Russia/Ukraine Sanctions Update - Month of September 2025

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

I. U.S. Sanctions 

• U.S. Secretary of State Meets with Russian Foreign Minister: On September 24, U.S. Secretary of State, Marco Rubio, met with Russian Foreign Minister, Sergey Lavrov. During the meeting, Secretary Rubio “reiterated President Trump’s call for the killing to stop and the need for Moscow to take meaningful steps toward a durable resolution of the Russia-Ukraine war.” Read more>>
• U.S. Secretary of State Attends United Nations Security Council Ministerial Meeting on Ukraine: On September 23, U.S. Secretary of State, Marco Rubio, attended a United Nations Security Council Ministerial Meeting on Ukraine, where he emphasized the Trump Administration’s high prioritization of “the restoration of peace anywhere and everywhere in the world where the opportunity presented itself.” Secretary Rubio also noted that the war in Ukraine has “proved to be an extraordinary challenge” but the war will end “at a negotiating table.” Read more>>
• President Trump Threatens Powerful Tariffs on Russia: According to ABC News, on September 23, during the United Nations General Assembly, President Trump stated that the U.S. is prepared to enforce a “very strong round of powerful tariffs” on Russia if there is no peace deal. Also during the General Assembly, Ukrainian President, Volodymyr Zelenskyy, urged the necessity of “[s]trong sanctions, strong political pressure, [and] Russia's accountability for the war." Read more>> and Read more>>
• U.S. Urges G7 Leaders to Impose Sanctions Relating to Russian Oil: According to Bloomberg, on September 12, President Trump announced that his patience with Putin was “running out fast” and threatened new economic sanctions. President Trump also announced he will urge G7 allies to impose tariffs as high as 100% on China and India for their purchases of Russian oil to convince President Vladimir Putin to end Russia’s war in Ukraine. Finally, President Trump said that he’d be hitting hard “with sanctions to banks and having to do with oil and tariffs also” in an interview with Fox News. Read more>>
• U.S. Government Accountability Office Issues Report on Sanctions and Export Controls: On September 8, the U.S. Government Accountability Office published a report on asset freezes and export controls on Russia in response to the war in Ukraine. The report found that despite such measures by the U.S. and its allies, “Russia has taken actions to mitigate the impact of these restrictions” and recommended “that U.S. agencies set targets to help measure the effectiveness of their sanctions and export controls on Russia.” This includes a recommendation that the Secretaries of Commerce and the Treasury “should define objectives that are linked to measurable outcomes with targets for their efforts related to” sanctions and export controls on Russia. Read more>>
• U.S. Hosts U.S.-Ukraine Reconstruction Investment Fund Meeting: On September 5, U.S. Secretary of the Treasury, Scott Bessent, hosted the inaugural board meeting of the U.S.-Ukraine Reconstruction Investment Fund, established to allow the U.S. to invest alongside Ukraine to facilitate Ukraine’s recovery. During the meeting, the board approved key items to operationalize the fund, including nominating the Chair of the Board and adopting committee charters. While discussing the fund, Secretary Bessent stated it “will help unlock an abundant and secure economic future for Ukraine—one built upon sound macroeconomic management and robust foreign investment.” Read more>>

