Russia/Ukraine Sanctions Update - Month of July 2025

US Sanctions | EU Sanctions | UK Sanctions | Russia/Ukraine Sanctions

I. U.S. Sanctions 

• U.S. Treasury Department Sanctions Iranian Shipping Network that Transports Oil and Petroleum Products from Russia: On July 30, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against over 50 individuals and 50 vessels determined to be part of “the vast shipping empire controlled by Mohammad Hossein Shamkhani.” OFAC alleged the network “transports oil and petroleum products from Iran and Russia, as well as other cargo, to buyers around the world, generating tens of billions of dollars in profit.” Moreover, in 2024, Hossein’s network “was publicly exposed for its involvement in shipping missiles, drone components, and dual-use goods from Iran to Russia in exchange for shipments of Russian petroleum.” Read more >>
• President Trump Threatens Tariffs If Russia Fails to Make Progress with Ukraine Cease Fire: On July 29, Reuters reported that President Trump said that the United States would start imposing tariffs and other measures on Russia “10 days from today” if Moscow showed no progress toward ending its war in Ukraine. President Trump also indicated that he had not yet heard a response from Russia. According to the Guardian, shortly after President Trump’s announcement, Kremlin spokesperson, Dmitry Peskov, stated that Russia has an “immunity” to such actions as “[w]e been living under a huge number of sanctions for quite a long time, our economy operates under a huge number of restrictions.” Read more >> and Read more >>

II. EU Sanctions

• EU Adopts 18th Package Against Russia and Parallel Sanctions on Belarus: On July 19, the EU published its 18th package against Russia, along with mirror amendments to the Belarus sanctions regime. This comprehensive initiative combines individual sanctions and trade control measures, underscoring the EU’s determination to intensify pressure on Russia’s energy, banking and military industrial sectors. Moreover, the new measures cover sanctions circumvention, both inside and outside the EU. In particular, 11 entities in China, Hong Kong and Turkey identified as enabling circumvention of export restrictions have been added to Annex IV of Regulation 833/2014 and new catch-all controls on advanced technology items exports to third countries other than Russia and Belarus have been introduced. Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >> and Read more >>
• EU Imposes Additional Sanctions in View of Russia’s Destabilizing Activities: On July 15, the EU added nine individuals and six entities to the list of persons subject to asset freeze and travel ban measures under the EU sanctions regime in view of Russia’s destabilizing activities. The entities listed includes the Federal State-owned Enterprise “Russian Television and Radio Broadcasting Network” (RTRS), the BRICS Journalists Association (BJA), the Foundation to Battle Injustice (R-FBI) and the Center for Geopolitical Expertise (CGE). Read more >> and Read more >>
• EU Imposes Additional Sanctions in View of the Situation in Russia: On July 15, the EU added five individuals to the list of persons subject to asset freeze and travel ban measures under the EU sanctions regime in view of the situation in Russia. Read more >> and Read more >>
• EU Extends Sanctions Against Russia for a Further 6 Months: On June 30, the EU renewed the EU sanction measures in view of the Russian Federation’s continuing actions destabilizing the situation in Ukraine until January 31, 2026. Read more >>
