Russia/Ukraine Sanctions Update - Month of April 2026

US Sanctions | EU Sanctions | UK Sanctions | Russia/Ukraine Sanctions

I. US Sanctions 

• OFAC Issues General License for the Delivery and Sale of Russian Federation Crude Oil and Petroleum Products: On April 17, OFAC issued a 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 vessels blocked under the above-listed authorities, on or before 12:01 a.m. eastern daylight time, April 17, 2026, through 12:01 a.m. eastern daylight time, May 16, 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 >> 

• OFAC Issues Amended Russia-Related General License Relating to Directive 4: On April 8, OFAC amended a general license authorizing US persons, or entities owned or controlled, directly or indirectly, by a US person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, Prohibitions Related to 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, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such US persons or entities, through 12:01 a.m. eastern daylight time, July 9, 2026. Read more >>

• OFAC Issues Amended Russia-Related General Licenses and FAQs Regarding Lukoil: On March 30, OFAC issued an amended general license and related FAQs authorizing certain transactions for the negotiation of and entry into contingent contracts for the sale of Lukoil International GmbH ("Lukoil") and related maintenance through 12:01 a.m. eastern daylight time, May 1, 2026, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from OFAC. On April 14, OFAC issued an amended general license and FAQ authorizing certain transactions involving Lukoil retail service stations located outside of Russia and certain Lukoil entities in Bulgaria through 12:01 a.m. eastern daylight time on October 29, 2026. On April 29, OFAC issued a further amended general license and FAQs extending authorization for certain transactions for the negotiation of and entry into contingent contracts for the sale of Lukoil and related maintenance through 2:01 a.m. eastern daylight time, May 30, 2026, again provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from OFAC. Read more >>, Read more >> and Read more >>

• Presidents Trump and Putin Discuss Iran War and Ukraine Ceasefire During Call: According to the Guardian, on April 29, President Trump and President Putin held a phone call to discuss the war in Iran and floated a temporary ceasefire in Ukraine. In the call, President Putin "said Moscow viewed the prospect of a US ground operation in Iran as dangerous, while welcoming Trump's decision to extend a ceasefire in the region, according to Yuri Ushakov, Putin's foreign policy adviser." Read more >>

II. EU Sanctions

• EU Adopts 20th Package Against Russia and Parallel Sanctions on Belarus: On April 23, the EU adopted its 20th package of sanctions targeting Russia, along with parallel amendments to the EU’s sanctions regime against Belarus. The package is intended to increase pressure on the energy, finance, and military‑industrial sectors, and to target both Russia and those helping Russia evade sanctions. Reflecting the package’s anti‑circumvention focus, the EU also extended certain trade restrictions to cover specified trade flows involving Kyrgyzstan. Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >> and Read more >>

• EU Imposes New Sanctions on Two Russian Entities Over Information Manipulation: On April 21, the EU added two additional entities responsible for Russia’s continued hybrid activities, in particular propaganda and disinformation, to the list of natural and legal persons subject to asset freeze and/or travel ban measures. Read more >> and Read more >>

• Commission Answer on Reported Ammunition-Related Production in Belarus: The European Commission was questioned regarding the reported involvement of China National Electronics Import & Export Corporation (a Chinese state-owned enterprise) in the construction in Belarus of a production line for 122 mm rocket warhead components. The Commission confirmed that it is aware of the information and is monitoring developments that may contribute to Russia’s ability to sustain its war of aggression against Ukraine. The Commission further indicated that it continues to engage with China at all levels, calling on Beijing to cease any support that directly or indirectly strengthens Russia’s military capabilities. Read more >> and Read more >>

• EU Court of Justice Dismisses Appeal Brought by Mr. Konov: By its judgment delivered on April 29, the General Court dismissed the action brought by Mr. Dmitry Konov challenging his listing. Read more >>

• EU General Court Annuls Sanctions Listing of Mr. Chevtsov: By its judgment delivered on April 22, the General Court annulled the acts maintaining Mr. Viktor Arkadievich Chevtsov’s name 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 substantiate, to the requisite legal standard, the reasons relied on to justify both the initial listing and the subsequent maintenance of the applicant’s name on those lists. Read more >>

III. UK Sanctions

• UK government issues Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026: On April 23, the UK government amended its sanctions regimes by issuing the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026, which come into force on 13 May 2026. These regulations affect end-user controls, financing monitoring thresholds, electronic notices, and broaden the prior obligations licensing ground. These regulations create new end-user controls for which OTSI has updated its guidance in order to help UK businesses understand sanctions end-use controls and how to ensure compliance. Read more >>