II. EU Sanctions

• EU Imposes Additional Sanctions Against Serious Human Rights Violations and Abuses: On September 5, the EU added two individuals responsible for abuses in detention centres in Crimea to the list of persons subject to asset freeze and travel ban measures under the EU sanctions regime concerning serious human rights violations and abuses. Read more>> and Read more>>
• EU Extends Individual Sanctions Over Territorial Integrity of Ukraine for a Further 6 Months: On September 12, the EU renewed the EU sanction measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine until March 15, 2026. In the context of the sanctions' review, the Council also decided not to renew the listings of one individual, and to remove one deceased person from the list. Read more>>and Read more>>
• EU Commission Proposes 19th Sanctions Package Against Russia: On September 19, the European Commission proposed the EU’s 19th sanctions package against Russia. The measures would introduce additional asset freezes and transaction bans; expand export controls on chemicals, metal components, salts and ores, AI, geospatial data, and other critical resources; extend the list of entities – including some in China and India – subject to reinforced dual use and advanced technology export controls; phase out Russian LNG by 1 January 2027; impose restrictions on cryptocurrency transactions; and ban investment in Russian special economic zones. The package now awaits adoption by the Member States. Read more>> and  Read more>>
• EU Commission Updates its Guidance on Sanctions Against Russia and Belarus: On August 29, the European Commission updated its guidance on the oil price cap in light of the introduction of a new price per barrel of crude oil, which entered into force on September 3. Furthermore, on September 8, the European Commission updated its guidance regarding the concept of "acting on behalf of or at the direction of an entity" as referred to in Article 5aa of Regulation 833/2014, as well as on exemptions for transactions involving listed ports and locks in Russia. Read more>>, Read more>> and Read more>>
• EU Commission Addresses Concerns Over Lack of Inspections of the Russian Shadow Fleet in the Netherlands: On September 24, the European Commission responded to questions regarding the absence of inspections by Dutch authorities of ships belonging to the Russian shadow fleet. The European Commission emphasized that Member States are responsible for enforcement actions concerning maritime issues, in accordance with the United Nations Convention on the Law of the Sea, which restricts the boarding of foreign ships outside territorial waters. To strengthen enforcement, the European Commission confirmed that it is collaborating with Member States to ensure that insurance information is shared across the EU through technical upgrades to the SafeSeaNet system, aiming to provide real-time access and prevent weak links in maritime surveillance. Read more>> and Read more>>
• EU Commission Responds to Calls for Listing of Mr. S. Matviyenko: On September 25, the European Commission replied to requests to add Mr. Sergey Matviyenko to the EU sanctions list and prevent him from operating in EU territory. It noted that listings are decided by the Council, require unanimous Member State approval, and must meet legal criteria supported by evidence. The European Commission added that its High Representative/Vice-President will continue working with Member States to further strengthen sanctions, including new individual designations. Read more>> and Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Positive Group PAO: By its judgment delivered on September 10, the General Court dismissed the actions brought by Positive Group PAO, an entity listed based on the so-called “IT criterion” serving to freeze the funds and economic resources of entities operating in the Russian IT sector with (i) a license administered by the Federal Security Service of the Russian Federation (FSB) Centre for Licensing, Certification, and Protection of State Secrets or (ii) a ‘weapons and military equipment’ licence administered by the Russian Ministry of Industry and Trade. The General Court ruled that the IT criterion is consistent with the principles of foreseeability and legal certainty in so far as it clearly and objectively defines a limited category of persons: entities operating in the Russian IT sector which hold a licence from the FSB or a ‘weapons and military equipment’ license. Second, the General Court found that the IT criterion is not manifestly disproportionate in the light of the objectives pursued by the restrictive measures. Third, the General Court held that the criterion at issue is not a disproportionate interference in the freedom to conduct a business. Read more>>
• EU's Court of Justice Rules on the Asset Freeze Exemptions: By its judgment delivered on September 11, the Court of Justice, seized with a request for a preliminary ruling from the Belgian Council of State, ruled on the scope of the exemption regime set out in Article 4(1)(a), (b), and (d) of Regulation (EU) 269/2014. This article provides that frozen funds may be released and made available if necessary for the payment of taxes, professional fees or reimbursement of expenses incurred in connection with the provision of legal services, or extraordinary expenses. The Court of Justice recognized that the payment of a roll fee and a flat-rate contribution upon lodging an action before a court cannot be regarded as an expense incurred to permit a person, entity, or body whose assets are frozen to obtain legal representation. However, the Court of Justice held that a roll fee and a flat-rate contribution, which must be paid by such a person, entity, or body in order to bring an action for annulment against a decision implementing Regulation No 269/2014 by rejecting their application for the release of their funds, are ‘taxes’ within the meaning of Article 4(1)(a) of that regulation, the payment of which is necessary to satisfy their ‘basic needs’ within the meaning of that provision. Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Several Individuals: In its judgments delivered in September, the General Court dismissed the actions brought by Alisher Usmanov, Viktor Fedorovych Yanukovych, Oleksandr Viktorovych Yanukovych, and Roman Arkadyevich Abramovich challenging their listings. Read more>>, Read more>>, Read more>> and Read more>>
