Russia/Ukraine Sanctions Update - Month of May 2025

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

I. U.S. Sanctions 

• President Trump Threatens Sanctions on Russia Following Drone Attack on Ukraine: On May 28, Bloomberg reported that President Trump said he was “‘absolutely’ considering new sanctions against Russia as Ukraine said Moscow launched its largest drone barrage of the war during a third night of strikes.” Bloomberg also reported that the comments “came as [President Trump grew] visibly frustrated with Russian President Vladimir Putin and the state of talks meant to deliver a ceasefire in Ukraine.” The Washington Post reported that Russia and Ukraine will meet in Istanbul for a second round of peace talks if the Kremlin produces its promised memorandum of terms for an agreement. Read more>> and Read more>>

• Legislation to Impose Additional Sanctions on Russia Is Introduced to U.S. House and Senate: On April 1, 2025, Representative Brian Fitzpatrick (R-PA) and Senators Richard Blumenthal (D-CT) and Lindsey Graham (R-SC) introduced S. 1241 and H.R. 2548, the Sanctioning Russia Act of 2025. If passed, the legislation would require the President, not later than 15 days following its enactment, and every 90 days thereafter, to determine if the Government of Russia, any proxy of the Government of the Russian Federation, any individual or entity controlled by or acting at the direction of the Government of the Russian Federation, those affiliated or supporting the Government of Russia, or financial institutions affiliated with the Government of the Russian Federation has refused to negotiate a peace with Ukraine, has violated any negotiated peace agreement, has initiated another military invasion of Ukraine, or has overthrown, dismantled, or sought to subvert the Government of Ukraine (a "covered determination"). Upon making a covered determination, the legislation would then require the President to take various actions, including imposing property blocking sanctions on certain persons affiliated with or supporting the government of the Russian Federation, financial institutions affiliated with the government of the Russian Federation, and entities owned by or affiliated with the Russian Federation. The legislation has reached 81 cosponsors in the Senate. Read more>> and Read more>>

• U.S. Secretary of State Speaks with Russia Foreign Minister: On May 17 and May 28, Secretary of State, Marco Rubio, held calls with Russian Foreign Minister, Sergey Lavrov. The calls emphasized U.S. commitment to “achieving a lasting end to the Russia-Ukraine war.” The calls also emphasized President Trump’s calls “for an immediate ceasefire and an end to the violence” and “constructive, good faith dialogue with Ukraine as the only path to ending this war.” Read more>> and Read more>>

• U.S. Secretary of State Meets with Foreign Ministers for Türkiye and Ukraine: On May 16, Secretary of State, Marco Rubio, met with Ukrainian Head of the Presidential Office, Andriy Yermak, Ukrainian Foreign Minister, Andrii Sybiha, and Turkish Foreign Minister, Hakan Fidan. The parties “discussed the importance of seeking a peaceful end to the Russia-Ukraine war,” and Secretary Rubio reiterated “the U.S. position that the killing needs to stop.” Read more>>

• U.S. Announces U.S.-Ukraine Reconstruction Investment Fund: On April 30, the U.S. and Ukraine signed an agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which commits the parties to work collaboratively and invest together to accelerate Ukraine’s economic recovery. The U.S. Treasury Department and the U.S. International Development Finance Corporation agreed to work with the Government of Ukraine “to finalize program governance and advance this important partnership.” Read more>>

II. EU Sanctions

• EU Adopts 17^th Sanctions Package: On May 20, the EU adopted new package of sanctions targeting Russia, with a primary focus on additional sanctions designations. The EU imposed asset-freeze measures against 66 individuals and 67 entities, both inside and outside Russia. In addition, the EU extended its sectoral sanctions, concentrating largely on Russia’s military-industrial complex and the so-called "shadow fleet." Read more>>, Read more>>, Read more >>, Read more >>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>> and Read more >>

• EU Introduces a New Listing Criterion Under Sanctions Against Russia: On May 13, the EU introduced a new listing criterion to include natural or legal persons, entities or bodies that have participated in or enabled transfers of ownership, control or economic benefit of the business interests of leading businesspersons operating in Russia. Additionally, the EU established a presumption that sanctioned businesspersons remain subject to restrictive measures, even if they claim to have transferred their assets after February 2022. Read more>> and Read more>>

