Russia/Ukraine Sanctions Update - Month of September 2026

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

I. US Sanctions

• President Signs Russia and Iran Sanctions Bill into Law: On September 18, 2026, President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 into law. The Act provides the President with new sanctions authorities and requires the imposition of sanctions on certain Russia-related parties. The Act also introduces tariffs of up to 500% on goods imported from Russia and up to 100% on goods from the top importers of Russian energy products or countries that facilitate evasion of Russian sanctions. Most provisions take effect on October 18, 2026. Read more >>
• OFAC Removes Individuals from SDN List: On September 16, 2026, OFAC removed the following individuals and entities from the SDN List who were designated under Executive Order 14024: BOMATTER, Hans Peter, La Zubia and MODULSAN MAKINA KESICI TAKIM VE DISLI SANAYI TICARET LIMITED SIRKETI. Read more >>
• OFAC Extends General License for Sale of Lukoil International GmbH: On September 18, OFAC issued General License No. 131J 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, October 22, 2026. General License No. 131J replaces and supersedes General License No. 131I, dated August 20, 2026. The general license does not authorize the transfer of funds to any person or account located in the Russian Federation. Read more >> 

II. EU Sanctions

• EU Imposes Additional Sanctions on Russia Over Forced Deportation and Re-Education of Ukrainian Children: On September 28, the EU added 10 persons and 17 entities to the list of persons, entities and bodies subject to asset freeze and/or travel ban measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Read more >>, Read more >>
• EU Imposes Additional Sanctions on Russia Over Repression of Democratic Opposition: On September 28, the EU added 10 individuals to the list of persons subject to asset freeze and travel ban measures under the EU sanctions regime in view of the situation in Russia. The listings follow the barring of the Yabloko political party from participating in the September 2026 elections to the State Duma and the sentencing of its deputy chair, Lev Shlosberg, to more than 11 years in prison over anti-war speech. Read more >>, Read more >>
• EU Lists Xenia Fedorova Over Information Manipulation Activities: On September 24, the EU added Xenia Fedorova, a Russian media figure and former senior executive of Russia Today France, to the list of persons subject to asset freeze and travel ban measures under the EU's restrictive measures in view of Russia's destabilising activities. Read more >>, Read more >>
• EU Extends Individual Sanctions Against Russia for Three Years: On September 22, the Council decided to prolong the sanction measures targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for another 36 months, until 22 September 2029. In the context of the sanctions' review, the Council also decided not to renew the listings of three individuals, Mr. Alisher Usmanov, Mr. Mikhail Fridman, Mr. Andrey Pavlovich Falaeev and one entity, Redbird Corporate Services Ltd., as well as to remove three deceased persons from the list. Read more >>, Read more >>
• EU General Court Annuls Sanctions Listing of Mr Oleg Tkach: By its judgment delivered on September 23, the General Court removed Russian national Oleg Tkach, for 2024 and 2025, from the list of persons sanctioned by the EU. According to the General Court, the reasons that led to EU sanctions against that person - being a member of Russia’s Federation Council that ratified the cooperation treaties between Moscow and the occupied Ukrainian regions, and being the founder of a publishing group controlling the publishing house Enlightenment, involved in promoting the war - were valid when the Russian military aggression was launched. However, they are no longer sufficient to justify keeping Mr. Tkach on the EU sanctions list. Read more >>
• EU's General Court Dismisses Actions Against Belarus Sanctions Brought by Two Entities: By its judgments delivered on September 23, the General Court dismissed actions against EU sanctions in view of the situation in Belarus brought by OAO Belaz-upravljajusaja kompanija holdinga Belaz Holding, a Belarusian manufacturer of trucks and other heavy transport equipment, and OAO Minskii Avtomobilnyi Zavod – upravljajusaja kompanija holdinga Belavtomaz, a Belarusian motor vehicle manufacturing company. Read more >>, Read more >>
• EU's General Court Dismisses Actions Against EU Sanctions Brought by Two Individuals: By its judgments delivered on September 16, the General Court dismissed actions against EU sanctions brought by Roman Trotsenko and Polina Sergeevna Gagarina. Read more >>, Read more >>
• EU General Court Dismisses the Action Brought by Mr Roman Abramovich: By its judgment delivered on September 9, the General Court dismissed the action brought by Mr Roman Abramovich, thereby upholding the sanctions measures taken against him. The General Court rejected the argument that the measures at issue were adopted de facto by the working parties of the Council. It held that the designation criteria are objective, sufficiently precise and proportionate, and that it is the application of those criteria, having regard to the importance of Mr Abramovich's capital holdings, which led to the adoption of restrictive measures against him. The Court further held that the measures comply with the Charter of Fundamental Rights, including as regards restrictions on the freedom of movement of EU citizens, since the restrictions are proportionate and appropriate to the objective of promoting a peaceful settlement of the crisis in Ukraine. Read more >>
• EU General Court Dismisses Hungary's Action Against the European Peace Facility: By its judgment delivered on September 9, the General Court dismissed Hungary's action against the decision of the European Peace Facility (EPF) Committee that allocated the first instalment of extraordinary revenues from frozen Russian assets to support for the Ukrainian Armed Forces. The General Court held that it does not have jurisdiction to examine the legality of such a decision, since it is directly related to the political or strategic choices made in the context of the EU’s common foreign and security policy. The General Court found that the contested decision made political or strategic choices within the framework of the CFSP, inasmuch as it determined the allocation and specific distribution of the funds to the financing of the acquisition of equipment of a military nature intended for the Ukrainian Armed Forces. Read more >>
