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

I. US Sanctions

  • U.S. Secretary of State Celebrates Ukraine National Day: On August 24, U.S. Secretary of State, Marco Rubio, issued a statement congratulating the Ukrainian people on the anniversary of its independence from the Soviet Union. In his statement, Secretary Rubio emphasized the U.S. “is committed to Ukraine’s sovereignty and continues to work to support a negotiated settlement to the Russia-Ukraine war that establishes a lasting and durable peace.” Read more >>
  • OFAC Extends General License for Certain Diamond Imports: On August 26, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 104B under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587), extending the authorization for certain transactions ordinarily incident and necessary to the importation into the United States of certain categories of non-industrial diamonds. The authorization covers non-industrial diamonds with a weight of 1.0 carat or greater (that were physically located outside of the Russian Federation before March 1, 2024) and non-industrial diamonds with a weight of 0.5 carats or greater (that were physically located outside of the Russian Federation before September 1, 2024), provided such diamonds were not exported or re-exported from the Russian Federation after those respective dates. The general license extends the authorization through 12:01 a.m. eastern daylight time, September 1, 2027. General License No. 104B replaces and supersedes General License No. 104A, dated August 27, 2025. The importation of non-industrial diamonds of Russian Federation origin remains prohibited pursuant to section 1(a)(i)(A) of Executive Order 14068. Read more >>
  • OFAC Extends General License for Sale of Lukoil International GmbH: On August 20, OFAC issued General License No. 131I under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587), extending the authorization for certain transactions prohibited by Executive Order 14024 that are ordinarily incident and necessary to the negotiation of and entry into contingent contracts with Public Joint-Stock Company Oil Company Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. The general license also authorizes transactions ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements of LIG Entities. Both authorizations are extended through 12:01 a.m. eastern daylight time, September 19, 2026. General License No. 131I replaces and supersedes General License No. 131H, dated July 24, 2026. The general license does not authorize the transfer of funds to any person or account located in the Russian Federation. Read more >>
  • U.S. House Introduces Sweeping Russia and Iran Sanctions Bill: On August 10, a broad bipartisan group of U.S. House members introduced the House companion to the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, days after the Senate approved the legislation by an 86-11 vote. The bill, named after the late Senator Lindsey Graham, would target Russian banks, energy revenues, oligarchs, Russia’s “shadow fleet,” sanctions-evasion networks, and foreign governments and companies helping sustain Russia’s war against Ukraine. Key provisions include authorization of tariffs of up to 500 percent on goods imported from Russia and up to 100 percent on goods from countries that are among the largest purchasers of Russian crude oil or natural gas or leading facilitators of Russian oil sanctions evasion. The bill would also prohibit new U.S. investment in Russia, restrict investment in Russia’s energy sector, prohibit purchases of Russian sovereign debt, and target financial-messaging services used to circumvent sanctions. Additionally, the legislation would extend the Iran Sanctions Act of 1996 through 2031. The bill provides that the president may terminate the Russia-related sanctions only after certifying to Congress that Russia has signed a peace agreement accepted by Ukraine’s government and has ceased military hostilities against Ukraine. The House companion bill is identical to the Senate-passed measure. Read more >>

II. EU Sanctions

  • EU Imposes Additional Sanctions on Russia : On August 7, the EU added five Russian individuals to the list of persons subject to asset freeze and travel ban measures responsible for supporting Russia’s military and industrial complex in the context of its ongoing war of aggression against Ukraine. Read more >>; Read more >>
  • Human Trafficking and Illicit Recruitment of Foreign Nationals for Russia’s War of Aggression: On August 6, the High Representative/Vice-President Kallas responded to a parliamentary question on Russia’s deceptive and coercive recruitment of third country citizens, including from African states, to fight in its war against Ukraine and to work in its military industry. The HR/VP indicated that the EU strongly condemns these practices and that this issue has been raised in diplomatic and political contacts with affected countries, which have been invited to warn their citizens against signing up for job or training opportunities in Russia. The European External Action Service has also been raising awareness through public diplomacy and strategic communication campaigns, including through the network of EU Delegations, notably in Africa. The HR/VP further noted that possible specific measures have been discussed with the leadership of Ukraine, given the varying circumstances of the foreign nationals in question. As regards targeted sanctions, the HR/VP recalled that any additional restrictive measures on individuals and entities are decided by the Council by unanimity. Read more >>; Read more >>
  • Russia Expands Shadow LNG Fleet to Circumvent EU Sanctions: According to press reports, Russia has expanded its shadow LNG fleet to 25 vessels, including at least eight second-hand tankers acquired in the past six months and two domestically built carriers from the Zvezda shipyard, ahead of the EU’s full ban on Russian LNG imports taking effect in 2027. The shadow tankers, owned by Russia-linked shell companies in Dubai, Hong Kong, and Singapore, use flags of convenience, signal jamming, and ship-to-ship transfers to disguise cargo origins, mirroring the tactics of Russia’s 1,000-strong oil “dark fleet.” Further expansion faces constraints as France’s GTT, which holds a near monopoly on specialised LNG containment systems, has suspended Russian contracts and six ice-class vessels remain blocked at South Korea’s Hanwha shipyard due to sanctions. Read more >>
  • Gazprombank Luxembourg Directors Allegedly Profited from EU Sanctions via Bond Swap Scheme - A Financial Times investigation revealed that four managing directors at Gazprombank Luxembourg used personal loans from Gazprombank Moscow (totalling over €17 million) to purchase discounted Gazprom bonds on the European market between July and November 2022, then swapped them for full-value rouble-denominated replacements in Russia under a programme decreed by President Putin, potentially netting combined profits exceeding €9 million. The trades raised questions about circumvention of EU sanctions on Russia’s National Settlement Depository, which was involved in settling the bond replacements, and about possible use of insider information given the directors’ coordinated purchases shortly before Gazprom publicly announced eligible bonds. Luxembourg’s financial regulator (CSSF) inspected the bank in 2023 but imposed no fines and found only internal policy violations, drawing criticism of the country’s light-touch regulatory approach. Read more >>

