Russia Sanctions
Last updated - 07.09.2026
Introduction
International sanctions are restrictions imposed by governments on certain types of transactions with targeted countries, persons, or activities to achieve specific foreign policy or national security objectives, and can restrict a broad range of activities, including limiting the provision of certain financial services and restricting access to financial markets, funds, and economic resources
The UK sanctions regime is a legal framework of restrictive measures designed to achieve foreign policy, national security, and international peace objectives, administered under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA).
Legal Framework and Authorities
The UK sanctions regime is primarily governed by the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), which empowers ministers to establish sanctions regimes, impose regulations, and designate individuals or entities for sanctions.
The Economic Crime (Transparency and Enforcement) Act 2022 and the Economic Crime and Corporate Transparency Act 2023 introduced additional powers, including urgent designations and director disqualification measures. The key bodies are listed here, with more detailed information provided in future sections:
- OFSI (Office of Financial Sanctions Implementation): Implements and enforces financial sanctions, issues licences, and can impose civil monetary penalties.
- OTSI (Office for Trade Sanctions Implementation): Oversees civil enforcement of trade sanctions and related services.
- ECJU (Export Control Joint Unit): Administers trade sanctions and export licensing.
UK Sanctions Regime
The UK’s Sanctions legislative framework regime is the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). This legislative framework establishes the way in which sanctions in the UK are created, enforced, and challenged.
The UK Government publishes the UK Sanctions List, which provides details of those designated under regulations made under SAMLA. The list also details which sanctions measures apply to these persons or ships, and in the case of UK designations, provides a statement of reasons for the designation
The UK Government response through the mechanism of international sanctions can be found on the following webpage:
The UK government issues statutory guidance providing a high-level summary of the measures imposed under each regime.
UK Sanctions on Russia
UK Sanctions applied to the Russia regime is mainly comprised of measures set out in the Russian (Sanctions) (EU Exit) Regulations 2019 (as amended), which are regulations made under SAMLA.
In 2025, the UK announced new measures against Russia, further restricting Russian access to goods, software and technology and imposing additional import bans.
The new measures, contained in Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 (the “2025 Amendments”) amend the Russia (Sanctions) (EU Exit) Regulations 2019 (the “2019 Regulations”).
The measures bring the UK sanctions programme more in line with EU prohibitions, including by imposing restrictions on certain sectoral software and technology.
The Government guidance published alongside the new legislation, sets out examples of concrete steps that businesses can take to ensure compliance with the complex restrictions.
UK sanctions bodies and authorities
Several organisations share responsibility for formulating sanctions policy and implementing, administering, and enforcing sanctions legislation in the UK. The Foreign, Commonwealth and Development Office (FCDO) is responsible for overall UK government policy on international sanctions. Summaries of the function of each are below. All have contact details for enquiries and up-to-date information on their activities.
Financial sanctions are administered and implemented by HM Treasury, and specifically by the Office of Financial Sanctions Implementation (OFSI), which was established in 2016 to ‘provide a high-quality service to the private sector, working closely with law enforcement to help ensure that financial sanctions are properly understood, implemented, and enforced
Trade sanctions are administered and implemented by the Department for Business, Innovation, Science and Trade (BIST). The Export Control Joint Unit, which is part of the DBT, administers the UK’s system of export controls and licensing for military and dual-use items, as well as licences issued under the UK’s various trade sanctions regimes.
OTSI, part of the BIST will be responsible for enforcement of sanctions prohibiting: the provision of certain services (such as professional and legal services); moving, acquiring and making available restricted goods outside of the UK; transferring, acquiring and making available restricted technology outside of the UK; and providing ancillary services (technical assistance, financial services, brokering services) in relation to movement of restricted goods and technology outside of the UK.
Types of Sanctions
The UK imposes sanctions in several categories:
Financial sanctions: Asset freezes, restrictions on financial services, and prohibitions on dealing with designated persons or entities.
Trade sanctions: Restrictions on exporting, supplying, or providing services related to listed goods and technology, including arms embargoes.
Transport sanctions: Controls on ships and aircraft ownership, registration, and movement.
Immigration sanctions: Travel bans preventing entry to the UK.
Director disqualification sanctions: Preventing individuals from acting as company directors.
Sanctions can be geographic (targeting specific countries like Russia, Iran, or North Korea) or thematic (targeting issues such as human rights violations, corruption, terrorism, chemical weapons, or cybercrime).
Scope and Application
UK sanctions apply to:
- Individuals, businesses, and organisations located in the UK, including the territorial sea.
- UK nationals and UK-incorporated entities operating abroad.
- British Overseas Territories and Crown Dependencies, ensuring global effectiveness.
- Designated persons include individuals, entities, and ships, as well as companies owned or controlled by them. “Owned or controlled” is defined as holding over 50% of shares, controlling board appointments, or otherwise directing the entity’s affairs.
Enforcement and Compliance
Breach of UK sanctions is a criminal offence if there is knowledge or reasonable cause to suspect dealings with designated persons, including making funds or economic resources available, directly, or indirectly.
OFSI can also impose civil monetary penalties on a strict liability basis. Reporting obligations are extensive, requiring banks, law firms, and other professionals to report suspected breaches.
Licences and exceptions may be granted for humanitarian aid or other authorised activities.
International Context
The UK sanctions regime operates independently from the EU, though it continues to cooperate with the UN, US, and other partners.
UK sanctions often mirror EU or US measures but can diverge in scope, enforcement, and licensing procedures. Urgent designations allow the UK to act swiftly in alignment with allied sanctions without prior investigation.
Practical Implications
Businesses and individuals must:
- Conduct sanctions screening of clients, counterparties, and transactions.
- Avoid dealing with funds or resources of designated persons.
- Apply for licences when engaging in otherwise prohibited activities.
- Maintain compliance policies and risk assessments to mitigate sanctions exposure.
In the current circumstances, the status of these measures is subject to change daily. UK Government will keep the .Gov.UK pages above refreshed daily, according to the introduction of new information and relevant sanction measures.
Whilst every effort has been made to ensure the accuracy and completeness of this summary at the date of publication, no reliance should be placed on its content, and it does not constitute legal advice. We would encourage readers to refer to the primary sources of the UK Government information for the continued update on sanction restrictions. We would encourage readers to take independent legal and financial advice on the implications of the UK sanctions regime on their UK and international economic, trade and financial operations if there is any suggestion of direct or indirect commercial connections with countries, entities, individuals, and products /services detailed in the information provided by the UK Government..