• EU Amends Grounds for Listing for Several Individuals: On May 20, the EU amended the grounds for listing of one individual subject to asset freeze and travel ban measures under sanctions framework in view of Russia’s destabilizing activities. On May 26, the EU amended the grounds for listing of two individuals subject to asset freeze and travel ban measures under sanctions framework in view of the situation in Russia. Read more>>, Read more>>, Read more>> and Read more>>

• Council Addresses Demands for Stronger Measures Against Shadow Fleet in 16th Sanctions Package: The Council has responded to concerns regarding the environmental risks posed by the Russian shadow fleet by highlighting measures included in the 16th sanctions package against Russia. According to the Council, this package specifically targets the Russian shadow fleet by adding additional vessels to the list of those prohibited from entering EU ports and by imposing further restrictions on services related to their maritime transport. The Council recognized the substantial environmental and safety threats these vessels present to both European and third-country coastal waters, as underscored by the International Maritime Organisation. The Council also recalled that it introduced a new listing criterion as part of the 16th package targeting those who support the operations of tankers transporting Russian oil while conducting irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33). Read more>> and Read more>>

• EU Measures on Frozen Russian Assets and Support for Ukraine: The MEPs questioned what measures the European Commission plans to take to use frozen Russian assets for Ukraine’s benefit, and, if not, what alternative steps would be as effective in strengthening Ukraine’s negotiating position. The High Representative for Foreign Affairs and Security Policy and Vice-President of the European Commission Kaja Kallas responded that the EU has already begun using the extraordinary profits generated from immobilized Russian assets to support Ukraine, with significant financial contributions made in 2024 and 2025, and that a new financial assistance package leveraging these revenues has been adopted. She emphasized that all legally and financially sound options remain under consideration, and any further decisions on the use of Russian assets will be made by the Council. Read more>> and Read more>>

• German Tech Firm Circumvented EU Sanctions to Export Sensitive Equipment to Russia: A German technology company, Kontron, exported over €3.5 million in sensitive telecommunications equipment to its Russian subsidiary after the EU imposed strict sanctions on such exports in 2023, using its Slovenian arm to facilitate the shipments. Despite Kontron’s claim that these were pre-approved orders under Slovenian export licenses, the case has raised concerns about loopholes in the EU sanctions regime. The company maintains a significant presence in Russia and Kazakhstan, and its financial dealings with its Russian subsidiary have also drawn scrutiny, highlighting ongoing challenges in preventing sanctioned technology from reaching Russia. Read more>>

• Latvian Firm Facilitated Sanctioned Western Tech Exports to Russian Defense Sector: In 2024, Latvian company KLC Group SIA exported $1.3 million worth of Western-made industrial automation equipment to Russia, circumventing EU sanctions by routing shipments through Kazakhstan and Kyrgyzstan with the help of intermediary firms. The equipment, sourced from major multinational manufacturers, ultimately reached Russian companies involved in defense contracts. Read more>>

• China Implicated in 80% of Sanctions Circumvention Against Russia, Says German Report: An internal report from the German Foreign Ministry claims that China, including Hong Kong, is responsible for 80% of the routes used to circumvent sanctions against Russia. The report highlights that while EU sanctions have significantly impacted Russia’s economy and restricted military exports through several countries, issues remain with incomplete export data from Kazakhstan, the UAE, and Turkey. Additionally, the report notes EU companies' involvement in circumvention schemes and calls for stronger action against ports in Turkey, India, and Malaysia that support Russia’s "shadow fleet." Read more>>

• Lithuania Urges Stronger EU Sanctions Targeting Russia’s Key Sectors: Lithuanian Foreign Minister Kęstutis Budrys called for the European Union's 18th sanctions package to focus on Russia's most vulnerable sectors, including energy, liquefied natural gas, oil, nuclear fuel, and financial institutions, to effectively counteract President Putin's strategies to evade sanctions. This statement follows the EU's recent approval of its 17th sanctions package, with further measures being considered if Russia does not agree to a ceasefire in Ukraine. Read more>>