iii. UK Sanctions

  • OTSI publishes Annual Review for 2025-26: On 27 August 2026, the Office of Trade Sanctions Implementation (OTSI) published its Annual Review for 2025-26. In the reporting period, OTSI received 178 reports or referrals relating to potential breaches of trade sanctions. The majority of reports were submitted by the financial services sector and related to potential breaches under the UK Russia regime. 104 enforcement cases were closed, with 41 for which no breach was identified and 40 cases which were closed by OTSI and referred to HMRC for a range of reasons, including criminal enforcement consideration or where potential breaches predate OTSI’s enforcement powers. Read more >>
  • OFSI amends General Licence INT/2025/5635700: On 31 July 2026, OFSI amended General Licence INT/2025/5635700 under the Russia (Sanctions) (EU Exit) Regulations 2019, which permits the continuation of business operations with certain sanctioned entities relating to certain oil projects, to add the Kurdistan Export Pipeline to the list of relevant projects. Read more >>; Read more >>
  • OTSI publishes guidance on banknotes trading: On 3 August 2026, OTSI issued guidance on the prohibitions under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 and the Russia (Sanctions) (EU Exit) Regulations 2019 on supplying banknotes. The guidance explains the prohibitions and the exception for personal use in the context of travel to Russia and Belarus. Read more >>
  • House of Commons Library publishes updates on Russian sanctions: On 3 August 2026, the House of Commons Library published a research briefing entitled “Sanctions against Russia: What has changed since January 2025?”. The briefing notes that since January 2025 the UK has tightened sanctions against Russia, continued to target Russia’s shadow fleet, implemented further measures designed to restrict Russia’s energy revenues and financed the purchase of military equipment for Ukraine using the proceeds from frozen Russian assets. The briefing also notes that the UK government plans to introduce new legislation to target sanctions evasion and the export of goods to third countries which are then re-directed to Russia. Read more >>
  • New sanctions package targeting Russia: On 6 August 2026, the UK sanctioned certain Russian banks, shadow fleet ships, other entities and one individual under the Russia (Sanctions) (EU Exit) Regulations 2019. Read more >>; Read more >>
  • UK extends Lukoil-related general licences and adds reporting requirement: On 12 August 2026, the UK amended General Licence INT/2025/7895596 under the Russia (Sanctions) (EU Exit) Regulations 2019, which authorises the continuation of business operations with four Lukoil Bulgaria entities, to (inter alia) add a new notification requirement and to extend the term of the General Licence to 29 October 2026. The UK also amended General Licence INT/2025/8031092, which allows the continuation of business operations with Lukoil International GmbH and its subsidiaries, to (inter alia) add a new notification requirement and to extend the term of the General Licence to 26 February 2027 Read more >>; Read more >>; Read more >>; Read more >>

