Russia/Ukraine Sanctions Update - Month of October 2025

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

I. U.S. Sanctions 

• U.S. Department of the Treasury Announces Balkans-Related Designation Removals: On October 29, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the deletion of several Balkans-related designations. OFAC also issued an amended Frequently Asked Question (“FAQ”) relating to the provision of petroleum services to Russia, as a well as Russia-related General License 129, which authorizes certain transactions involving Rosneft Deutschland GmbH and RN Refining & Marketing GmbH. Read more>>
• OFAC Designates Russia’s Two Largest Oil Companies: On October 22, OFAC designated Russia’s two largest oil companies, Open Joint Stock Company Rosneft Oil Company and Public Joint-Stock Company Oil Company Lukoil, “as a result of Russia’s lack of serious commitment to a peace process to end the war in Ukraine.” OFAC also designated several Russia-based Rosneft and Lukoil subsidiaries. As part of the designations, Secretary of the Treasury, Scott Bessant, emphasized “Treasury is prepared to take further action if necessary to support President Trump’s effort to end yet another war” and encouraged U.S. allies to “join us in and adhere to these sanctions.” OFAC also issued and amended four General Licenses relating to these designations. Read more>>
• U.S. Secretary of State Hosts Call with Russian Foreign Minister: On October 20, U.S. Secretary of State, Marco Rubio, spoke with Russian Foreign Minister, Sergey Lavrov, to discuss next steps following a call between President Trump and President Putin, held on October 16. On the call, Secretary Rubio “emphasized the importance of upcoming engagements as an opportunity for Moscow and Washington to collaborate on advancing a durable resolution of the Russia-Ukraine war, in line with President Trump’s vision.” Read more>>
• OFAC Issues Amended Russia-Related General License and FAQs: On September 29, OFAC issued an amended Russia-related General License 13O, which authorizes certain administrative transactions in Russia—such as paying taxes and fees and obtaining permits—otherwise restricted by Directive 4 of Executive Order 14024 through January 9, 2026. Directive 4 prohibits U.S. persons from engaging in transactions involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. OFAC also updated two FAQs relating to Directive 4. Read more>>

