Russia/Ukraine Sanctions Update - Month of December 2025

US Sanctions | EU Sanctions | UK Sanctions | Other Notable Developments

I. U.S. Sanctions 

• U.S. Is Prepared to Issue New Russia Sanctions if Putin Rejects Ukraine Peace Deal: According to Bloomberg and Reuters, on December 17 the United States was reported to be preparing an additional round of sanctions targeting Russia’s energy sector to increase pressure on Moscow should it reject a peace deal with Ukraine. That said, a White House official told Reuters that President Donald Trump had made no new decisions regarding Russian sanctions. Read more>>
• OFAC Announces $1 Million Settlement with Individual Relating to Russia Sanctions Violations: On December 9, OFAC announced a $1,092,000 settlement with an individual to resolve civil liability for 122 apparent violations of OFAC’s Russia sanctions. Specifically, between April 2018 and June 2022, the individual allegedly served as the fiduciary of the U.S.-based family trust of a sanctioned Russian oligarch. In that capacity, the individual allegedly dealt in the oligarch’s blocked property and provided prohibited services to the oligarch. OFAC emphasized that the individual’s conduct was non‑egregious and not voluntarily self‑disclosed, and that the individual substantially cooperated with OFAC’s investigation. Read more>>
• U.S. Special Envoy for Peace Meets with Ukrainian Representatives: On December 5, U.S. Special Envoy for Peace, Steven Witkoff, and Jared Kushner met with Rustem Umerov, the Secretary of the National Security and Defense Council of Ukraine, and General Andriy Hnatov, the Chief of the General Staff, “for constructive discussions on advancing a credible pathway toward a durable and just peace in Ukraine.” During the meeting, Secretary Umerov reaffirmed that Ukraine’s priority is securing a settlement that protects its independence and sovereignty, ensures the safety of Ukrainians, and provides a stable foundation for a prosperous democratic future. Read more>>
• OFAC Announces $7 Million Civil Penalty Relating to Dealings with Sanctioned Russian Property: On December 4, OFAC announced that it assessed a $7,139,305 civil monetary penalty against Gracetown, Inc. for alleged violations of OFAC’s Russia sanctions arising from its alleged dealings in the property of sanctioned Russian oligarch, Oleg Deripaska, and related reporting obligations. Specifically, between April 2018 and May 2020, Gracetown allegedly knowingly accepted 24 monthly payments totaling $31,250 from an entity owned by Deripaska. OFAC emphasized that the penalty reflected its determination that Gracetown’s conduct was egregious and not voluntarily self-disclosed. Read more>>
• OFAC Issues Amended Russia-Related General Licenses: On December 4, 10, and 17, OFAC amended several general licenses authorizing limited transactions involving Lukoil retail service stations outside Russia; the negotiation of and entry into contingent contracts for the sale of Lukoil International GmbH and related maintenance activities; certain services related to Sakhalin-2; and certain transactions related to civil nuclear energy. Read more>>
• OFAC Announces $11 Million Settlement Agreement Relating to Russian Sanctions Violations: On December 2, OFAC announced an $11,485,352 settlement with IPI Partners, LLC to resolve potential liability for 51 alleged violations of OFAC’s sanctions against Russia. Specifically, in 2017 and 2018, IPI was alleged to have solicited and received investments from Russian oligarch, Suleiman Kerimov, through a series of legal structures, and to have continued to maintain those investments for four years after OFAC designated Kerimov on April 6, 2018. OFAC emphasized that the settlement amount reflected that IPI’s conduct was non‑egregious and not voluntarily self‑disclosed. Read more>>

