Russia/Ukraine Sanctions Update - Month of February 2026

US Sanctions | EU Sanctions | UK Sanctions | Russia/Ukraine Sanctions | Other Notable Developments 

I. U.S. Sanctions

• OFAC Issues Amended Russia-Related General License and FAQs: On February 26, OFAC issued General License 131C, which extends the authorization of certain transactions for the negotiations/contingent contracts for the sale of Lukoil International GmbH and related maintenance activities through 12:01 a.m. eastern daylight time, April 1, 2026, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from OFAC. OFAC also issued two amended Frequently Asked Questions (“FAQs”) on Russia. Read more >>
• Ukraine-Russia Peace Talks Continue: According to Reuters, on February 23, President Volodymyr Zelenskiy's chief of staff told Ukrainian media that another round of Ukraine-Russia peace talks could be held soon. U.S. and Ukrainian negotiators then reportedly met for hours in Geneva on February 26 “to prepare for the next round of trilateral peace negotiations.” Over the past few months, Ukraine, Russia, and the United States have held several rounds of talks in Abu Dhabi and Geneva. Read more >>, Read more >>
• State Secretary Call with G7 Foreign Ministers Discusses Russia-Ukraine War: On February 14, Secretary of State, Marco Rubio, spoke with G7 foreign ministers. The leaders discussed several topics, including “negotiating an end to the Russia-Ukraine war.” Read more >>

