UK Imposes a New Wave of Sanctions Against Russia

Some of the designations also encompass persons operating in the Russian defence and financial sectors. Furthermore, the UK Government targeted a number of vessels involved in transporting Russian oil and gas.

The full list of 90 newly sanctioned persons and vessels can be accessed here: List of Russia sanctions targets, 15 October 2025 - GOV.UK.

Immediate Impact

As a result of these new asset freeze measures, UK persons are now effectively prohibited from trading with the newly designated persons and vessels. Specifically, UK persons will now be prohibited from making funds and/or economic resources available directly or indirectly to, or for the benefit of, a designated person as well as any person which is owned for more than 50%, or controlled by, a designated person (importantly, this includes Rosneft’s and Lukoil’s subsidiaries, such as Litasco).  

The new measures mean that, for example:

• UK persons will not be able to (directly or indirectly) buy goods or services from, or sell goods or services to, the sanctioned entities;

• UK persons will not be able to accept products delivered on (or provide insurance or financial services relating to) the newly sanctioned vessels; and

• UK financial services institutions, insurance providers, flag registries, vessel operators and other service providers will be prohibited from servicing the newly sanctioned entities.

The UK Government has granted two General Licences which provide limited wind-down periods (subject to record-keeping conditions), allowing UK persons to wind-down or divest from any transactions involving some of the newly designated persons, including the closing out of any positions. Third party UK service providers and UK financial institutions are also authorised to carry out any activity reasonably necessary to effect such wind-down. The wind-down periods will come to an end under the Russian Oil Majors General Licence on 28 November 2025 23:59 (GMT) and under the Other Energy Entities General Licence on 13 November 2025 23:59 (GMT).

Increased Secondary Sanctions Risk

‘Secondary sanctions’ are restrictive measures imposed by a government on third country persons in the event where those persons are deemed to act contrary to the government’s stated sanctions policy objectives. They are typically imposed by way of asset freeze designations in accordance with designation criteria set out in legislation underpinning the relevant sanctions programme. The UK has recently started using secondary sanctions under its sanctions programme against Russia to target entities in countries which are known as sanctions circumvention hubs.

The latest round of UK sanctions measures indicates that the UK Government is now actively exercising its ‘secondary sanctions’ powers against third-country entities (including China, India, and the UAE). Accordingly, there is likely to be a heightened risk of secondary sanctions for third-country businesses who are active in the energy, defence and financial institutions sectors, and have exposure to Russia and/or designated parties. Interestingly, one of the reasons why some of the Indian and Chinese refineries were added to the UK sanctions list is stated to be “dealing with UK-designated vessels”. This shows the increasing breadth of interpretation of the designation criteria under the UK’s sanctions legislation against Russia.

Intention to ban import of refined oil products

In its 15 October a Press Release, the UK also said that they “will ban imports of oil products refined in third countries from Russian-origin crude oil”. This indicates that the UK will follow in the EU’s footsteps and take action to close the “refining loophole” (although no details have been provided at this stage).

In its 18^th package of sanctions issued in July 2025 (on which we published a briefing – see here), the EU introduced an import ban on refined products derived from Russian crude oil – this ban will come into effect on 21 January 2026. On 16 October, the EU has only just issued Frequently Asked Questions (FAQs) on the evidence that importers will be required to provide upon importation of refined products into the EU in order to demonstrate compliance with the prohibition.

• The FAQs states that, while importers may be flexible as to the type of documentation they rely on as evidence of compliance, they are advised to insert specific contractual clauses with their suppliers “containing a guarantee (e.g. requesting an attestation of assurance) of non-Russian crude oil origin, giving rise to liability of the latter if it is established that Russia crude oil was used for refining of the imported products”.

• The FAQs also set out specific rules of segregation of Russian crude oil by refineries which refine Russian crude oil and also other crude oils, clarifying that if Russian crude oil cannot be segregated and processed separately then no import into the EU is allowed.

Commentary

UK persons with exposure to the newly designated entities and vessels will need to review existing contracts, consider the availability of wind-down periods under the relevant General licences, and take measures to suspend / terminate impacted contracts. 

Many multinational businesses will operate internal policies and mechanisms to comply with UK sanctions (despite not being established in the UK). As such, even in the absence of a UK nexus, global businesses and services providers may take a commercial decision not to transact with the entities and vessels sanctioned by the UK, particularly given the heightened secondary sanctions risks indicated above. Therefore, we would expect that the implications of the designations will go beyond merely the business operations and transactions which have a UK nexus.

At the moment it is not clear when more detail in relation to the UK’s refined products import ban will be made available and when the prohibitions against refined products will come into force. It also remains to be seen whether the practical guidance of crude oil segregation set out in the EU’s FAQs will be replicated by the UK.