II. EU Sanctions

• EU Adopts 19th Package Against Russia and Parallel Sanctions on Belarus: On October 23, the EU adopted its 19th package of sanctions targeting Russia, including parallel measures aligning sanctions on Belarus. This package targets primarily the energy, financial and military industrial sectors, while addressing circumvention concerns through a mix of list-based sanctions, enhanced trade controls (including on liquefied natural gas), services restrictions and reinforced financial sanctions. Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>>, Read more>> and Read more>>
• EU Commission Updates its Guidance on Sanctions Against Russia and Belarus: On October 16, the European Commission issued updated guidance on export-related restrictions concerning dual-use goods and advanced technologies; on October 29, it further updated its guidance regarding oil imports and the ban on refined products derived from Russian crude oil. Read more>>, Read more>> and Read more>>
• EU Commission Comments on EU Airlines Problems Due to Sanctions against Russia: In response to an inquiry regarding the financial challenges faced by EU airlines due to EU sanctions against Russia and the resulting competitive advantages enjoyed by Chinese, Turkish, and Gulf carriers such as Emirates, the European Commission confirmed that it is aware of the detours European airlines must undertake to reach many Asian destinations following the closure of Russian airspace to Union carriers. Although these detours lead to longer and more expensive operations, the Commission noted that EU airlines continue to report profit growth, supported by the robust post Covid recovery in other aviation markets. The Commission also recalled that, in 2016, it proposed that Member States pursue an EU wide aviation agreement with China, but this was not taken forward by the Member States. The Commission remains ready to engage with Member States on this matter. Read more>> and Read more>>
• EU Commission Comments on Russian Cryptocurrency Bypassing EU Sanctions to Move Capital and Fund Foreign Influence Campaigns: The European Commission was questioned on new cryptocurrency token, the A7A5, allowing Russia to make cross-border payments despite Western sanctions. In the four months following its launch, A7A5 is said to have processed approximately USD 9.3 billion on a dedicated crypto exchange and has been described as a powerful tool for evading sanctions, enabling the movement of Russian capital across borders to finance political influence operations abroad. The Commission commented that it is for the Council to determine the content of Council Regulations imposing EU sanctions. As guardian of the Treaties, the Commission reiterated its commitment to combating sanctions circumvention, including via cryptocurrencies, wherever such practices are identified. Read more>> and Read more>> 
• EU's General Court Annuls Sanctions March 2025 Listing of Ms. Galina Pumpyanskaya: By its judgment delivered on October 15, the General Court annulled the March 2025 acts maintaining Ms. Galina Evgenyevna Pumpyanskaya on the Russia related sanctions lists. The Council had extended Ms. Pumpyanskaya’s listing on the basis that she was an immediate family member benefiting from her husband, Dmitry A. Pumpyanskiy, who was characterized as a “leading businessperson operating in Russia”. According to the General Court, that basis cannot stand in light of its judgment of 10 September 2025 in T 541/24, Pumpyanskiy v Council, which found that the Council had wrongly classified Mr Pumpyanskiy as a “leading businessperson operating in Russia.” Read more>>
• EU's General Court Annuls Sanctions Listing of Mr. Mikail Gutseriev: By its judgment delivered on October 22, the General Court annulled the listing of the Russian businessman operating in Belarus, Mr. Mikail Gutseriev, ruling that the Council made an error of assessment when it maintained restrictive measures based on outdated evidence of his ties to Belarusian President Alexander Lukashenko. The General Court found that the Council’s evidence supporting several grounds for Mr. Gutseriev’s listing was either insufficient or related exclusively to past events. The Court also noted that the Council had not proved that Mr. Gutseriev continued to have business interests in Belarus at the time of the contested acts that would allow him to be regarded as a prominent businessperson with substantial business interests in several sectors, such as potash, energy and commercial property, or as having a prosperous personal relationship with President Lukashenko. Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Several Individuals: In its judgments delivered in October, the General Court dismissed the actions brought by Ms. Maria Albot and Mr. Gennady Nikolayevich Timchenko and Mrs. Elena Petrovna Timchenko challenging their listings. Read more>> and Read more>>
• EU Seeks to Boost Powers to Board Russian Shadow Fleet Vessels: According to a document prepared by the European External Action Service, the EU diplomatic arm, the issue of ships transporting Russian oil sailing under different flags to escape EU sanctions has wide implications as those vessels not only help to boost Russia's economy but also "pose threats to the environment and to navigation safety”. The shadow fleet ships also are a risk for critical infrastructure and "can be used as platforms for hybrid attacks against EU territory," the document states. The EU plans to provide an additional tool to Member States to boost the effectiveness of enforcement actions, including providing a basis to board shadow fleet ships, and proposes "possible bilateral agreements between the flag states and the EU on pre-authorized boardings for inspections.” Read more>>
• Cyprus Introduces Criminal Liability for Circumventing Sanctions Against Russia: To implement the EU directive harmonizing criminal offences and penalties for violations of EU restrictive measures, Cyprus is introducing criminal liability for the circumvention of Russia related sanctions. In particular, making funds or economic resources available to designated persons will now constitute a criminal offence. Read more>>
• Poland Sanctions Firms Exporting Steel to Russia: Poland has imposed autonomous sanctions, in addition to EU measures, on STEELTRADE Sp. z o.o. (formerly EMK Group) and OMNI GRP Sp. z o.o. for indirectly supporting Russia’s war against Ukraine through exports and re-exports of metal and steel products banned under EU sanctions, including steel sheet, plate, and flat-rolled products made of alloyed and non-alloyed steel or cast iron. According to Polish authorities, STEELTRADE – registered in 2019 and controlled by Belarusian citizen Uladzimir Liashchuk – exported nearly PLN 30 million (approximately USD 8.25 million) worth of steel to Russia in 2021–2022, later redirecting over PLN 110 million in shipments to Kazakhstan and then to a Hong Kong intermediary that re-exported the goods to Russia. More than 200 shipments reportedly ended up in Russia. OMNI GRP, founded in 2022 and led by Andrei Karpovich together with Liashchuk and Veranika Pental, carried out similar exports to Turkey, China, and Kazakhstan, using intermediaries that supplied Russia. Read more>>
• Baltic Companies Secretly Fueling Russia’s Shadow Fleet: Lithuanian-flagged tankers Rina and Zircone have reportedly supplied fuel to vessels linked to Russia’s so called “shadow fleet,” conducting 286 ship to ship bunkering operations between June 2024 and March 2025. In that period, they refueled 177 oil tankers, 159 of which subsequently called at Russian ports. Both tankers are said to be tied to Fast Bunkering, whose subsidiaries are already under investigation in Estonia on suspicion of document falsification. The scheme allegedly involved importing Russian oil products into the EU disguised as Kazakh-origin cargo through the use of falsified customs codes. Read more>>
• Russia Allegedly Circumvents Sanctions to Build Underwater Surveillance Network Shielding Nuclear Submarines: Russia has allegedly evaded Western sanctions by using shell companies to procure American and European underwater surveillance technologies and is deploying them to protect its nuclear submarine fleet. Reportedly, these acquisitions – ranging from sensitive sonar systems and deep-sea drones to advanced underwater antennas and vessels disguised as commercial or research ships – fed into a multiyear effort to build an underwater surveillance network in the Barents Sea and other cold waters. Read more>>