II. EU Sanctions

• EU Imposes New Sanctions on Russian Individuals: On February 23, the Council added eight individuals responsible for serious violations or abuses of human rights and the repression of civil society and democratic opposition in Russia to the list of natural and legal persons subject to asset freeze and/or travel ban measures. Read more >>, Read more >>
• EU Sanctions Against Russia Extended for a Further Year: On February 23, the EU prolonged its sanctions measures in response to the illegal recognition, occupation or annexation by Russia of certain non-government controlled areas of Ukraine until February 24, 2027. Read more >>
• Distortions of Competition and Possible Circumvention of EU Sanctions: A Member of the European Parliament questioned the European Commission on the prohibition to export certain components for rail transport from the EU to Russia and Belarus, while companies based in Belarus or in which Belarus has a stake can continue to export comparable products to the EU, even if they are simultaneously exporting identical or similar products to Russia through EU subsidiaries or joint ventures. The Commission explained that any company operating in the EU, including branches of Belarusian companies, must comply with EU sanctions. The Commission also reaffirmed that it continuously monitors the situation and proposes adjustments to the measures where necessary with a view to strengthening their implementation and preventing their circumvention. Read more >>, Read more >>
• Use of Georgian Refineries to Evade EU Sanctions on Russian Oil Exports: On February 3, the European Commission reacted to information on the potential routing of Russian oil through Georgia. The Commission recalled that a new ban on imports into the EU of refined oil products produced in third countries using Russian crude oil took effect on January 21, 2026. As of that date, operators must exercise enhanced due diligence when importing refined petroleum from third countries, including Georgia, to ensure that those products are not obtained from Russian crude oil. In addition, as a candidate country, Georgia is subject to heightened expectations and scrutiny regarding its alignment with the EU acquis, including the Common Foreign and Security Policy and EU sanctions. The Council is also entitled to list refineries and other entities in third countries like Georgia. Read more >>, Read more >>
• Flags of Convenience for the Russian Shadow Fleet: On February 3, the European Commission responded to a question regarding the possibility of taking action against countries providing flags of convenience to vessels linked to the Russian shadow fleet. According to the Commission, the EU is fully engaged in discussions with like-minded partners, including the G7 and the Nordic-Baltic 8 Shadow Fleet Task Force, to further facilitate the preparation of additional measures against the Russian shadow fleet. The EU also continues conducting outreach to flag states to ensure that ship registers do not allow shadow fleet tankers to sail under their flag and has appointed a coordinator on the shadow fleet within the European External Action Service. Read more >>, Read more >>
• Circumvention of EU Sanctions: On February 3, the European Commission commented on its efforts to combat circumvention of its sanctions measures through Central Asian countries. It reaffirmed that preventing sanctions circumvention remains a priority, and especially preventing the re-export of EU-origin Common High Priority (CHP) items considered vital for Russia's war effort. The Commission monitors trade flows of these items from the EU to Central Asia and their potential re-exports to Russia. The EU Sanctions Envoy regularly engages with Central Asian countries where suspicious trade flows have been identified, notably Kazakhstan, Kyrgyzstan and Uzbekistan. According to the Commission, this engagement has led those countries to adopt measures to address circumvention as trade data shows that after the peaks observed between late 2022 and mid-2023, there has been a significant decrease in the export of CHP items from these countries to Russia. Read more >>, Read more >>
• Charges Against Former Commissioner for Justice for Money Laundering and Ties to Sanctioned Oligarch: On February 5, the European Commission commented on the investigation into former Commissioner for Justice Didier Reynders's alleged links to Russian oligarch Oleg Deripaska. The Commission clarified that it has not been involved in any investigations regarding the charges brought against the former Commissioner for Justice and is not aware of any link between him and any Russian oligarch. At this stage, based on the currently available information, the Commission has no reason to perform any audit linked to the exercise by the former Commissioner for Justice of his duties as a Member of the Commission. Read more >>, Read more >>