III. UK Sanctions

• UK Government amends seven entries on UK sanctions list under the Russia regime: On May 28, the UK Government amended seven entries for one individual and six entities on the UK sanctions list under the Russia regime. Read more>>

• UK Government amends one entry on UK sanctions list under the Russia regime: On May 23, the UK Government amended the entry for Michel Litvak on the UK sanctions list under the Russia regime. Read more>>

• UK extends General Licence authorising charity Interim Managers and trustees to make certain payments: On May 21, the UK Government renewed General Licence INT/2022/1834876, which inter alia authorises interim managers and trustees to make certain payments associated with the basic needs and wind up of a charity, subject to certain terms and conditions.  The expiry date of the General Licence has been extended from 30 May 2025 to 30 May 2028. Read more>> and Read more>>

• UK adds 100 sanctions targets to UK sanctions list under the Russia regime: On May 20, the UK Government added 100 entries to the UK sanctions list under the Russia regime. According to the UK Government, the latest measures target Russian revenue generating sectors, including energy, communications and financial services, the Russian military industrial complex (RMIC) and its third country suppliers, and malign actors involved in democratic interference and Russia’s information war on Ukraine. Read more>>, Read more>> and Read more>>

• UK issues General Licence relating to the wind down of position involving St Petersburg Currency Exchange and JSC Petersburg Settlement Center: On May 20, the UK Government issued General Licence INT/2025/6275812, which authorises 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.  The General Licence expires on June 19, 2025. Read more>> and Read more>>

• UK issues General Licence relating to processing of payments to the Deposit Insurance Agency: On May 20, the UK Government issued General Licence INT/2025/6279615, which authorises the processing of payments due to be paid to the State Corporation Deposit Insurance Agency, subject to certain terms and conditions.  The General Licence is of indefinite duration. Read more>> and Read more>>

• UK Parliament approves Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025: On May 14, the UK Parliament approved the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which were laid before Parliament on 23 and 24 April 2025 and which impose further trade sanctions on Russia, including certain dealings in further categories of chemicals, plastics, metals, machinery and electronics, technological information and synthetic diamonds. Read more>>, Read more>> and Read more>>

• OFSI extends General Licence relating to Amsterdam Trade Bank to May 2030: On May 12, OFSI amended General Licence INT/2022/1678476, which authorises Amsterdam Trade Bank N.V (“ATB”) to make or receive certain payments in connection with inter alia the winding down of transactions with ATB and ATB’s insolvency proceedings, subject to certain terms and conditions.The amendments permit the bankruptcy trustees of Amsterdam Trade Bank N.V to fulfil their statutory functions as bankruptcy trustees and extends the expiry date of the general licence to 12 May 2030. Read more>> and Read more>>

• UK adds more than 110 entries (including 100 ships) to the UK sanctions list under the Russia regime, targeting Russia’s “shadow fleet”: On May 9, the UK Government proscribed 101 ships and added five individuals and four entities to the UK sanctions list under the Russia regime.  The new measures target Sogalsie Insurance Company Limited, Romarine AS, BX Energy and Nord Axis Ltd, among others.  In a press release, the UK Government described the new measures as the “largest ever sanctions package” targeting Russia’s shadow fleet in an effort to increase pressure on Russia and protect UK and European critical national infrastructure. Read more>>, Read more>> and Read more>>

• OFSI issues first information enforcement penalty on Svarog Shipping Company for failure to respond to RFI under Russia regime: On May 9, the UK Office of Financial Sanctions Implementation (OFSI) announced a £5,000 monetary penalty against Svarog Shipping Company Limited for a failure to comply with its information obligations under the Russia regime. In its penalty notice, OFSI identified various aggravating factors, including that: Svarog neglected or failed to take reasonable care to comply with its information obligations, notwithstanding its receipt of several communications from OFSI, and Svarog ought to have been more vigilant to OFSI’s request given it operates in a sector with elevated exposure to sanctions risks. Read more>>

• OFSI publishes blog on compliance lessons for industry in relation to information offences: On May 8, OFSI published a blog post titled “Svarog Penalty: A Lesson in Information Offences.”  The blog post identifies key compliance lessons for industry in light of the publication of its first information offence enforcement action announced against Svarog on the same day. In particular, OFSI states that companies should: recognise the seriousness of failing to respond promptly to RFIs; engage proactively and candidly with OFSI when it comes to RFIs; have effective communication and monitoring systems in place; and consider other compliance and reporting obligations. Read more>>