• EU Court of Justice Clarifies Application of Asset Freeze Measures to Non-Designated Entities Based on Ownership/Control: By its judgment delivered on September 3, the Court of Justice ruled on a preliminary reference from the Supreme Administrative Court of Lithuania concerning the application of EU asset freeze measures under Decision 2014/145/CFSP and Regulation (EU) No 269/2014 to entities not themselves listed in the EU sanctions annexes. The Court held that Member States may maintain national lists of non-designated entities considered subject to EU asset freeze measures on the basis of ownership or control by a designated person, and that doing so does not amount to the imposition of national or additional sanctions, but constitutes implementation of EU sanctions. The Court further clarified that the mere existence of "links" with a designated person is not sufficient: it must be established that the funds or economic resources of the non-designated entity "belong to" or are "owned, held or controlled by" a designated person. As regards the standard of proof, ownership or control must rest on an objective and sufficiently solid basis, which can be established through direct evidence (e.g. corporate registers) or a sufficiently specific, precise and consistent set of indicia, in particular where the control is indirect or informal. The Court stressed that "control" requires a genuine influence, i.e. the ability to concretely and effectively influence the decisions of the non-designated entity. Member States cannot automatically assume that Russian State-owned entities are "controlled" by the President of the Russian Federation: control must be assessed on a case-by-case basis and cannot be solely derived from abstract claims based on the autocratic or oligarchic nature of Russia's political regime. Read more >>
• EU Commission President Signals Shift in Sanctions Strategy: In her annual State of the Union speech, European Commission President Ursula von der Leyen suggested that the EU should focus on enforcing existing sanctions rather than proposing fresh restrictive measures on Russia. "The pressure on Russia must continue to increase. And this does not always require new sanctions, but above all the enforcement of existing ones," she stated, adding that Russia is doing everything it can to circumvent sanctions, so the EU must close all loopholes. The remarks came amid delays in the adoption of the latest sanctions package caused by disagreements among Member States. Read more >>
• HR/VP Kallas Proposes Assigning Sanctions Evasion Cases to the European Public Prosecutor's Office: EU High Representative for Foreign Affairs and Security Policy and Vice-President of the European Commission K. Kallas proposed at a meeting with ambassadors of EU Member States that the European Public Prosecutor's Office be tasked with investigating cases involving the circumvention of sanctions against Russia. The Luxembourg-based European Public Prosecutor's Office could investigate supplies of sensitive goods that Moscow may use for its war machine, as well as money laundering for the Kremlin. Prosecutors could also examine violations of rules governing dealings with sanctioned Russian and Belarusian entities and prohibited transactions within the EU. Currently, enforcement of EU sanctions is complicated by differing national legislation and varying approaches by prosecutors in the 27 capitals. Read more >>
• EU Commission Examines Irish Investigation Report on Alumina Export to Russia: According to press reports, the European Commission is still examining the investigation report submitted by the Irish government on the export of alumina from the Aughinish Alumina plant in Limerick, Europe's largest alumina refinery, owned by Russian aluminium giant Rusal. The Irish investigation found no definitive evidence linking the export to Russian weapons manufacturers, while qualifying that it could not be ruled out. At the informal meeting of the EU Foreign Affairs Ministers in Wicklow, HR/VP Kallas stated that the EU must "forcefully crack down sanctions circumvention" and noted that Ukraine has identified more than 5,500 Western and Asian components in Russian weapons. Alumina is currently not subject to EU export restrictive measures. Read more >>
• Finnish Customs Uncovers Large-Scale Sanctions Circumvention Scheme: Finland's Customs uncovered a large-scale scheme to circumvent EU sanctions, under which industrial equipment worth nearly €6 million was illegally exported to Russia. Local companies from Eastern Finland declared shipments of pumps and engines to Kazakhstan and Türkiye, but in fact diverted them to the Russian Federation. Customs suspects two people of a large-scale violation of the sanctions regime, and the materials will be submitted to the prosecutor's office of Eastern Finland by the end of the year. Read more >>
• Luxembourg Probes Gazprombank Ex-Managers Over Sanctions Circumvention Allegations: According to press reports, Luxembourg's finance ministry has asked the public prosecutor to investigate allegations of sanctions circumvention and possible insider trading by former managers of Gazprombank Luxembourg, the last major Russian bank operating in Europe. Four former directors at Gazprombank Luxembourg allegedly enriched themselves through a bond-trading scheme that may have circumvented sanctions. They took advantage of the chaos unleashed by EU sanctions against Russia in 2022, buying cut-price Gazprom bonds and replacing them with newly issued bonds in Russia, which traded at full price. These swaps could have netted profits of more than €9 million. Read more >>
• Rosneft Billions Fed Kremlin-Backed Money Laundering Network: According to a Financial Times investigation, billions of dollars of Rosneft's foreign earnings were funnelled through a Kremlin-backed money laundering network, putting the state oil group at the heart of Russia's efforts to circumvent sanctions and supply its war in Ukraine. A vast document leak from inside A7, a Moscow-backed fintech company, shows that Rosneft-connected traders supplied more than $2 billion in vital hard currency to the group, which has paid for battlefield supplies and other imports to Russia. A7 aims to enable clients in Russia to make international payments despite being shut out of the Swift system. Using forged documents, the company set up front companies in other jurisdictions and used these entities to make international payments within Swift on behalf of Russian buyers. Read more >> 