• Russian Nickel Trade via EU’s Port in Rotterdam: The European Commission was questioned on companies operating in the Port of Rotterdam, the Netherlands, and playing a key role in the export of Russian nickel to Europe and beyond. The Commission indicated that EU sanctions reflect a careful balance between the EU's determination to impact Russia's ability to finance its war of aggression and limiting, to the extent possible, negative impacts on Member States and industry, taking into account shortages of certain critical raw materials. Read more >>, Read more >>
• Advocate General Opinion on Meaning of “Operator” in Broadcast Prohibition Targeting Russia: By its opinion issued on February 12, Advocate General Norkus proposed that the EU Court of Justice should answer the preliminary ruling question referred by the Regional Court of Saarbrücken, Germany, by interpreting that the concept of "operator" under Article 2f(1) of Council Regulation No 833/2014 includes natural persons operating a website, irrespective of whether such persons derive income in any form from that operation. Read more >>
• Advocate General Opinion on Enforcing Sanctions Over Conflicting Arbitral Awards: By its opinion issued on February 26, Advocate General Biondi proposed that the EU Court of Justice should answer the preliminary ruling question referred by the Svea Court of Appeal, Stockholm, Sweden, by holding that the prohibition on satisfying any claim of a Russian entity in respect of a contract the performance of which has been affected by sanction measures does form part of the public policy of the Union. A national court must therefore ensure – of its own motion, if necessary – that the arbitration tribunal has acted in line with that prohibition. If it has not, the national court must draw all the appropriate conclusions provided for by national law and set aside the arbitration award on the basis of a breach of EU public policy. Read more >>
• Advocate General Opinion on Implementation of EU Sanctions and the Scope of National Discretion and Judicial Review: By its opinion issued on February 26, Advocate General Manuel Campos Sanchez-Bordona proposed that the EU Court of Justice should answer the preliminary ruling question referred by the Supreme Administrative Court of Lithuania by holding that EU law does not preclude a Member State from adding a person to a national asset-freezing list, even if that person is not designated in the EU's own sanctions annexes, without giving that person the opportunity to challenge the listing before it takes effect. The Advocate General also proposes the interpretation that EU law permits national courts to rely on circumstantial evidence when assessing whether a company is subject to control by Russian political authorities. Read more >>
• EU Court of Justice Interprets the Prohibition on Importing Certain Goods from Russia: By its judgement delivered on February 5, the Court of Justice answered the preliminary ruling question referred by the Düsseldorf Finance Court, Germany, by holding that the prohibition under Article 3i(1) of Council Regulation No 833/2014 on purchasing, importing or transferring into the EU certain goods listed in Annex XXI to that Regulation applies to all goods listed that annex without it being necessary to verify, for each individual transaction, whether the purchase, importation or transfer in question generates significant revenues for Russia. Read more >>
• EU Court of Justice Dismisses Appeal Brought by VEB.RF: By its judgment delivered on February 5, the Court of Justice dismissed the appeal brought by the State Development Corporation 'VEB.RF' challenging the General Court's dismissal of its action against its listing. Read more >>
• EU General Court Annuls Sanctions Listing of Ms. Tokareva: By its judgment delivered on February 11, the General Court annulled the September 2025 acts maintaining Ms. Maya Tokareva on the Russia-related sanctions list. The General Court noted that to comply with Article 266 TFEU, the Council should have either removed Ms. Tokareva's name from the lists at issue, or adopted new measures with the same grounds for listing subject to producing new evidence, or amended those grounds. Read more >>
• EU Court of Justice Interprets Sanctions Against Russia in the Context of Public Procurement: By its judgement delivered on February 12, the Court of Justice answered the preliminary ruling question referred by the Italian Council of State by holding that public contracts may still be awarded to EU resident companies with Russian nationals sitting as board members, but only after the awarding authority verifies that there is no plausible risk that the funds which will be paid to that company under the contract in question will be diverted to the Russian economy and where it has not been established, or is at least highly unlikely, that that administrator has de facto control over that company. Read more >>
• Germany Arrests Five Persons Accused of Smuggling Western Tech to Russia: On February 2, German police arrested five men and accused them of running a smuggling operation for Russian intelligence to supply at least two dozen Russian arms manufacturers with European technology, in breach of EU sanctions. The group is accused of delivering more than 16,000 shipments to at least 24 Russian arms companies since 2022. In total, the group smuggled goods worth more than €30mn from Europe. Read more >> 