• EU's General Court Annuls Previous Sanctions Listing of Several Individuals: By its judgments delivered in September, the General Court annulled the September 2024 listings of former Ukrainian Member of Parliament Vyacheslav Aleksandrovich Boguslayev, as well as of Dmitry Alexandrovich Pumpyanskiy, and Tigran Khudaverdyan. Read more>>, Read more>> and Read more>>
• EU Advocate General’s Opinion on the Interpretation of “No Claims” Clauses: On September 4, Advocate General of the Court of Justice, Mr. Rimvydas Norkus, delivered an opinion following a request for a preliminary ruling from a Latvian court, concluding that, in civil adversarial proceedings, national courts should, on their own initiative, assess whether sanctioned individuals are involved and whether “no claims” clauses apply not only when the parties raise the issue but also when the court is aware, or the circumstances indicate, that they may be applicable. To carry out this assessment, national courts must use their powers and consult specialized national authorities to obtain the necessary information. Read more>>
• EU Advocate General’s Opinion on Listed Person’s Rights to Attend Meetings and Voting Rights: On September 25, Advocate General of the Court of Justice, Mr. Jean Richard de la Tour, delivered opinion further to a request for preliminary ruling referred by a Dutch court, concluding that asset freeze measures under EU sanctions law require the freezing of all rights associated with shares held by sanctioned shareholders, including voting rights and the right to participate in meetings. The Advocate General emphasized that freezing funds encompasses preventing any transaction that has an impact on the funds, and that the objectives of the sanctions regime against Russia justify a broad interpretation. Read more>>
• Latvia Adopts National Sanctions Framework in Response to Russian Aggression: On September 12, the Cabinet of Ministers of Latvia has adopted new regulations enabling the imposition of national sanctions on individuals and entities linked to Russia’s military aggression against Ukraine, aiming to strengthen Latvia’s national security. The framework outlines criteria for targeting those who support or benefit from actions undermining Ukraine’s sovereignty. This move complements existing EU sanctions and is intended to enhance Latvia’s ability to respond to ongoing threats posed by the Russia’s actions in Ukraine. Read more>>
• Lithuania Stands Firm on Sanctions Against Russia and Belarus Despite International Pressure: Lithuanian Prime Minister Ingrida Šimonytė reaffirmed that Lithuania will not ease sanctions or lift the ban on Belarusian fertilizer transit, even if pressured by the US, emphasizing the need for tougher measures against Russia and Belarus. This stance comes as the US recently lifted sanctions on Belarusian airline Belavia and amid ongoing diplomatic efforts by Belarus to remove restrictions on potash fertilizer exports, which remain blocked by the EU. Read more>>
• Spanish Court Exposes Smuggling Network Using Turkey to Evade EU Sanctions: A Spanish court has upheld the pretrial detention of a Georgian national accused of orchestrating the illegal export of dual-use industrial equipment from Spain to Russia, using Turkey as a logistical intermediary to circumvent EU sanctions. Court documents detail how the suspect, identified as Alexander, utilized Turkish shell companies—including one owned by a politically connected businessman—to disguise the equipment’s true destination: a Russian firm linked to defense sectors. Read more>>
• Lithuanian Authorities Uncover Sanctions Evasion Scheme Involving Industrial Equipment Shipments to Russia: Customs Criminal Service officers in Lithuania have uncovered a scheme in which a Kaunas-based company allegedly used fictitious recipients in Portugal to attempt to ship industrial water-treatment equipment to Russia, circumventing international sanctions. Authorities detained 11 individuals, seized several tonnes of equipment, and intercepted shipments in Lithuania, Bulgaria, and Portugal, with evidence suggesting the goods were destined for Russian industrial sites, including the oil industry. The case is part of a broader regional crackdown on sanctions violations, with recent related prosecutions in Latvia and Poland. Read more>>
• Polish Police Dismantle Luxury Car Fraud System: Polish authorities have arrested 20 members of an organized crime group accused of illegally exporting nearly 600 luxury vehicles to Russia and Belarus while orchestrating a VAT fraud scheme worth over €9.4 million. The syndicate allegedly used shell companies across several countries to create artificial transaction chains and issue fake invoices, enabling repeated VAT refund claims and evasion of EU sanctions. Investigators seized luxury goods, with suspects facing charges including money laundering and circumventing EU sanctions on Russia and Belarus. Read more>>