III. UK Sanctions

• OFSI publishes new FAQ on interest accruing on frozen accounts: On 14 September 2026, OFSI added FAQ 203 which clarifies that the exception allowing relevant institutions to credit a frozen account with interest or other earnings due on the account only applies where the interest or other earnings are credited to the same account on which they accrue, even if a separate account has been nominated to receive the relevant interest or other earnings or has otherwise been identified as the receiving account of such earnings under the contractual or other arrangements governing the account.  Read more >>
• Illumina Cambridge pays HMRC £7.4 million compound settlement: On 8 September 2026, HMRC announced that Illumina Cambridge Limited paid HMRC a compound settlement of £7,438,840.13 relating to breaches of Russia sanctions involving the supply sanctioned goods from one overseas group entity to another for export to Russia and other destinations. Read more >>
• UK court holds that freezing injunctions and asset disclosure order are not "funds" or "economic resources": In VTB v Kuanyshev [2026] EWHC 2140, the High Court considered an application to set aside a freezing injunction obtained by VTB, an assets freeze target. The defendants argued (inter alia) that the freezing injunction and the asset disclosure order each independently resulted in a breach of the sanctions, because they effectively compelled the defendants and any third parties bound by the orders to make funds available to VTB or to confer an economic benefit on VTB. The Court rejected this. It held that a freezing injunction is not “funds”, but an in personam order which restrains a defendant from dealing with his own assets, which does not create any proprietary or other interest in favour of the applicant. A freezing injunction is also not an economic resource, because it cannot be exchanged or used in exchange for funds, goods or services.  The Court further held that information provided pursuant to an asset disclosure order was not “funds” because it does not have intrinsic financial value; and neither is it an “economic resource”, because it is not an asset that can be used directly to obtain funds, goods and services. Read more >>
• UK court holds that liquidators' consent to assignment of rights by a sanctioned entity does not breach Russia sanctions: the UK High Court ruled that the liquidators of Petropavlovsk plc would not breach sanctions by consenting to the assignment of contractual rights held by Atlas JSC, a sanctioned Russian company, to Denali Corp. Read more >>
• NCA, OFSI and the FCDO issue alert on the A7 sanctions evasion network: On 31 August 2026, the NCA and its National Economic Crime Centre, in conjunction with OFSI and the FCDO, issued an alert on A7, a complex web of financial structures and tools hosted between Kyrgyzstan and Russia, with state-level backing, which is used to circumvent financial and trade sanctions. This alert highlights the risks posed to the international financial system and red flags to be alert for. Read more >> 