III. UK Sanctions

• UK Government updates UK Sanctions List with 297 new designations under the Russia regime: On February 24, the UK Government updated the UK Sanctions List under the Russia (Sanctions) (EU Exit) Regulations 2019, adding 240 companies and organisations, 7 individuals and 50 vessels to the list of persons and entities subject to financial sanctions, asset freezes and related restrictions as part of the UK’s Russia sanctions regime. This package represents one of the largest expansions of UK sanctions against Russia since the start of the full-scale invasion of Ukraine, targeting key Russian energy sector operators (including Transneft and Rosatom Energy Projects), associated organisations, shadow shipping networks, financial institutions, and transport vessels involved in the export of Russian oil and gas. Read more >>, Read more >>, Read more >>
• OFSI amends General Licence for Russian Oil Exempt Projects: On February 24, OFSI amended General Licence INT/2025/5635700, which authorises a Person to continue business operations with the Relevant Subsidiary to the extent that those operations relate to the Exempt Projects, subject to specified terms and conditions. This General Licence was amended to include any entity owned or controlled, directly or indirectly, by PJSC Transneft, following its designation by the UK. The General Licence remains in force subject to its existing terms and expiry provisions. Read more >>
• OFSI issues General Licence for the winding down of Maritime Mutual re-insurance policies: On February 24, OFSI issued General Licence INT/2026/8893924, which authorises Persons to wind down insurance and re-insurance contract activity involving Maritime Mutual Association Limited (Gibraltar), Maritime Mutual Insurance Association (NZ) Limited and their subsidiaries to which that Person is a party, subject to specified terms and conditions. This General Licence takes effect from February 24, 2026, and expires on April 9, 2026. Read more >>, Read more >>
• OFSI issues General Licence for the winding down of transactions involving PJSC Transneft: On February 24, the OFSI issued General Licence INT/2026/8889196, which authorises Persons to wind down from any transactions involving PJSC Transneft or its Subsidiaries to which that Person is a party, subject to terms and conditions. This General Licence takes effect from February 24, 2026, and expires on April 9, 2026. Read more >>
• OFSI amends and extends General Licence for Personal Remittances: On February 23, OFSI amended and extended General Licence INT/2024/4761108, which authorises a Person to use the retail banking services of a designated Credit or Financial Institution provided that the payments made or received are intended for the personal use of that Person, subject to specified terms and conditions. This amendment included an extension of the licence’s expiry date to April 3, 2030 (originally scheduled to expire on May 27, 2026) and updates to the licence conditions to reflect evolving requirements for permitted personal remittances and reporting obligations. Read more >>, Read more >>
• UK Government varies an entry on the UK Sanctions List under the Russia regime: On February 13, the FCDO amended the listing for Saodat Narzieva, sister of Alisher Usmanov, who is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 and was designated by the UK on March 3, 2022. The variation removes the reference to Narzieva "obtaining a financial or other material benefit from Usmanov". Narzieva remains subject to sanctions. Read more >>, Read more >>
• OFSI amends General Licence for the continuation of business operations with the Lukoil Bulgaria Entities under the Russia regime: On February 10, OFSI extended General Licence INT/2025/7895596 until August 13, 2026. The licence permits certain persons to continue business operations with the Lukoil Bulgaria entities and their subsidiaries, including payments under existing or new contracts and the provision and receipt of economic resources. OFSI also updated FAQ 173 to reflect the extended expiry date. Read more >>, Read more >>
• UK Government corrects an entry on the UK Sanctions List under the Russia regime: On February 10, the FCDO amended the listing for the vessel Lunar Tide (IMO 9277735) under the Russia sanctions regime. The vessel is designated for involvement in activities that destabilise Ukraine, undermine its territorial integrity, sovereignty or independence, or benefit or support the Russian Government—specifically, transporting Russian-origin oil or oil products to third countries. The vessel remains subject to shipping sanctions. The correction removed Tazmania as the vessel's believed flag. Read more >>, Read more >>
• OFSI amends General Licence for Humanitarian Activity: On February 5, OFSI amended General Licence INT/2022/1947936, which authorises a Relevant Person to ensure the timely delivery of humanitarian assistance activity in relation to the conflict in Ukraine and non-government controlled Ukrainian territory, subject to certain terms and conditions. This General Licence was amended to reflect Bank Otkritie’s merger with BM-Bank. This General Licence took effect on July 7, 2022. Read more >>
• OFSI amends General Licence for Payments by Revenue Authorities: On February 2, OFSI amended General Licence INT/2025/7328184, which authorises a Revenue Authority to make Permitted Payments to UK Designated Persons frozen UK bank accounts, subject to certain terms and conditions. This General Licence was amended to include the Welsh Revenue Authority and Revenue Scotland definitions . This General Licence took effect on September 26, 2025. Read more >>