III. UK Sanctions

• UK Government amends five entries on the UK Sanctions list under the Russia regime: On October 23, the UK Government updated the entries for Alexandr Shulgin, Namina Dadashova, Mihajlo Perenčević, Alisher Usmanov and USM Holdings Limited on the UK sanctions list under the Russia regime. Read more>>
• OFSI issues General Licence relating to continuation of business of Rosneft’s German subsidiaries: On October 22, OFSI issued General Licence INT/2025/7598960, which authorises UK persons to continue business operations with certain named German subsidiaries of PJSC Rosneft Oil Company, subject to certain terms and conditions. The General Licence expires on October, 22, 2027. Read more>>
• UK Government responds to written question relating to Chelsea FC: On October 23, Lucy Rigby MP responded to a written question raised to the Chancellor of the Exchequer in relation to whether the UK is working with the EU and G7 partners to release frozen Russia-linked assets and the proceeds from the sale of Chelsea Football Club.  The UK Government response noted that the Chancellor is actively working with EU and G7 partners to explore all viable legal avenues to make use of Russia’s sovereign assets for the benefit of Ukraine in line with international law and that the UK Government is seeking to ensure that the proceeds from the sale of Chelsea FC are directed towards humanitarian causes in Ukraine as swiftly as possible. Read more>>
• UK Government extends General trade licence Russia sanctions – sectoral software and technology: On October 16, the Export Control Joint Unit (ECJU) extended the validity of General trade licence Russia sanctions – sectoral software and technology, which authorises inter alia the transfer of business enterprise software and technology that is otherwise prohibited by Chapter 4N of the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. The expiration of the general licence has been extended from October 20, 2025 to April 17, 2026. Read more>> and Read more>>
• UK Government amends one entry on the UK Sanctions list under the Russia regime: On October 16, the UK Government amended the entry for German Valentinovich Belous on the UK sanctions list under the Russia regime. This individual is still subject to an asset freeze. Read more>>
• UK Government adds 39 entries to UK Sanctions List and specifies 51 ships under the Russia regime: On October 15, the UK Government added 24 entities, including Rosneft, Lukoil and Nayara Energy Limited, and 5 individuals to the UK sanctions list and specified 51 ships under the Russia regime.  According to the UK Government, these measures represent the UK’s “strongest sanctions yet on Russia, choking off energy revenues that flow into its war chest by directly targeting oil giants Rosneft and Lukoil.” Read more>> and Read more>>
• OFSI amends Russian Oil Exempt Projects General Licence: On October 15, OFSI amended General Licence INT/2025/5635700, which authorises the continuation of business operations with certain parties to the extent they are in relation to certain oil projects.  The scope of ‘relevant subsidiaries’ to which the general licence relates was expanded to include Lukoil, Rosneft and any entity they respectively own or control; the list of exempt projects was expanded to include inter alia Shah Deniz, the Caspian Pipeline Consortium and the Azerbaijan Gas Supply Company.  The exemption for these oil exempt projects expires on October 14, 2027. Read more>>
• OFSI issues General Licence relating to the wind-down of transactions involving certain energy entities: On October 15, OFSI issued General Licence INT/2025/7538856, which authorises the wind down of any transactions involving Nayara Energy Limited, National Pipeline Group Beihai Liquified Natural Gas Co Ltd, Shandong Yulong Petrochemical Company, Shandong Baogang International Port Co, Jingang Port Co, Shandong Haixing Port Co or any of their subsidiaries, subject to certain terms and conditions. The general licence expires on November 13, 2025. Read more>>
• OFSI issues General Licence relating to the wind-down of transactions involving Rosneft and Lukoil: On October 15, OFSI issued General Licence INT/2025/7539056, which authorises the wind down of any transactions involving PJSC Lukoil Oil Company, PJSC Rosneft Oil Company or any of their subsidiaries, subject to certain terms and conditions. The general licence expires on November 28, 2025.Read more>>
• OFSI amends General Licence relating to petrol station payments for UK nationals in Kyrgyzstan and Tajikistan: On October 15, OFSI amended General licence INT/2025/5886860, which authorises certain payments to be made by UK nationals to purchase petrol from certain designated parties in Kyrgyzstan or Tajikistan.  The list of designated persons to which this General Licence relates now includes PJSC Lukoil Oil Company and PJSC Rosneft Oil Company, as well as their subsidiaries. The General Licence expires on March 15, 2027. Read more>>
• OTSI publishes blog post highlighting the role of good due diligence in preventing breaches of trade sanctions: On October 13, the Office of Trade Sanctions Implementation (OTSI) published a case study highlighting the role of good due diligence in preventing breaches of trade sanctions. The case study related to the receipt of a number of suspected breach reports from the UK branch of a multinational bank in connection with the trade of certain products from Russia to a third country.  Owing to trade sanctions concerns, the UK branch in question performed enhanced due diligence checks and did not process the payments, and so OTSI concluded that there had not been a breach of trade sanctions.  OTSI included 8 key takeaways for industry arising from this case study. Read more>>
• OFSI issues £152,750 monetary penalty to pharmaceutical company for breach of financial sanctions under the Russia regime: On September 30, OFSI issued a £152,750 monetary penalty to Colorcon Limited for making funds available to UK designated persons in breach of UK financial sanctions relating to Russia. In particular, between 23 March and 2 December 2022, the company made 79 payments worth £128,277.72 to non-designated employees and service providers with accounts held at certain sanctioned Russian banks in violation of UK sanctions.  In its penalty notice, OFSI stated in its compliance lessons for industry, among other things, that it is insufficient for companies to rely on third parties to conduct sanctions screening on their behalf, sanctions policies and processes should be regularly reassessed to maximise effectiveness in response to the changing geopolitical landscape, and breaches should be disclosed to OFSI as soon as reasonably practicable after discovery. Read more>>