• EU Commission Updates its Guidance on Sanctions Against Russia and Belarus: On July 23, the European Commission updated its guidance on enhanced due diligence for operators manufacturing and/or trading with CHP items, as well as on import, purchase and transfer of listed goods. The revised guidance on imports offers in particular a detailed explanation of the prohibition concerning primary aluminium, as set out in Article 3i of Regulation 833/2014. Read more >> and Read more >>
• EU Advocate General Opinion in Application of Russia Sanctions to Trusts: On July 10, Advocate General of the Court of Justice, Mr. Manuel Campos Sánchez-Bordona, delivered opinion further to a request for preliminary ruling referred by an Italian court addressing the question of whether freezing measures may be extended to assets or economic resources put into a trust by a settlor designated under Annex I of Regulation 269/2014. According to the interpretation provided by the Advocate General, subject to the specific terms of the trust and applicable law, the assets or resources of a trust may be considered as owned or held by a designated person. Read more >>
• EU Initiates Infringement Procedure Due to Sanctions: The European Commission decided to open infringement procedures by sending a letter of formal notice to 18 Member States (Belgium, Bulgaria, Czechia, Germany, Ireland, Greece, Spain, France, Croatia, Italy, Cyprus, Hungary, Malta, Austria, Poland, Portugal, Romania and Slovenia) for failing to notify measures fully transposing the Directive on the criminalization of the violation of Union restrictive measures (Directive (EU) 2024/1226). The Directive establishes common rules harmonizing the definition of criminal offences and penalties for the violation of Union restrictive measures. Member States had until 20 May 2025 to transpose the Directive into their national law. Read more >>
• EU Commission’s Measures to Prevent Vessel Sales: Members of the European Parliament have voiced their concern to the European Commission over recent reports that European and US ship owners have sold at least 230 ageing oil tankers to entities facilitating the Russian shadow fleet. They have requested clarification on the measures the European Commission intends to implement to prevent the sale of vessels to such entities in the future. The European Commission explained that EU sanctions restrict, but do not completely ban, the sale of oil tankers by EU operators and that the EU has also already designated 342 vessels, including those in Russia’s shadow fleet and those engaging in deceptive shipping practices. The Commission added that to strengthen enforcement, the EU now requires Ship Reporting Systems to include insurance certificate reporting, enhancing monitoring of maritime activities and addressing risks from uninsured or unsafe vessels. Read more >> and Read more >>
• Slovak Bearings Exports to Russia via Türkiye: It has been reported that in 2024, Slovak company Kinex Bearings A.S. exported over $1.1 million in ball and roller bearings to its Russian subsidiary via Turkish intermediaries, circumventing EU sanctions. High-quality bearings are crucial for Russian military equipment like tanks, missiles, and drones, making them a key focus of EU export controls. In particular, bearings have been included in the Common High Priority Items List agreed together by the EU together with the US, UK, and Japan. Read more >>