II. EU Sanctions

• EU Prohibits Transfers of Immobilized Central Bank of Russia Assets Back to Russia: On December 12, the EU adopted an ad hoc mechanism to temporarily, but indefinitely, immobilize the Central Bank of Russia’s assets. Concretely, the agreed measure prohibits, on a temporary basis, any direct or indirect transfer of assets or reserves of the Central Bank of Russia, or of any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Russia, such as the Russian National Wealth Fund. Read more>> and Read more>>
• EU Sanctions Shadow Fleet Enablers: On December 15, the EU added five individuals and four entities responsible for supporting Russia’s shadow fleet and its value chain to the list of natural and legal persons subject to asset freeze and/or travel ban measures. The entities targeted are shipping companies based in the United Arab Emirates, Vietnam and Russia which own or manage tankers that are subject to EU sanctions. Read more>> and Read more>>
• New Asset Freeze Designations in Response to Russia’s Hybrid Threats: On December 15, the EU added 12 individuals and two entities involved in Russia’s continued hybrid activities to the list of natural and legal persons subject to asset freeze and/or travel ban measures. These designations target foreign information manipulation interference, malicious cyber activities, electronic warfare, foreign-policy analysts, pro-Russian propaganda influencers, international Russophile movements, and members of the Russian military intelligence, including US, Swiss, and French citizens. Read more>> and Read more>>
• EU Extends the List of Designated Vessels: On December 19, the EU designated 41 vessels that are part of Russia’s ‘shadow fleet’ of oil tankers and contribute to Russia’s energy revenues. These vessels are now subject to an EU port ban, as well as a ban on a broad range of activities and services. Read more>> and Read more>>
• New Asset Freeze Designations in Response to Human Rights Violations in Russia: On December 22, the EU added two persons responsible for serious violations of human rights to the list of natural persons subject to asset freeze and travel ban measures. Read more>> Read more>>
• EU Extends Economic Sanctions in View of Russia’s Destabilizing Actions for a Further 6 Months: On December 22, the EU renewed sanctions in view of Russia’s continuing actions destabilizing the situation in Ukraine for a further 6 months, until 31 July 2026. These economic measures, first introduced in 2014, have been significantly expanded since February 2022 and currently consist of a broad spectrum of sectoral measures, including restrictions on trade, finance, energy, technology and dual-use goods, industry, transport and luxury goods. Read more>>
• EU Extends its Global Human Rights Sanctions Regime for Another Year: On December 4, the EU renewed sanctions for serious human rights violations and abuses for another year, until 8 December 2026. These sanctions currently apply to 135 persons and 37 entities subject to an asset freeze and/or a travel ban. At the same time, the designation entries concerning 27 natural persons, and 12 entities were updated. Read more>> and Read more>>
• EU Commission Comments on the Economic Impact of the Russia Sanctions: The European Commission has been requested by a Member of the European Parliament to comment on the competitiveness challenges faced in sectors such as the fertilizer, glass, chemical, and energy industries as a result of EU sanctions targeting Russia. The Commission explained that EU sanctions decided by the Council unanimously have been imposed to curtail Russia’s war financing, impose economic and political costs, and weaken Russia’s economic base, while being regularly reviewed, strictly enforced (including against circumvention via third countries), and that any assessment of their overall impact should be sought from the European Commission. Read more>> and Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Several Individuals and One Entity: By its judgments delivered in December, the General Court dismissed the actions brought by Mr. Gennady Nikolayevich Timchenko, Ms. Elena Petrovna Timchenko, Mr. Alexander Dmitrievich Pumpyanskiy, Ms. Aleksandra Melnichenko and a Russian limited liability company SBK Art OOO challenging their listings. Read more>>, Read more>>, Read more>>, Read more>> and Read more>>
• Belgian-Luxembourg Lobby Accused of Giving Sanctions Evasion Advice: A recent online seminar organized by the Belgian-Luxembourg Chamber of Commerce in Russia has raised questions about whether the chamber is indirectly advising companies on ways to circumvent EU sanctions against Russia. During the seminar, an experienced Russian financial manager reportedly advised participants on “alternative payment channels and digital transactions,” essentially addressing the challenges posed by the disconnection of many Russian banks from the SWIFT system and the suspension of key payment systems. Read more>>
• The Netherlands Prosecutes Sanctions Evasion Through the Export of Dual-Use Goods: The Dutch Financial Intelligence Unit reported that a Dutch court of first instance convicted two people for sanctions violations after a bank reported a customer selling products subject to EU sanctions to a country often used for circumvention routes. The analysis of the unusual transaction showed that, prior to the war in Ukraine, the company had exported the goods to customers in Russia. Read more>>
• Germany Investigates Sale of Luxury Cars to Russia: The Munich prosecutor's office is investigating a case involving businessmen who illegally sold 50 luxury cars, including an armored Mercedes, to Russia for over 10 million euros. Read more>>
• Suspect Oil Shipment to Georgia Draws Scrutiny: A background report published by a leading transparency watchdog group in Tbilisi highlights the sketchy ownership structure of a tanker that delivered oil from Russia to Georgia, raising suspicions that the shipment was part of a sanctions-busting endeavor. Read more>>

