Russia/Ukraine Sanctions Update - Month of May 2026

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

I. US Sanctions 

• OFAC Extends General License for the Delivery and Sale of Russian Federation Crude Oil and Petroleum Products: On May 18, OFAC issued an updated general license authorizing certain transactions ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian Federation origin loaded on any vessel, including blocked vessels pursuant to certain authorities, on or before 12:01 a.m. eastern daylight time, April 17, 2026, through 12:01 a.m. eastern daylight time, June 17, 2026. The license defines such transactions to include “transactions for the safe docking and anchoring of vessels carrying such crude oil or petroleum products; the preservation of the health or safety of the crew of any such vessel; emergency repairs or environmental mitigation or protection activities relating to any such vessel; and services such as vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification, and salvage.” Read more >>

• Ukrainian President Urges US to Expand Patriot Missile Deliveries: According to CBS, in a five-page letter on May 25, Ukrainian President, Volodymyr Zelenskyy, urged the United States to expand deliveries of Patriot missile systems, warning that Russia is preparing a broader campaign of ballistic missile attacks against Ukrainian cities. Read more >>

• US Secretary of State and NATO Secretary General Discuss Ukraine: On May 22, US Secretary of State, Marco Rubio, and NATO Secretary General, Mark Rutte, discussed Ukraine. In particular, the leaders discussed “making sure Ukraine stays strong in the fight.” Secretary General Rutte also thanked the US for “the critical flow of US military support to Ukraine in terms of, for example, the interceptors for Patriot systems continues to go, paid for by European and Canadian Allies, and it is really vital for Ukraine to stay strong in the fight.” Read more >>

• US Secretary of State and Russian Foreign Minister Hold Two Calls in May: On May 5 and May 25, US Secretary of State, Marco Rubio, and Russian Foreign Minister, Sergey Lavrov, held calls to discuss the US-Russia relationship, the Russia-Ukraine War, bilateral relations, and Iran. Read more >> and Read more >>

II. EU Sanctions

• EU Sanctions for Human Rights Violations in Russia Extended Until May 2027: On May 26, the Council decided to extend the framework for restrictive measures against those responsible for serious human rights violations and abuses, for the repression of civil society and democratic opposition, and for undermining democracy and the rule of law in Russia for a year, until May 28, 2027. These measures currently apply to 72 individuals and one entity, which are subject to an asset freeze and/or travel ban. Read more >> and Read more >>

• EU Extends Scope of Iran-Related Sanctions Framework to Target Threats to Freedom of Navigation: On May 22, the Council decided to extend the scope of existing EU restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region. The amended sanctions framework will now also target individuals and entities involved in Iran's actions and policies threatening the freedom of navigation in the Middle East. Read more >> and Read more >>

• EU Sanctions 16 Individuals and Seven Entities over Deportation of Ukrainian Children to Russia: On May 11, the Council adopted restrictive measures against a further 16 individuals and seven entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The designations target those responsible for the deportation, forced transfer and forced assimilation of Ukrainian minors, as well as their unlawful adoption and removal to the Russian Federation and within temporarily occupied territories. Read more >> and Read more >>

• Commission Answer on Russian Shadow Fleet Vessels Carrying Stolen Ukrainian Grain to Israel: The European Commission was questioned on whether the landing of Russian shadow fleet vessels, the Abinsk and the Panormitis, at the Israeli port of Haifa carrying grain stolen from occupied Ukrainian territories is compatible with Israel's commitments under the EU-Israel Association Agreement, and on the EU's readiness to use sanctions against third-country entities involved in the trade of stolen Ukrainian agricultural products. The High Representative/Vice-President of the European Commission, Kaja Kallas, confirmed that the EU is aware of the reports and has conducted outreach to the Israeli authorities through the Head of the EU Delegation to Israel. On the EU-Israel Association Agreement, the Commission clarified that the agreement focuses on political dialogue, economic cooperation, and trade liberalisation, and does not explicitly include provisions requiring the EU and Israel to automatically align their trade restrictions. On the sanctions dimension, the High Representative/Vice-President stated that the EU stands ready to take targeted actions related to the trade with stolen Ukrainian agricultural products, if necessary. The Commission further noted that, with the 20th package of sanctions, the Council listed two entities incorporated in third countries owning vessels used to transport stolen Ukrainian grain, in addition to five individuals and two entities already listed for their involvement with the theft of Ukrainian grain and agricultural products. Read more >> and Read more >>