• UK Government amends one entry on UK sanctions list under the Russia regime: On May 1, the UK Government amended the entry for Albert Kashafovich Shigabutdinov on the UK sanctions list under the Russia regime. Read more>>

• UK Government issues factsheet summarising support to Ukraine: On April 30, the UK Government issued a factsheet summarising UK Support to Ukraine. Among other things, the factsheet summarises support in the areas of Diplomacy, Military, Energy and Sanctions. The factsheet highlights that more than 2,300 individuals and entities have been sanctioned, including more than 2,100 since full-scale invasion. Read more>>

• UK Government issues statement at the UN Security Council: On April 29, Lord Collins of Highbury, Minister for Africa and the UN issued a statement at the UN Security Council meeting on Ukraine. The statement urges Russia to commit to a ceasefire, and reiterates the United Kingdom’s commitment to stand by Ukraine. Read more>>

• OFSI issues General Licence relating to the transfer of assets and liabilities between Credit Suisse and UBS: On April 28, OFSI issued General Licence INT/2025/6135848 which authorises a person to carry out activities that are required to enable and that are ordinarily incident and necessary to the transfer of assets and liabilities as part of the integration of Credit Suisse Group AG into UBS Group AG, subject to certain terms and conditions.The licence takes effect from April 28, 2025, and expires on April 26, 2030.  Read more>> and Read more>>

• OFSI issues new legal services General Licence: On April 28, OFSI issued General Licence INT/2025/6160920, which authorises certain payments relating to the provision of legal services to or on behalf of designated persons, subject to certain terms and conditions.  The new general licence replaces the previous general licences relating to legal services, which have now expired. Read more>> and Read more>>

• OFSI amends General Licence relating to membership fees for International Organisations: On April 28, OFSI amended General Licence INT/2025/5855272, which authorises International Organisations to receive certain payments transferred from an account held with Gazprombank.In particular, the general licence was added to include the International Maritime Organization.  The licence expires on February 20, 2030. Read more>> and Read more>>

IV. Russia/Ukraine Sanctions

• Ukraine imposes sanctions on 10 individuals and 9 entities: On May 25, under Decrees No. 345/2025 and No. 344/2025, Ukraine imposed sanctions on 10 individuals and 9 entities, the sanctions include, among other things, asset blocking, restrictions on trade operations and the prevention of capital withdrawal. Read more>> and Read more>>

• Ukraine to pitch tough Russia sanctions plan: On May 21, it was reported that Ukraine will ask the EU to consider tougher sanctions against Russia which include seizing Russian assets and bringing in sanctions for some buyers of Russian oil. Read more>>

• Zelenskyy discusses additional sanctions pressure on Russia with Prime Minister of Australia: On May 18, Zelenskyy held a meeting with the Australian Prime Minister to discuss specific sanctions which could compel Russia to stop placing conditions on an unconditional ceasefire, and the coordination of steps with partners. Read more>>

• Ukraine imposes sanctions on 58 individuals and 74 entities: On May 9, under Decree No. 301/2025, Ukraine imposed sanctions on 58 individuals and 74 entities, the entities mainly relate to the defence-industrial sector and the individuals are based in Russia, Iran, Uzbekistan and Hong Kong. The sanctions have been implemented against actors supporting Moscow’s invasion of Ukraine. Read more>> and Read more>>

• Ukraine imposes sanctions on 76 individuals and 81 companies: On May 1, under Decrees No. 267/2025, No. 268/2025, and No. 269/2025, Ukraine imposed sanctions on 76 individuals and 81 entities, including the former Ukrainian presidential advisor Oleksy Arestovych. The sanctions packages target figures accused of auding Russia’s war efforts or spreading propaganda. Read more>>, Read more>> and Read more>>

V. Other Notable Developments

• Alleged Sanctions Violations Lead to Toronto Company Owner Arrest: On May 27, the owner of a Toronto company was arrested by the Royal Canadian Mounted Police following allegations that his company supplied the Russian military with restricted goods and technologies in violation of Canadian sanctions. Read more>>