III. UK Sanctions

• OFSI publishes seven FAQs regarding Arbitration Costs General Licence: On December 23, OFSI added seven FAQs (Q177-Q183) to their FAQs page. These were added to answer questions about the application and scope of the Arbitration Costs General Licence INT/2025/5787748, which authorises certain payments to be made to an Arbitrator or an Arbitration Association in relation to arbitration proceedings, subject to certain terms and conditions, under both the Russia and Belarus regimes. Read more>>
• UK Government adds 25 entries to the UK sanctions list under the Russian regime: On December 19, OFSI added one entry to the UK sanctions list under the Russia regime and on December 18, 2025, OFSI added 24 entries to the UK sanctions list under the Russia regime. These individuals and entities are subject to an asset freeze. Read more, Read more and Read more>>
• OFSI issues General Licence for the winding down of Russian oil companies: On December 18, OFSI issued General Licence INT/2025/8202932 which authorises persons to wind down from any transactions involving the designated persons to which that person is a party, subject to terms and conditions. This General Licence expires on 31 January 2026. Read more>> and Read more>>
• OFSI amends General Licence for Russian Oil Exempt Projects: On December 17, OFSI amended General Licence INT/2025/5635700, which authorises the continuation of business operations with the Relevant Subsidiary to the extent they are in relation to the Exempt Projects, subject to certain terms and conditions. This amendment added the Zohr project to the list of Exempt Projects. Additionally, the permissions of the General Licence were amended. The date of expiration of the General Licence depends on the Exempt Project, with the expiry date being 14 October 2027 for most Exempt Projects. Read more>> and Read more>>
• OFSI amends General Licence relating to Russian travel: On December 12, OFSI amended General Licence INT/2022/1839676, which authorises UK persons to purchase tickets from certain Russian airlines and railway companies, subject to certain terms and conditions.  In particular, the general licence was expanded to cover the purchase of tickets from JSC Siberia, and the general licence was extended to May 22, 2028. Read more>>
• UK Government adds seven entriesto the UK Sanctions list under the Russia regime: On December 9, the UK Government added Aleksandr Geljevitj Dugin, Mikhail Sergeevich Zvinchuk, Center for Geopolitical Expertise, Euromore, Foundation for the Support and Protection of the Rights of Compatriots Living Abroad, Golos and RYBAR LLC to the UK sanctions list under the Russia regime. According to the UK Government, these entities are involved in running or supporting foreign information manipulation and interference operations including by flooding social media with counterfeit documents and deepfake material in English, German and French to advance Russia’s strategic aims. Read more>> and Read more>>
• UK Government adds four entries to the UK Sanctions List under the Russia regime: On December 4, the UK Government added Vladimir Lipchenko, Yuriy Alekseevich Sizov, Denis Alexandrovich Smolyaninov and the Main Directorate of the General Staff of the Armed Forces of the Russian Federation to the UK sanctions list under the Russia regime. According to the UK Government, these measures target Russia’s military intelligence agency, the GRU, and three of its officers who are responsible for orchestrating hostile activities in Ukraine and across Europe. Read more>> and Read more>>
• OFSI amends General Licence for transactions related to agricultural commodities under the Russia Regulations: On November 28, OFSI amended General Licence INT/2022/2349952, which authorises certain exporters and trade licence holders to receive or transfer funds or economic resources in connection with the export, sale, production and transport of agricultural commodities, subject to certain terms and conditions. The amendments to the General Licence reflect changes to Schedule 3E Part 2A of the Russia Regulations, expending the definition of fertiliser to include those permitted under commodity code 2814 and its subheadings. Read more>>