iv. Russia/Ukraine Sanctions

  • Ukraine Extends the Sanction Lists: In August 2026, Ukraine extended the sanctions to 97 legal entities and 118 individuals. The sanctions cover Russian companies in aluminium, agricultural and military sectors. Separate sanctions were also imposed against 13 vessels 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 >>; Read more >>, Read more >>, Read more >>, Read more >>, Read more >>
  • Ukraine Proposes Expanding the Grounds for Imposing Sanctions: Ukraine’s government has introduced a draft law that would allow the Foreign Ministry to independently propose the imposition, amendment, or removal of sanctions to the National Security and Defence Council. The legislation would also permit Ukraine to use sanctions decisions adopted by foreign governments in response to Russia’s armed aggression as a basis for imposing corresponding Ukrainian restrictions, provided they do not conflict with Ukraine’s national interests. In addition, the bill sets out new grounds for lifting sanctions, including the achievement of their objectives and relevant decisions by the UN, EU, or foreign authorities. Read more >>
  • Ukraine Calls on EU to Sanction Rosatom: Ukraine renewed Kyiv’s call for the EU to sanction Russia’s nuclear energy giant Rosatom following reports of safety, security and engineering failures at one of its projects in Egypt. Ukraine, which sanctioned Rosatom in 2023, argues that Russia’s actions at the Chornobyl and Zaporizhzhia nuclear sites demonstrate that Moscow cannot be trusted in the nuclear sector. However, EU-wide sanctions remain blocked by the need for unanimous approval among all 27 member states, while Rosatom continues to maintain and expand its nuclear projects in several European countries. Read more >>
  • Russia Threatens To Seize EU-Linked Vessels In Response To Sanctions Enforcement: President Vladimir Putin warned that Russia could seize vessels linked to “unfriendly” EU states in retaliation for European efforts to board and confiscate cargo from ships carrying sanctioned Russian oil. Moscow accused EU countries of violating international maritime law and said it has the capability to inspect or detain EU-linked and third-country “shadow fleet” vessels. At the same time, Russia plans to expand Arctic shipping with China, India and other partners, with the Northern Sea Route increasingly used to transport Russian oil to Asian markets and potentially shorten voyages compared with the Suez Canal. Read more >>
  • Putin Signs Law Allowing Russia to Strip Foreign Companies of Buyback Rights: President Vladimir Putin signed a law allowing Russian asset owners to reject foreign investors’ contractual rights to repurchase assets or stakes in Russian companies sold after 22 February 2022. The restrictions apply to investors from “unfriendly” states and can be triggered by support for anti-Russian sanctions or criticism of the Russian military, as well as by economic factors such as a buyback price deviating from market value by at least 25% or additional investments made by the Russian buyer. Affected foreign investors may seek compensation within one year, although the court can reduce or deny such payments. Read more >>
  • Putin Signs Law Imposing Restrictions On Russians Convicted In Absentia: President Vladimir Putin signed a law imposing financial, property, and consular restrictions on Russians living abroad who have been convicted in absentia, including for offenses commonly used against Kremlin critics and anti-war activists. Those placed on a new official register will face frozen assets, blocked banking and property transactions, restricted access to government services, and limits on obtaining passports and other consular documents. The measure is part of a broader package of legislation expanding state control, which also introduces a tightly regulated cryptocurrency market and grants authorities wider access to confidential business data in the food sector. Read more >>
  • Russia and Myanmar Sign Declaration to Counter Sanctions: Russia and Myanmar signed a joint declaration on countering, mitigating, and compensating for the negative effects of unilateral sanctions following talks between Presidents Vladimir Putin and Min Aung Hlaing in Moscow. The document was exchanged by the two countries’ foreign ministers alongside other agreements signed during the Myanmar president’s visit to Russia. The move underscores the two countries’ efforts to coordinate their response to foreign sanctions and strengthen bilateral cooperation. Read more >>
  • EU Increases Imports of Russian LNG Despite Plans to End Supplies in 2027: EU countries increased imports of Russian liquefied natural gas (LNG) by 14% year-on-year in June, with France accounting for the largest share. The increase came amid disruptions to global LNG supplies caused by the war between Iran and the US, which sharply reduced exports through the Strait of Hormuz. Despite the surge, the EU plans to phase out Russian LNG entirely from January 2027, while Russia remained the bloc’s second-largest LNG supplier in the first half of 2026, after the US. Read more >>

v. Other Notable Developments

  • Switzerland Approves 20th Sanctions Package Against Russia: On August 20, the Swiss government approved the 20th package of sanctions against Russia, aligning itself with the European Union. In the energy sector, Switzerland issued new service bans concerning liquefied natural gas (LNG) tankers, icebreakers, and LNG terminals based in Russia, and prohibited the sale of tankers to Russia. Switzerland also activated, for the first time, the anti-circumvention tool designed to prevent the circumvention of existing sanctions via third countries; in practical terms, the export of certain sensitive goods to Kyrgyzstan is now prohibited. In the financial sector, the government banned the use of Russian platforms for the transfer and exchange of cryptocurrencies and prohibited support for the development of certain Russian cryptocurrencies, such as the digital Ruble. Currently, around 2,790 individuals, companies, and organizations in Switzerland are subject to asset freezes in connection with Russia’s war against Ukraine. Read more >>
  • Canada Sanctions Defence Manufacturing Company: On August 10, Canada announced the imposition of sanctions on Streit Group under the Special Economic Measures (Russia) Regulations. Streit Group is a defence manufacturer that produces armoured vehicles and other military equipment. Canada imposed the sanctions following multiple credible reports confirming that armoured vehicles manufactured by Streit Group have been used by the Russian National Guard (Rosgvardia) in Russia’s ongoing war against Ukraine. By sanctioning Streit Group, Canada is aligning with similar measures taken by Ukraine in 2023 and by the European Union and Switzerland in 2025. Read more >>
  • New Zealand Announces 36th Round of Russia Sanctions: On August 8, New Zealand Foreign Minister Winston Peters announced a new round of sanctions targeting 33 individuals and entities supporting Russia’s war against Ukraine. The package focuses particularly on cyber actors, as well as those involved in the forced relocation, abduction, and re-education of Ukrainian children. The sanctions also target individuals supporting Russia’s military-industrial complex, Russian political figures, and North Korean and Iranian actors providing support to Moscow. Since the Russia Sanctions Act came into force in March 2022, New Zealand has imposed sanctions on more than 2,000 individuals, entities, and vessels. Read more >>

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