III. UK Sanctions

• OFSI issues £300k monetary penalty for UK sanctions breaches: On July 31, OFSI announced that it had issued a £300,000 penalty against Markom Management Limited (“MML”) for its instruction of a £416,590.92 payment on February 20, 2018, from another company’s bank account with the knowledge that the recipient was a designated person, having failed to put in place adequate compliance and controls procedures.  OFSI outlines some key lessons for industry, including that all firms, regardless of their size, should take appropriate steps to understand and address their exposure to sanctions risks; have adequate sanctions processes to ensure compliance including to promptly identify as well as report suspected breaches of financial sanctions to OFSI; and be alert to the risks of making payments in haste. Read more >> and Read more >>
• UK government amends one entry on the UK sanctions list under the Russia regime: On July 31, the UK amended the entry for Petr Aven on the UK sanctions list under the Russia regime. Read more >>
• UK Supreme Court dismisses Shvidler and Dalston Projects de-listing appeals: On July 29, the UK Supreme Court dismissed appeals by Eugene Shvidler and Dalston Projects Ltd against sanctions imposed against them.  The Court agreed that the sanctions had interfered with the appellants’ private lives under Article 8 of the ECHR, but rejects that those interferences were disproportionate and unlawful. Read more >>
• UK government amends two entries on the UK sanctions list under the Russia regime: On July 24, the UK made administrative amendments to two entries on the UK sanctions list under the Russia sanctions regime, namely Litasco Middle East DMCC and the Victor Konetsky, a specified ship. Read more >>
• UK government adds two entities to the UK sanctions list and specifies 135 ships under the Russia regime: On July 21, the UK added two entities, Intershipping Services LLC and Litasco Middle East DMCC, to the UK sanctions list and specified 135 ships under the Russia regime. At the same time, the entries on for Yegor Yurievich Karasev and OJSC Keremet Bank were updated on the UK sanctions list. Read more >> and Read more >>
• ECJU publishes general trade licence for the transfer of sectoral software and technology to Russia: On July 21, the ECJU published Notice to Exporters 2025/22 announcing the issuance of a General Trade Licence that permits inter the transfer of technology of business enterprise software and technology and the making available of business enterprise software and technology and ancillary services relating to business enterprise software and technology prohibited by Chapter 4N of the Russia (Sanctions) (EU Exit) Regulations 2019, subject to certain terms and conditions. This General Trade Licence expires on 20 October 2025. Read more >> and Read more >>
• UK issues general licence relating to the continuation of business Intershipping Services LLC under the Russia regime: On July 21, the UK Government issued General Licence INT/2025/6403704, which authorises vessels owned or operated by, or on behalf of, the Government of the Gabonese Republic, to continue certain business operations with Intershipping Services LLC, the authorised representative for the Maritime Administration of the Gabonese Republic.  The General Licence is of indefinite duration. Read more >> and Read more >>
• UK issues general licences relating to the wind down of positions involving Intershipping Services LLC and Litasco Middle East DMCC under the Russia regime: On July 21, the UK Government issued General Licence INT/2025/6397444, which authorises the wind down of transactions involving Intershipping Services LLC, and General Licence INT/2025/6488808, which authorises the wind down of positions involving Litasco Middle East DMCC. Each General Licence expires on September 18, 2025. Read more >> and Read more >>
• UK Lowers Oil Price Cap on Seaborn Russian Crude Oil, OFSI publishes related FAQs: On July 18, the UK Government, alongside the EU, announced that it will lower to Oil Price Cap on seaborne Russian crude oil from $60 to $47.50 with effect from 23:01 BST, September 2, 2025.  This will apply to all services capture by the Oil Price Camp, including maritime transportation and the provision of brokering services, financial services or funds related to the maritime transport of Russian crude from a place in Russia to a third country, or from one third country to another.  At the same time, OFSI published FAQs 154 to 161 to support industry to adapt to the lower price cap and to explain the 45-day wind down period, published updated Oil Price Cap guidance, and updated the Oil Price Cap general licence. Read more >>, Read more >>, Read more >> and Read more >>
• UK issues General Licence allowing non-designated persons to make certain transfers to a non-designated broker: On July 18, the UK Government issued General Licence INT/2025/6641960, which inter alia allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker, subject to certain terms and conditions.  The expiry date of the General Licence is 16 July 2026. Read more >> and Read more >>
• UK Government adds four entries to the UK sanctions list under the Russia sanctions regime: On July 18, OFSI added three individuals (Artyom Sergeevich Kureyev, Anna Sergeevna Zamaraeva, Victor Aleksandrovich Lukovenko) and one entity (African Initiative) under the Russia sanctions regime. . According to the UK Government, the measures target GRU military intelligence officers who previously targeted Yulia Skripal’s device with malicious malware. Read more >> and Read more >>