• EU General Court Annuls Sanctions Listing of Mikail Safarbekovich Gutseriev: By its judgment delivered on May 13, the General Court annulled the acts of February 2025 maintaining Mikail Safarbekovich Gutseriev, a businessman of Russian nationality, on the lists of persons subject to asset‑freeze measures and travel bans under the Belarus sanctions regime. The Court found that the Council had failed to adduce sufficient up-to-date evidence demonstrating that, at the time of adoption of the contested acts, the applicant still had business interests in Belarus or maintained a relationship with President Lukashenko capable of justifying the maintenance of his name on the sanctions lists. Read more >>

• EU Court of Justice Judgment on Freezing of Assets Held by a Trust: By its judgments delivered on May 21 in Case C-483/23, T Trust, and in Joined Cases C-428/24, FZ AR, and C-476/24, SX, the Court of Justice ruled that the freezing of assets held by a trust is compatible with EU law. The Court finds that EU law covers a variety of legal relationships between the sanctioned person or entity and the funds and economic resources at issue, ranging from ownership to situations in which the person or entity can exercise de facto power over those funds and resources. In order to ensure the effectiveness of EU law, the concepts of "belonging to" and of "control" must be interpreted in such a way that they encompass all forms of power or influence exercised over those assets, including in the absence of any legal link between them and the person concerned. This means that assets can be regarded as belonging to or being under the control of the settlor or the beneficiary of a trust, where those persons have power to use, benefit from or dispose of those resources or to have influence over them and over the decisions made by the trustee in relation to them. Read more >>and Read more >>

• Netherlands Reignites Push to Tap Frozen Russian Assets for Ukraine: On May 6, Dutch Finance Minister Eelco Heinen sought to restart EU talks on using up to €210 billion in frozen Russian assets to support Ukraine, canvassing support at a closed session of the Economic and Financial Affairs Council (Ecofin) in Brussels. The initiative comes as the €90 billion loan agreed by EU leaders in December 2025, from which no funds have yet been disbursed, is expected to cover only two-thirds of Ukraine's forecasted budget shortfall until 2027. Estonia, Latvia, Lithuania and Finland backed the Dutch calls, though Belgium continues to resist given that some €185 billion of the frozen assets are held at Brussels-based Euroclear. Read more >>

• Lithuania Warns Belarus Fertiliser Transit Would Undermine EU Sanctions: Lithuania's State Security Department warned that proposals to resume the transit of Belarusian fertilisers through the port of Klaipėda would effectively circumvent EU sanctions without reducing the security threats posed by Minsk. The warnings followed reports that US officials had approached Lithuania, Poland and Ukraine about lifting restrictions to allow Belarusian potash transit through their territories. The Lithuanian Foreign Minister confirmed discussions with the US but stressed that EU sanctions on Belarus and potash fertilisers remain in force until the end of February 2027, and that any change would require unanimous approval from all 27 Member States. Lithuania halted the transit of Belarusian potash through Klaipėda in 2022 after US sanctions were imposed on Belaruskali, later expanded by the EU. Read more >>

• EU Preparations for the 21st Sanctions Package Against Russia: The EU is preparing its 21st sanctions package against Russia, expected in late June or early July, with Russia's shadow fleet of aging, opaquely owned tankers as a key target. The package will also likely target Russian banks, financial institutions, military-industrial companies and firms selling stolen Ukrainian grain. Officials see an opportunity to advance measures previously blocked by former Hungarian Prime Minister Viktor Orbán, including sanctions on senior members of the Russian Orthodox Church, notably Patriarch Kirill. The European Commission may also revive a proposed ban on maritime services for Russian vessels, previously blocked by Malta and Greece. EU Economy Commissioner Valdis Dombrovskis emphasised to G7 and US counterparts that "now is not the time to weaken pressure on Russia." Read more >>

• Germany Exposes Scheme to Supply European Components to Russia in Circumvention of EU Sanctions: According to reporting published on May 18, German law enforcement officers have concluded a four-year investigation exposing a sanctions circumvention network centred on Global Trade, a trading company based in Lübeck. The company exported directly to Russia before 2022 but, after EU sanctions were imposed, altered its business model to disguise Russian end users. At the centre of the scheme was the US-sanctioned Russian company Kolovrat (also operating under the name Siderius), which German investigators describe as the operational core of a procurement network supplying Russian industry, including entities linked to the defence and nuclear sectors. Nikita S., a 39-year-old who became managing director of Global Trade in March 2022, is described as the "binding link" between the German company and its Russian controllers, simultaneously working for Kolovrat in Moscow. Kolovrat employees reportedly logged into Global Trade email accounts and posed as German staff to contact suppliers and place orders across Europe. The goods included microcontrollers, electronic components, sensors, converters, ball bearings, oscilloscopes and other dual-use items, routed through Turkey. German front companies including ER Industriebedarf GmbH and Amtech Solutions further obscured the operation. Prosecutors believe the network moved roughly 16,000 shipments worth more than €30 million. Several suspects are now in custody, including Nikita S., and face potential prison sentences of up to ten years under Germany's Foreign Trade Act for systematic violations of export controls and large-scale sanctions evasion. Read more >>