• OTSI updates guidance on end-user controls: On April 22, OTSI updated its guidance on end-user controls. The controls constitute a new licensing requirement for export to a non-sanctioned third country where the exporter has been informed by the government that there is a risk of ultimate diversion of the goods or related technology, via that route, to a sanctioned destination. These controls build upon current ‘making available’ prohibitions, that make it an offence to make available restricted goods and technology to a sanctioned destination by direct or indirect means. This measure will only apply to goods, or technology related to the export of a good, that are not otherwise subject to strategic export controls. Read more >>

• OFSI extends general licence under Russia Sanctions: On April 9, OFSI extended the general licence INT/2026/8893924 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, the Maritime Mutual Re-Insurance Wind Down General Licence, to 8 July 2026. Read more >>

• The UK Government extended its general trade licence Russia sanctions - sectoral software and technology: On April 1, the UK Government has extended the licence which authorises the provision of some business software and technology to Russia which would otherwise be prohibited by Chapter 4N of the UK Russia Sanctions Regulations. The previous version of this licence has been revoked, and a new identical licence has been issued. The new licence will expire on 30 October 2026. Read more >>

• OFSI fines Apple Distribution International Ltd (“ADI”) £390,000 for Russia sanctions breaches: On March 30, OFSI fined ADI £390,000 for making funds available to an entity owned by a UK‑designated person under the Russia (Sanctions) (EU Exit) Regulations 2019. This is the first time that OFSI’s settlement mechanism has been used to resolve a sanctions breach case. ADI, an Irish subsidiary of Apple Inc., instructs payment transactions for developers on the Apple App Store. In 2022, it instructed a UK bank to make two payments totalling £635,618.75 to Okko LLC. At the time of the payments Okko was owned by JSC New Opportunities, which the UK designated on the day the first payment was processed. Read more >>

• UK Supreme Court hands down judgement in Celestial Aviation case: On March 25, in UniCredit Bank GmbH, London Branch (Respondent) v Celestial Aviation Services Ltd (Appellant) [2026] UKSC 10, the Supreme Court determined that Regulation 28(3) of the Russia (Sanctions) (EU Exit) Regulations 2019 prohibited payment by UniCredit (a German bank) under letters of credit (“LCs”) issued by Sberbank in respect of leases of aircraft to Russian airlines entered into before the imposition of the prohibition. The Court also held (obiter) that UniCredit would have had a defence under section 44 of the Sanctions and Anti-Money Laundering Act 2018, which provides protection for acts done in the reasonable belief that the act is in compliance with sanctions. Read more >>

• UK Prime Minister's Office issues press release on shadow fleet vessels in UK waters: On March 25, the UK Government issued a press release stating that British military forces will be able to board shadow fleet vessels transiting UK waters. Read more >>

IV. Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In April 2026, the President of Ukraine adopted 8 Orders extending the sanctions to 57 legal entities and 204 individuals. The extended sanctions lists cover the entities involved in military production in Belarus and close to the President of Belarus Alexandr Lukashenko. The sanctions also cover 23 vessels registered in various jurisdictions and involved in operations of the shadow fleet. The full list of the sanctioned persons is available at the website of the State Sanctions Register of Ukraine. Read more >>

• Ukraine Nationalizes Russian-linked Stake in Major Railcar Manufacturer: Ukraine has seized a significant share previously owned by a Russian businessman in one of the country’s largest railway wagon producers, expanding state control over strategic industry. A court ordered the confiscation of roughly 25% of shares in the Kryukiv Railway Car Building Works as part of sanctions targeting assets linked to Russia’s war effort. The stake has now been transferred to Ukraine’s State Property Fund, marking another step in Kyiv’s broader policy of reclaiming Russian-owned assets for national use during the conflict. Read more >>

• Ukraine Urges Israel to Seize a Vessel Carrying Allegedly Stolen Grain: The Prosecution Service of Ukraine has formally asked Israel to detain a vessel it claims is carrying grain looted by Russia from occupied Ukrainian territories, escalating diplomatic tensions. Kyiv called on Israeli authorities to inspect the cargo, gather evidence and question the crew, while also criticizing a previous case where a similar ship was allowed to unload. Israel rejected the accusations, saying no sufficient evidence had been provided, as the ship’s operators insist the grain is of Russian origin. Read more >>