III. UK Sanctions

• UK Government publishes new guidance summarising exceptions to Russia trade and transport sanctions and amendments to the Russia sanctions regulations: On September 25, the UK Government published new guidance that summarises (i) exceptions to Russia trade and transport sanctions, which provides a list of exceptions that allow activities otherwise subject to sanctions in certain defined circumstances; and (ii) amendments to the Russia sanctions regulations, which provides a non-exhaustive list of statutory instruments that have made changes to the UK’s Russia sanctions regulations. Read more>> and Read more
• UK Government amends one entry on the UK sanctions list under the Russia regime: On September 23, the UK amended the entry for Yuri Olegovish Denisov on the UK sanctions list under the Russia regime. This individual remains subject to an asset freeze. Read more>>
• UK Government removes one entry on the UK sanctions list under the Russia regime: On September 22, the UK removed the entry for Tatiana Evtushenkova from the UK sanctions list under the Russia regime. Read more>>
• UK adds four entries to the UK sanctions list and proscribes two ships under the Russia regime: On September 19, the UK added Otar Anzorovich Partskhaladze, Levan Shioyevich Vasadze, HeliCo Group LLC and Aeza International Ltd to the UK sanctions list under the Russia Regime. The UK also proscribed two ships, Bavly and Karakuz, under the Russia regime. According to the UK Government, these measures target Georgia’s hidden supporters of Russia. Read more>> and Read more>>
• UK issues News Media Services General Licence: On September 19, OFSI issued General Licence INT/2025/7159960 (the "GL") in respect of "News Media Services", under the UK Autonomous Sanctions Regulations listed in Annex I of the GL, which includes the Russia (Sanctions) (EU Exit) Regulations 2019. Read more>>
• UK amends Civilian Telecommunication Services General Licence: On September 19, OFSI amended General Licence INT/2022/1875276 (the "GL") in respect of "Civilian Telecommunication Services", pursuant to Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019. Read more>>
• OFSI moves General Licences relating to Intershipping Services LLC and Litasco Middle East DMCC to expired licence page: On September 19, OFSI moved General Licence INT/2025/6488808 (relating to the wind down of positions involving Litasco Middle East DMCC) and General Licence INT/2025/6397444 (relating to the wind down of activities relating to Intershipping Services LLC). Read more>>, Read more>> and Read more>>
• UK amends one entry on the UK sanctions list under the Russia regime: On September 18, the UK amended the entry for Autel Robotics Co., Ltd on the UK sanctions list under the Russia regime.  This entity remains subject to an asset freeze. Read more>>
• UK Government adds 30 entries to the UK sanctions list and proscribes 70 ships under the Russia regime: On September 12, OFSI added 27 entities and three individuals to the UK sanctions list and proscribed 70 ships under the Russia sanctions regime. The new measures primarily target the Russian oil and defence sectors. Read more>>
• UK Government removes Ilya Brodskiy from UK sanctions list under Russia regime: On September 11, the UK Government removed Ilya Brodskiy from the UK sanctions list under the Russia regime.  According to OFSI’s notice, this individual is a former member of the supervisory board of Sovcombank. Read more>>
• UK High Court finds that owners made reasonable decision in good faith not to perform sub-charter due to sanctions risk: The judgment in Ceto Shipping Corporation v Savory Shipping Inc. [2025] EWHC 2033 (Comm), which was handed down on July 31, 2025, has been made public.  Among other things, Savory and the ship manager (DelfI0 refused to performance a charter for the carriage of Iranian origin oil due to concerns that this would breach US sanctions with regard to Iran and concerns that the cargo may have been ultimate destined for Venezuela and that the charter had been set up with the involvement of a sanctioned individual.  The management agreement provided that “[Delfi] shall not be obliged to comply with the provisions of this Agreement if in [its] reasonable judgment… it will expose them or their… crew, registered owners, to any sanction… imposed by any State.”  The Court accepted evidence that the risk of Savory and Delfi, among others being designated as an SDN was ‘very high’ in this case.  The Court concluded that Savory was entitled to refuse to perform the charter and Delfi was not in breach by acting on this refusal. Read more>>
• UK government adds 11 entries to the UK sanctions list under the Russia regime: On September 3, the UK added three entities, namely All-Russian public-state movement of children and youth “Movement of the First” , Akhmat Kadyrov Foundation, and Volunteers of Victory, and eight individuals to the UK sanctions list under the Russia regime. According to the UK Government, these new sanctions target those supporting Putin’s attempts to forcibly deport and indoctrinate Ukraine’s children and erase their Ukrainian cultural heritage. Read more>> and Read more>>
• OFSI revokes Evraz North America General Licence: On September 3, the UK OFSI revoked General Licence INT/2022/1710676, which authorised parties to continue certain business operations involving the North American subsidiaries of Evraz plc, namely Evraz North America plc, Evraz Inc. NA, Evraz Inc. NA – Canada and their subsidiaries, subject to certain terms and conditions. Read more>>
• Lowered Oil Price Cap enters into force: On September 2, 2025, the UK lowered the oil price cap from USD 60 to USD 47.50, as announced on July 18, 2025. OFSI has published FAQs 154 to 161 to support industry in adapting to the lower price cap and explain the 45-day wind down period. Read more>>, Read more>> and Read more>>