• UK Government updates one entry on the UK Sanctions list under the Russia regime: On November 28, the UK Government amended the entry for Sergey Vladimirovich Mikhailov under the Russia regime, This individual remains subject to an asset freeze. Read more>>
• OFSI issues General Licence for the Continuation of Business of Lukoil International Entities and publishes related FAQ: On November 27, OFSI issued General Licence INT/2025/8031092 under the Russia regime.  This General Licence authorises UK persons to continue business operations involving Lukoil International GmbH and its subsidiaries, including payments and the provision and receipt of economic resources, subject to certain terms and conditions. The General Licence expires on February 26, 2026.  OFSI also published FAQ 174, which states that any renewal of this General Licence would be considered in the context of the ongoing negotiations on the sale of PJSC Lukoil’s international assets. Read more>> and Read more>>
• UK Court rejects application anti-suit due to risk of breaching EU sanctions: On November 25, the UK Commercial Court handed down its judgment in FH Holding Moscow Ltd v AO UniCredit (Russia) and UniCredit SPA (Italy) [2025] EWHC 3111 (Comm).  FH Holdings, which operate in Russia, had borrowed funds from UniCredit, an Italian bank, in 2018 under a facility agreement governed by English law which referred disputes to arbitration in Vienna. FH Holdings provided Russian property as security for the loan under a separate agreement with UniCredit AO, which referred disputes to the Russian courts.  In March 2025, Unicredit AO filed a claim in Moscow seeking foreclosure of FH Holdings’ mortgaged Russian assets.  FH Holdings applied to the UK Courts for an anti-suit injunction to restrain the Russian proceedings.  The Court rejected the application stating that the risk the Russian courts would compel, FH Holdings to breach EU sanctions was too remote to justify interference with the Russian proceedings, and that (ii) UK public policy of supporting EU Russia sanctions cannot create sufficient interest for the UK court to issue an anti-suit injunction where there are no other links to English jurisdiction. Read more>>
• NCA exposes billion-dollar money laundering network that purchased bank to fund Russian war effort: On November, 21, the UK’s National Crime Agency (“NCA”) issued a press release with updated information on Operation Destabilise, an international probe into a billion dollar money-laundering network active in the United Kingdom that reportedly purchased a Kyrgyzstan bank to facilitate sanctions evasion and payments in support of Russian military efforts. According to the press release, the NCA has supported its international law enforcement partners in seizing $24 million and over EUR 2.6 million from the network, in addition to 128 arrests and the seizure of more than £25 million in cash and cryptocurrency in the United Kingdom alone. Read more>>
• UK High Court enforces arbitral order requiring withdrawal of Russian proceedings brought to frustrate EU sanctions: On November 21, the UK High Court handed down judgment in Tecnimont SpA and MT Russia v EuroChem NW2 and EuroChem [2025] EWHC 3151 (Comm). In the case, Tecnimont obtained anti-suit relief to restrain EuroChem NW2 from pursuing Russian proceedings commenced in breach of an English arbitration agreement.  EuroChem NW2 had  commenced the Russian proceedings to restrain the English arbitration and pursue its arbitral claims before the Russian courts, following the High Court’s determination earlier in 2025 that EuroChem NW2 was controlled by an assets freeze target (Andrey Melnichenko). Read more>>

IV. other notable developments

• Switzerland Imposes New Sanctions Relating to Russian Information Manipulation and Cyberattacks: On December 19, Switzerland, in line with the EU, announced new sanctions on 12 individuals and two entities for information manipulation and cyberattacks. Those targeted by Switzerland’s sanctions were determined to be analysts and influencers linked to pro-Kremlin networks who have promoted pro-Russian propaganda. Among them are five experts associated with the Valdai Club, a Russia-based international forum and think tank at which President Vladimir Putin speaks annually. Read more>>