• HMRC agrees £1 million compound settlement in relation to breaches of Russia sanctions: On July 8, HMRC published details of a compound settlement in relation to a UK exporter that made goods available to Russia in breach of The Russia (Sanctions) (EU Exit) Regulations 2019. The compound settlement involved a penalty of £1,160,725.67 which was paid to HMRC in May. This is the largest compound settlement HMRC has concluded for a Russia sanctions offence. Read more >>
• UK issues Red Alert on Russia ‘shadow fleet’ sanctions evasion and avoidance network: On July 6, the UK Government published a Red Alert on shadow fleet sanctions evasion and avoidance.  Issued jointly by the National Crime Agency (NCA), the National Economic Crime Centre (NECC), and OFSI among others, the Red Alert provides information to assist financial institutions in identifying potential sanctions evasion in relation to the sale of Russian oil and gas. Read more >>
• UK Government moves General Licence relating to the wind down of position involving St Petersburg Currency Exchange and JSC Petersburg Settlement Center to expired General Licences page: On July 2, the UK Government moved General Licence INT/2025/6275812 to the expired General Licences page of the UK Government website.  The General Licence authorised the wind down of transactions involving either St. Petersburg Currency Exchange or Non-bank Credit Organization Joint-Stock Company Petersburg Settlement Center, subject to certain terms and conditions, and expired on June 19, 2025. Read more >>
• UK government amends three entries on the UK Sanctions list under the Russia regime: On July 1, the UK amended the entries for Anatoliy Moiseevich Cherner, Yegor Yurievch Karasev, and the Main Directorate of Deep-Sea Research of the Ministry of Defence of the Russian Federation on the UK sanctions list under the Russia regime. Read more >>
• The Council for Licensed Conveyancers (CLC) publishes updated advisory note on compliance with UK sanctions: On July 1, the CLC published an updated advisory note which inter alia states that the sanctions regime applies to all CLC practices regardless of what kind of services they offer, including conveyancing, probate and all CLC permissions such as will writing and power of attorney work. Read more >>
• Mikhail Vlasov pleads not guilty in relation to eight charges of UK sanctions violations in connection with the alleged sending of cryptocurrency to militia groups in the LNR and DNR: On July 1, Mikhail Vlasov, a Russian-British dual national, pleaded not guilty in relation to eight counts of breaching UK sanctions by sending Bitcoin to pro-Russian separatist militias in eastern Ukraine to fund weapons and military equipment. Read more >>
• UK Government updates UK support to Ukraine: factsheet: On June 30, the UK government updated the UK support to Ukraine: factsheet, which summarises how the UK is supporting Ukraine following the Russian invasion. Read more >>
• UK Government extends Sakhalin 2 exemption under two General Licences: On 27 June, OFSI extended General Licence INT/2025/5635700, which authorises certain activities with Gazpromneft-Sakhalin LLC in relation to Sakhalin-2, and General Licence INT/2022/2470156, which permits the maritime transfer of Russian oil below a certain price cap, each subject to certain terms and conditions.  The Sakhalin-2 exemption in each general licence has been extended to June 28, 2026. Read more >>, Read more >>, Read more >> and Read more >>
• UK government updates 16 entries on the UK sanctions list under the Russia regime: On 26 June, the UK updated 16 entries on the UK sanctions list under the Russia regime. Read more >>
• UK Solicitors Regulatory Authority “rebukes” law firm for failure to comply with OFSI licences: On June 24, the SRA published a regulatory settlement agreement with Steptoe International (UK) LLP for failing to comply with certain conditions of two OFSI licences. According to the agreement, the law firm was formally ‘rebuked’ and was ordered to pay £600 in relation to the costs of the investigation. Read more >>

IV. Russia/Ukraine Sanctions

• Ukraine introduces new law targeting Russia’s shadow fleet: On July 30, Ukraine introduced a new law that enables sanctions to be imposed on sea and air vessels that transport oil and petroleum products, as well as those carrying weapons or troops. Read more >>
• Ukraine imposes sanctions on 45 individuals and 50 companies: On July 27, President Zelenskyy enacted decree No. 555/2025 which imposed sanctions on 45 individuals and 50 companies linked to Russia’s defence industry. The sanctions focused on, amongst other things, preventing the transfer of capital outside of Ukraine, the suspension of discharge of economic and financial obligations and the blocking of assets. Read more >> and Read more >>
• Ukraine imposes sanctions on 5 individuals: On July 20, President Zelenskyy enacted decree No. 502/2025 which imposed sanctions on five individuals. Read more >>
• Ukraine imposes sanctions on 190 individuals and 200 legal entities: On July 8, President Zelenskyy enacted decrees No. 465/2025, No. 471/2025; No. 472/2025 and No. 473/2025, imposing sanctions on 190 individuals and 200 legal entities. Read more >>, Read more >>, Read more >> and Read more >>