IV. Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In September 2026, Ukraine extended the sanctions to 29 legal entities, 30 individuals and 20 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 >> and Read more >>
• EU Renews Russia Sanctions but Removes Usmanov and Fridman: The EU agreed to renew its individual sanctions against Russia while removing businessmen Alisher Usmanov and Mikhail Fridman from the sanctions list, lifting their asset freezes and travel bans. The decision followed two weeks of negotiations, with France pushing for Usmanov’s delisting, while Slovakia and Luxembourg supported removing Fridman as well. Read more >>
• US and Gulf Consortium Seeks to Acquire Lukoil’s International Assets: Investors from the US, UAE and Qatar have formed a consortium to acquire Lukoil’s international assets, which the Russian oil company put up for sale following US sanctions imposed in October 2025. The consortium is led by US billionaire Todd Boehly and includes UAE and Qatari investors as well as the US International Development Finance Corporation (DFC), seeking to take over a deal previously agreed between Lukoil and Carlyle. Read more >>
• Russia Nationalizes Assets Of Auchan, Nestlé And Leroy Merlin: Russian President Vladimir Putin signed a decree transferring the Russian assets of Auchan and Nestlé, as well as those of former Leroy Merlin operations, under the control of the Russian entity L.E.V. Management. The decree also covers the assets of logistics companies FM Logistics and Bati Logistics, while L.E.V. Management, established in Moscow in October 2024, has no disclosed ultimate beneficiaries or significant commercial activity. The move follows years of Russian threats to confiscate Western companies’ assets in retaliation for international sanctions and the freezing of Russian state assets abroad. Read more >>
• Raiffeisen Bank Accused of Helping Russia Circumvent Sanctions: Austria’s Raiffeisen Bank International (RBI), the largest Western bank still operating in Russia, has been accused by short-selling firm Grizzly Research of facilitating more than $1 billion in Russian trade that allegedly circumvents Western sanctions. Grizzly claimed that RBI’s Russian subsidiary had become a key channel for trade payments, including transactions involving goods allegedly used in Russian weapons production. RBI rejected the report as misleading and containing factual errors. Read more >>
• Russia Extends Food Embargo Against Western Countries Through 2028: Russian President Vladimir Putin has extended Russia’s food embargo against countries subject to or supporting anti-Russian sanctions through the end of 2028. The measures, first introduced in 2014, currently cover the US, EU, UK, Canada, Australia, Norway, Ukraine and several other countries, with restrictions applying to products including meat, dairy, fish, vegetables and fruit. The embargo also provides for the destruction of prohibited food imports and imposes additional controls on their transit through Russia. Read more >>

V. Other Notable Developments

• Swiss Voters Reject Proposal to Restrict Neutrality and Limit Sanctions Authority: On September 27, Swiss voters firmly rejected a proposal to adopt a more restrictive form of neutrality that would have blocked Switzerland from imposing economic sanctions or cooperating with NATO. About 70% of voters and all cantons rejected the proposal, which was backed by the right-wing Swiss People's Party (SVP) and would have required that Switzerland refrain from joining any sanctions unless approved by the United Nations. Foreign Minister Ignazio Cassis said the result allows Switzerland to continue deciding on economic sanctions on a case-by-case basis. Read more >>
• Australia Signs Bilateral Security Agreement with Ukraine and Imposes Additional Sanctions on Russia: On September 24, Prime Minister Anthony Albanese and President Zelenskyy signed the Australia–Ukraine Bilateral Security Agreement, providing a framework for defense and security cooperation. Australia also announced an additional $60 million in support to Ukraine, including $45 million in defense equipment, $10 million for Ukraine's Energy Support Fund and $5 million in humanitarian assistance, bringing Australia's total contribution to nearly $1.9 billion. The Australian government also imposed additional sanctions on Russia, bringing its total to almost 1,900 sanctions on Russia and its supporters, and almost 300 shadow fleet vessels listed. Read more >>
• Japan Pledges to Continue Sanctions Pressure on Russia: On September 23, Japanese Prime Minister Sanae Takaichi pledged in a meeting with President Zelenskyy on the sidelines of the U.N. General Assembly in New York that Japan will continue to pressure Russia through sanctions as the war has entered its fifth year. Takaichi stated that Japan will work on Ukraine assistance and sanctions against Russia in coordination with the international community. Read more >>

• Canada Sanctions Eight Individuals Over Forcible Transfer of Ukrainian Children: On September 4, Canada imposed sanctions on eight individuals over their involvement in the unlawful deportation, forcible transfer, indoctrination and militarization of Ukrainian children. The measures were announced during President Zelenskyy's visit to Canada. Canada co-chairs the International Coalition for the Return of Ukrainian Children. With the new package, Canadian sanctions against Russia now cover more than 3,500 individuals and entities, with more than 600 shadow-fleet vessels listed separately. Read more >>

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