IV. Russia/Ukraine Sanctions

• Ukraine intensifies sanctions drive to hasten an end to the war: On October 29, President Volodymyr Zelenskyy affirmed that Ukraine’s sanctions campaign is advancing. Following the alignment of the EU’s 19th sanctions package within Ukraine’s jurisdiction, work is already underway on the EU’s 20th package. He urged continued global and Ukrainian sanctions against Russia and noted he is awaiting a detailed intelligence assessment of the impact of recent U.S. sanctions on Russian oil companies, with preliminary data described as promising. Read more>>
• Ukraine calls for the EU to expand their next sanctions package for Russia: On October 24, Vladyslav Vlasiuk met with the Ambassador of Denmark to Ukraine and said that after securing unanimous EU support for the 19th sanctions package, it is important that the next sanctions package includes further restrictions on Russia’s financial sector and alternative payments, personal sanctions, and the infrastructure of the shadow fleet. Read more>>
• Ukraine urges for stronger sanctions against Russia at the European Council Meeting: On October 23, President Volodymyr Zelenskyy proposed creating strong sanctions control, and real consequences for those who break the rules. He emphasised that they will coordinate with Norway, Switzerland, and the UK, and others so they apply these strong EU measures in their own systems. Zelenskyy said that the world should respect EU sanctions the same way it respects U.S. sanctions. Read more>>
• Ukraine imposes new and extended sanctions targeting Russia’s military‑industrial complex, oil-linked actors, and companies tied to sanctioned oligarchs: On October 4, President Zelenskyy enacted three decrees imposing sanctions on 33 individuals and 27 entities supplying Russia’s defense sector (including drone, optical, and aviation producers and suppliers circumventing controls such as Hardberry Rusfactor, Jupiter Plant, Valday Opto‑Mechanical Design Bureau, and Shenzhen Weiliao tied to the Alabuga drone plant), extending for two years 2023 sanctions on companies linked to Petr Aven, Mikhail Fridman, and Andrei Kosogov, and sanctioning four individuals and three entities connected to Russia’s oil sector (including Nefteavtomatika and the Kurgan Plant of Chemical Machine Building) for attempts to penetrate Ukraine’s financial system; Kyiv signaled accelerated alignment with partner jurisdictions and support for a robust 19th EU sanctions package. Read more>>

V. Other notable developments

• Switzerland Implements New Sanctions Against Russia: On October 30, Switzerland announced sanctions against Russia to implement the European Union’s 18^th package of sanctions, which includes asset freezes for 14 people and 41 companies and organizations, stricter export control measures, and the lowering of the price cap for Russian crude oil. Switzerland also announced a complete transaction ban on 45 Russian banks. Read more>>
• New Zealand Sanctions Russian Shadow Fleet: On October 29, New Zealand announced sanctions against Russia’s oil industry and shadow fleet, which included the designations of 65 vessels and actors from Belarus, Iran, and North Korea “involved in refining and transporting Russian oil, and in facilitating oil-related payments.” Read more>>