• EU Unlocks EUR 90 Billion Loan for Ukraine as Druzhba Oil Flows Resume: The EU formally approved a €90 billion loan for Ukraine after oil deliveries through the Druzhba pipeline to Hungary and Slovakia resumed, ending a months-long standoff triggered by Hungary's veto over the frozen funds. The pipeline, which carries Russian crude through Ukraine, had been offline since late January following damage caused by a Russian drone strike. This prompted Hungary's outgoing Prime Minister Viktor Orbán to block the loan on the grounds that Kyiv was delaying repairs. Read more >>

• Russia to Halt Kazakh Oil Flows to Germany via Druzhba Pipeline from May: Russia has confirmed it will suspend the transit of Kazakh crude oil to Germany through the Druzhba pipeline from 1 May, in a move that threatens a key refinery supplying the vast majority of Berlin's fuel. The PCK Schwedt refinery, located approximately 100 kilometres north of Berlin, relies on Kazakh oil delivered via the pipeline for around 17% of its total throughput of nearly 12 million metric tons per year, having switched away from Russian crude. Germany's Federal Ministry for Economic Affairs and Energy has stated that the halt does not ultimately jeopardize the country's security of supply, though the refinery would need to operate at reduced capacity and source alternatives via ports such as Gdansk and Rostock. Read more >>

• Russia Bans Gasoline Exports for Producers Until End of July: Russia has imposed a ban on gasoline exports by producers until 31 July in a bid to stabilize its domestic fuel market amid rising global oil prices and seasonal demand pressures. The government cited the need to ensure steady supply during the spring agricultural sowing campaign, with exemptions granted only for countries holding intergovernmental fuel supply agreements with Moscow. The ban extends restrictions first introduced in January for non-producers, and follows persistent shortages across several Russian regions. Read more >>

• Russia Restricts Helium Exports Beyond the Eurasian Economic Union Until End of 2027: The Russian government has imposed a temporary permit-based regime on helium exports outside the Eurasian Economic Union (EAEU) through the end of 2027, citing the need to secure stable domestic supply of a gas critical to fibre-optic manufacturing and other industries. Under the new rules, helium shipments will require authorisation from the Prime Minister, First Deputy Prime Minister, or a supervising Deputy Prime Minister, based on a proposal from the Ministry of Industry and Trade. The restrictions come amid wider disruptions to global helium supply chains triggered by the Middle East conflict, with Qatar — a major world supplier — having ceased exports of helium Read more >>

• Kyrgyzstan Says EU Sanctions Undermine Trust Amid Ongoing Dialogue: Kyrgyzstan's Foreign Ministry has expressed regret over the inclusion of Kyrgyz entities in the EU's 20th sanctions package against Russia, saying the unilateral measures undermine the atmosphere of trust built between the two sides and contradict Brussels' stated commitment to deepening cooperation with Central Asia. Bishkek stressed that it had consistently engaged in open and constructive dialogue with the EU on sanctions compliance, including providing all documentation requested by the European Commission, but that its position had effectively been ignored. The sanctions followed EU accusations — voiced by sanctions envoy David O'Sullivan – that Kyrgyzstan had become a conduit for re-exporting European goods, including potentially military-applicable equipment, to Russia in breach of sanctions, with the 20th package imposing a ban on CNC machine tool exports to the country and restrictions on transactions with several banks in Kyrgyzstan, Laos, and Azerbaijan. Read more >>

• Russia Expands Travel Ban on EU Representatives in Response to 20th Sanctions Package: Russia has expanded its list of EU representatives banned from entering the country, in a retaliatory move following the EU's 20th sanctions package adopted on 23 April. The blacklist includes officials from EU institutions and member states involved in decisions on military aid to Ukraine and the imposition of sanctions. Russia’s Foreign Ministry did not disclose how many people were added to the entry ban list or their names. Read more >>

• Moscow Court Orders Euroclear to Pay Alfa-Capital Over 15 Billion Rubles for Blocked Securities Income: The Moscow Arbitration Court has ruled in favour of Russian asset manager Alfa-Capital, ordering Belgium's Euroclear Bank to pay more than 15 billion roubles in damages representing income accrued on securities belonging to Alfa-Capital's clients that were frozen under EU anti-Russian sanctions. The ruling, issued on 6 April, fully upheld the claim. The Belgian Treasury had previously rejected Alfa-Capital's direct request to unfreeze the assets. Read more >>