IV. Russia/Ukraine Sanctions

• Ukraine imposes sanctions on officials of the Occupation Authorities in Crimea, propagandists, and pro-Russian figures from Moldova: On September 20, Ukraine imposed sanctions on eighty-three officials, businesspeople, and those involved in human rights violations in temporarily occupied Crimea, as well as on propagandists and pro-Russian figures from Moldova. President Volodymyr Zelenskyy signed three decrees to enact the decisions of the National Security and Defense Council of Ukraine. Read more>>, Read more>> and Read more>>
• Ukraine synchronizes sanctions with the United Kingdom and imposed restrictions on entities supporting Russia’s military-industrial complex, shadow fleet, and energy sector: Ukraine has aligned its sanctions with the United Kingdom by imposing restrictions on dozens of individuals and entities supporting Russia’s military-industrial complex, shadow fleet, and energy sector, targeting those involved in supplying electronics, coal, IT solutions, and equipment to Russia, and ensuring these measures are coordinated with allied jurisdictions. Read more>>
• Ukraine confiscates 1,600 Russian railway wagons: On September 3, Ukraine seized railway wagons belonging to Russian residents and the Russian Federation. The Presidential Envoy for Sanctions Policy Vladyslav Vlasiuk said that “the owners of these wagons are sanctioned residents of the Russian Federation… the compulsory seizure of these wagons will ensure their transfer into state ownership of Ukraine – in fact, Ukrzaliznytsia is already using them”. Read more>> and Read more>>

V. other notable developments

• New Zealand Sanctions Russian Military Hackers Over Cyberattacks on Ukraine: On September 15, New Zealand imposed sanctions on Russian military intelligence hackers accused of cyberattacks on Ukraine, including members of a notorious hacking unit previously tied to destructive malware campaigns. The sanctions imposed an asset freeze and a travel ban and prohibit New Zealand citizens and companies from making funds available to the designated entities. Read more>>
• Japan Expands Sanctions Against Russia: On September 12, Japan announced sanctions against Russia, freezing the assets of 14 individuals and 51 organizations, including Russian officials, company executives and pro-Russian figures in Ukraine. Japan also announced it will cut the current oil price cap to $47.60 from $60 per barrel, which was set in 2022 by the G7, aiming to reduce Russia's oil revenue. Read more>>
• Australia Adopts Targeted Sanctions on Russia: On September 3, Australia imposed targeted financial sanctions and travel bans against 14 individuals determined to be “responsible for silencing political expression in Russia, as well as enabling the illegal and immoral invasion of Ukraine.” Read more>>