IV. Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In February 2026, the President of Ukraine adopted 10 Orders extending the sanctions to 140 legal entities and 383 individuals. The sanctions were also imposed against 91 vessels of the shadow fleet registered in various jurisdictions and used to transport Russian oil. The new sanctions were imposed by the Orders No. 94/2026 and 95/2026 dated 2 February 2026, No. 102/2026 and 103/2026 dated 7 February 2026, No. 121/2026 dated 12 February 2026, No. 123/2026 dated 16 February 2026, No. 125/2026 dated 18 February 2026, No. 130/2026 and 131/2026 dated 21 February 2026, No. 161/2026 dated 24 February 2026. The full list of the sanctioned persons is available at the website of the State Sanctions Register of Ukraine. Read more >>
• Ukraine Imposed Sanctions against the President of Belarus: In February 2026, Ukraine imposed sanctions against the President of Belarus Alexander Lukashenko. The President of Ukraine Volodymyr Zelensky stated that the sanctions against the head of Belarus were imposed due to the country’s involvement in the Russia’s military aggression against Ukraine, in particular, for facilitating missile strikes against Ukraine. According to Ukrainian President, the sanctions against Belarus and its government might be extended in the nearest future. Read more >>
• Slovakia Stops Emergency Electricity Supplies to Ukraine: Slovak Prime Minister Robert Fico has ordered a halt to emergency electricity supplies to Ukraine, while deliveries of Russian oil through the Druzhba pipeline remain suspended. He said that Ukraine will no longer receive emergency electricity imports if it makes such requests to Slovakia. The Druzhba pipeline, which runs through Ukrainian territory and previously transported Russian oil to Slovakia and Hungary, was damaged during military operations in February 2026. The Slovak opposition criticized the prime minister's pressure on Ukraine. Read more >>
• The EU is Discussing a Plan to Speed Up Ukraine’s Membership Bid: The European Union is reportedly considering an unprecedented five-step plan that could allow Ukraine to gain partial or accelerated membership in the EU as early as 2027, even before completing all traditional accession reforms. The proposed roadmap includes preparing Ukraine for negotiations, creating a “membership-lite” or phased model often called “reverse enlargement” and overcoming political obstacles. If implemented, the approach would grant Ukraine a seat at the EU table early while it continues meeting reform benchmarks, marking a historic shift in how the bloc handles enlargement. Read more >>
• Ukraine Revokes the Mining Licenses of Several Sanctioned Companies: Ukraine revokes the mining licenses of Tiberius Plus LLC, belonging to a sanctioned Ukrainian oligarch Dmytro Firtash. According to the Prime Minister of Ukraine Yulia Svyrydenko, the company has breached the terms of 29 rare earths licenses and 10 oil and gas licenses. The cancelled licenses will be transferred to new investors through transparent auctions. Ukraine also introduced new sanctions against Dmytro Firtash in February 2026. Read more >>
• Ukraine Confiscates Shipment of Synthetic Rubber of Iranian Origin: The Assets Tracing and Management Agency of Ukraine confiscated over 43 tons of synthetic rubber from a sanctioned Iranian company. The raw materials were seized during an attempt to import them into Ukraine using forged documents. The investigation established that the products were actually manufactured at the production facilities of a sanctioned Iranian company. Read more >>
• The Russian Court Upheld the Claim of Evraz against its UK Subsidiary Evraz plc: The Moscow Arbitration Court has upheld Evraz NTMK's (Nizhny Tagil Iron and Steel Works, part of Evraz PJSC) claim against UK-registered Evraz plc for nearly 97.6 billion rubles. The court issued the ruling at a hearing on 11 February 2026. The details of the case are not disclosed, but it is known that the dispute concerns the recovery of funds and the foreclosure of property. Evraz NTMK demanded that the British company's debt be recovered through the seizure of its assets in Russia, Evraz plc explained in October. The UK company also announced its intention to seek legal advice to protect the interests of the company and its shareholders. Read more >>
• The Ministry of Industry and Trade of Russia Announced the Minimum Level of Parallel Imports: The volume of goods imported into Russia under the parallel import scheme reached a historic low of USD 1 billion in January 2026, according to State Secretary and Deputy Minister of Industry and Trade of Russia Roman Chekushov. He also noted that the trend toward reducing the number of brands on the parallel import list continues. Overall, in 2025, the volume of parallel imports into Russia amounted to USD 23.1 billion, or an average of USD 1.9 billion per month. The parallel import mechanism—the import of goods into the country without the consent of the manufacturer or copyright holder—has been in effect in Russia since 2022. Read more >>
• Rosneft Oil Refinery in Germany Warns of Risks from US Sanctions: Management at the Rosneft-controlled oil refinery in Germany has warned Berlin that ongoing U.S. sanctions on the Russian firm are hurting its operations and could jeopardize fuel supplies to Germany. The refinery relies on a temporary U.S. waiver from those sanctions, which expires at the end of April, and companies and insurers are increasingly reluctant to do business due to the risk of penalties. The situation has intensified pressure to sell the German assets or find a long-term solution, with German authorities discussing extending exemptions or alternative arrangements to safeguard energy security. Read more >>
• Russia Continues to Receive Military Goods from the EU through Turkey and China: Military goods from the European Union are still flowing to Russia through third countries, despite sanctions, states the Institute for Economic Research and the EconPol Europe analytical center. According to research, more than a third (36%) of EU military goods that continue to flow to Russia pass through Turkey. China accounts for almost a quarter (23%), followed by Hong Kong (16%) and the United Arab Emirates (10%). Although the EU has significantly tightened and expanded export bans on Russia since the beginning of 2024, which resulted in a decrease in the scale of circumvention of sanctions, the supplies have not completely stopped. Read more >>
• A Network of Companies Exporting Sanctioned Russian Oil to Western Markets Uncovered: A journalist investigation uncovered a network of about 48 shell companies that appear to be exporting more than $90 billion worth of Russian crude oil while hiding its sanctioned origins. These firms, many linked to traders with ties to Azerbaijan and operating as part of Russia’s so-called “shadow fleet,” shipped large volumes of oil despite Western sanctions imposed after the Ukraine invasion. The Russian oil was mixed with oil of non-Russian origin and sold in the Western markets through recently incorporated companies without indicating its origin. Read more >>

V. Other Notable Developments

• Australia Issues New Targeted Sanctions Against Russia: On February 24, the Australian government announced additional targeted sanctions on 180 individuals, entities, and shadow fleet vessels with links to Russia, the largest sanctions package since February 2022. The new sanctions “target Russia’s finance and banking, defense, aeronautical, oil and gas, transportation, and science and technology sectors” and are “designed to squeeze Russian revenues and further constrain its ability to continue its illegal and brutal invasion.” Read more >>
• New Zealand Announces New Sanctions Against Russia: On February 24, New Zealand announced it is implementing its 34th round of sanctions against Russia, which include lowering the price cap on Russian crude oil and sanctioning 100 shadow fleet vessels. New Zealand has also sanctioned actors from Belarus, Iran, and North Korea, alongside alternative payment providers, malicious cyber actors, and those supporting Russia’s military industrial complex. Read more >>