III. UK Sanctions

• FCDO designates individuals and entities linked to A7 crypto network: On May 26, the UK added 18 entities linked to the A7 crypto network to its sanctions list under the Russia (Sanctions) (EU Exit) Regulations 2019 (the "UK Russia Regulations"). In connection with the designations, OFSI has also amended the personal remittance licence (GL INT/2024/4761108), allows a person to make use of 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 an individual. Read more >> and Read more >>

• Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 come into force: On May 20, the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 came into force (the “2026 Regulations”), amending the Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations”). The 2026 Regulations: (a) expand existing export bans to include new categories of goods; (b) introduce new bans on the import/acquisition/supply of uranium from Russia, the import of oil processed in third countries from Russian oil, and related services; (c) introduce a new ban on the maritime transportation of Russian LNG and related services; (d) introduce a new ban on the provision of construction services to persons connected with Russia; (e) introduce new bans on the provision and procurement of services for specified ships, on chartering or operating specified ships, and on the registration of specified ships; (f) introduce a new ban on the acquisition of “detained transport assets” (ships or aircraft subject to certain directions). Read more >>

• UK Department of Business and Trade and OTSI issue two new licences: On May 19, the Department of Business and Trade published two general trade licences in conjunction with the introduction of the bans on the import of oil processed in third countries from Russian oil and the maritime transportation of Russian LNG, under the 2026 Regulations.  The “General Trade Licence for sanctioned processed oil products” authorise transactions prohibited by the ban on processed oil insofar as they relate to diesel and jet fuel. The “General trade licence: maritime transportation of liquefied natural gas” authorises the transportation of Russian LNG from the Sakhalin-2 and Yamal LNG terminals to or between third countries, and certain related services. Read more >>, Read more >> and Read more >>

• OFSI imposes £165,000 penalty on Deutsche Bank for sanctions breaches: On May 19, OFSI published an enforcement notice stating that it had imposed a penalty on Deutsche Bank AG London Branch ("DBLB") for breaches of Regulation 12 of the UK Russia Regulations, which prohibits (inter alia) making funds available to a person owned or controlled by a designated person. Between June and July 2022, DBLB processed two payments totalling £635,618.75 to Okko LLC, an entity wholly owned by a designated person, JSC New Opportunities. DBLB had initially requested a ministerial review of OFSI’s decision to impose a penalty. However, following the implementation of OFSI’s new enforcement framework earlier this year, OFSI and DBLB agreed to enter formal settlement discussions in March 2026 and settlement was agreed in April 2026. Read more >>

• FCDO announces new sanctions to curb Russian drones: On May 5, the FCDO announced in a press release that it would introduce new sanctions to curb the production of Russian drones. These sanctions are also intended to affect the networks exploiting migrants, with 35 people and entities added to the sanctions list under the Russia (Sanctions) (EU Exit) Regulations 2019 and the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025. Read more >>

• OWH v RTI & Rusal [2026] EWHC 1015 (Comm): On May 1, the High Court dismissed an application to set aside an order permitting enforcement of an arbitration award, holding that the public policy interest attaching to ancillary sanctions provisions (here, the s.44 compliance defence) was insufficient to refuse enforcement. The court noted that it has discretion to refuse to enforce an arbitration award on public policy grounds. It accepted that the sanctions regime engaged vital public interests and recognised the importance of the immunity provisions in section 44 in mitigating the harsh consequences on organisations caught between contractual compliance and sanctions compliance. However, it drew a distinction between primary sanctioning provisions (i.e. sanctions prohibitions) and ancillary ones, such as s.44. In its view, ancillary provisions do not necessarily attract the same public policy interest as primary sanctioning provisions. This is subsequent to the 6 May 2025 decision, when the English Commercial Court rejected Rusal's application to set aside an order enforcing an LCIA arbitration award of VTB's German subsidiary OWH. Rusal’s Jersey subsidiary (RTI) entered into a currency swap contract with OWH in 2019, but following the imposition of EU, UK and US sanctions on VTB in 2022, RTI refused to pay margin calls under the contract. Subsequently, OWH terminated the contract and obtained an LCIA award against RTI for breach of contract, seeking enforcement in England and Jersey and obtaining enforcement from the English High Court in 2025. Read more >>

