
