IV. Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In May 2026, the President of Ukraine adopted 5 Orders extending the sanctions to 53 legal entities, 179 individuals and 29 vessels. The full list of the sanctioned persons is available at the website of the State Sanctions Register of Ukraine. Read more >>

• Supreme Court of Ukraine Clarifies in a Landmark Ruling that Transactions Aimed at Circumvention of Sanctions are Void: In a landmark ruling published in May 2026, the Supreme Court of Ukraine came to a conclusion that transactions carried out in violation of Ukrainian sanctions or designed to bypass asset-freezing measures are void under Ukrainian law. According to the Court, any assets or benefits obtained through such deals may be confiscated in favour of the state. The Court underlined that courts must treat sanctions-evasion schemes as contrary to public policy and national security interests. Read more >>

• The Central Bank of Russia Will Challenge the Use of its Assets by Ukraine in the EU Court: Central Bank of Russia has challenged an EU mechanism that uses frozen Russian sovereign assets as backing for a EUR 90 billion loan package to Ukraine, calling it illegal and contrary to international law. The regulator argues that the EU’s actions violate sovereign immunity protections, property rights, and legal procedures, including the requirement for unanimous approval by member states. The dispute concerns both the EU’s permanent freeze of roughly €210 billion in Russian reserves and the February 2026 regulation establishing the Ukraine loan mechanism. Read more >>

• The Central Bank of Russia Demands Recovery of RUB 18.7 trillion from Euroclear: The Central Bank of Russia has filed a petition with the Moscow Arbitration Court for the immediate enforcement of its RUB 18.7 trillion judgment against Euroclear Bank, following the court's mid-May 2026 ruling that fully upheld the Central Bank's damages claim. The claim relates to the freezing of Russia's sovereign assets held at Euroclear after EU sanctions were imposed in February 2022. Euroclear has announced it will appeal the original court decision, while confirming that Russia's assets remain frozen despite the ruling. Read more >>

• Kyrgyzstan has Launched a Large-scale Purge of Businesses that Help Russia: Kyrgyzstan has launched its first major crackdown on companies suspected of helping Russia evade international sanctions, suspending the operations of 50 firms linked to high-risk trade and re-export schemes. The measures were introduced through a new interagency mechanism designed to identify businesses involved in sanctions circumvention and protect the country from potential secondary Western sanctions. The move comes amid growing pressure from the European Union, which recently imposed export restrictions on certain dual-use goods to Kyrgyzstan, accusing the country of serving as a transit route for sanctioned products bound for Russia. Read more >>

V. Other Notable Developments

• Switzerland Widens Sanctions Against Russia in line with EU Measures: According to Reuters, on May 22, Switzerland announced it was expanding its sanctions lists against Russia and Belarus, adopting parts of the ‌European Union's latest package of measures over Moscow's war in Ukraine. As a result, 115 individuals and entities will be subject to asset freezes and a ban on making funds available, while sanctioned individuals will also be barred from entering or ‌transiting ⁠Switzerland. Read more >>

• Canada Announces Additional Sanctions in Response to Violations Against Ukrainian Children: On May 11, Canada announced the imposition of additional sanctions “in response to the Russian government’s violations of Ukrainian children’s rights.” Specifically, Canada sanctioned over 80 individuals and entities following a determination of “their involvement in violations of the rights of Ukrainian children in Russia and in the temporarily occupied territories of Ukraine.” Read more >>

• Japan To Send Officials to Russia to Protect Japanese Companies’ Assets: According to Reuters, on May 11, Japan announced that it plans to send several officials to Russia “to facilitate communication and help protect assets owned by Japanese companies operating there,” according to Japan’s Minister of Economy, Trade ‌and Industry, Ryosei Akazawa. Read more >>

• New Zealand Announces New Sanctions on Russia: On May 7, New Zealand’s Foreign Minister, Winston Peters, announced a new round of sanctions targeting malicious cyber actors and others supporting Russia’s illegal war of aggression against Ukraine. Specifically, the package designated 20 individuals and entities, including “actors supporting the Kremlin’s hybrid warfare tactics, by enabling Russian cybercrime activity that supports the war, and the dissemination of anti-Ukraine