Russia/Ukraine Sanctions Update - Month of October 2026

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

I. US Sanctions

• U.S. Discussing Sanctions Relief for Russian Direct Investment Fund: On October 28, the Kremlin confirmed that Russia is discussing sanctions relief with the Trump administration for the Russian Direct Investment Fund ("RDIF"), Russia's flagship state investment fund. A U.S. official said the administration was assessing RDIF's application for sanctions to be removed through established procedures as part of an effort to "improve U.S.-Russia relations and help end the war". The Biden administration imposed sanctions on RDIF in February 2022. Read more >>
• OFAC Extends General License for Sale of Lukoil International GmbH: On October 21, OFAC issued General License No. 131K, extending through November 21, 2026 the authorization for transactions related to the negotiation of contingent contracts for the sale of Lukoil International GmbH ("LIG") and its majority-owned entities, and to the maintenance or wind down of their operations. General License No. 131K replaces and supersedes General License No. 131J. OFAC also amended FAQs 1224 and 1225.  Read more >>
• President Waives Graham Act Sanctions and Tariffs: On October 16, President Trump signed Executive Order 14436 implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, but waived nearly all of its sanctions and tariff provisions. The waived provisions include the Act's mandatory sanctions on Russian officials, state-owned entities, financial institutions, "shadow fleet" vessels and sanctions evasion networks. They also include the Act's investment, sovereign debt and energy-related restrictions. The order also waives Section 102(d), the provision that codifies sanctions under existing Russia-related Executive Orders. However, the order states that those existing sanctions are not affected. The waivers remain in effect until the President or the Secretary of State determines that further action is appropriate. Read more >>
• OFAC Extends General Licenses for Lukoil Retail Stations and Bulgarian Entities: On October 15, OFAC issued two amended Russia-related general licenses. General License No. 128D extends through April 24, 2027 the authorization for transactions involving Lukoil retail service stations located outside of Russia. General License No. 130B extends through April 24, 2027 the authorization for transactions involving certain Lukoil entities in Bulgaria, including Lukoil Neftohim Burgas JSC. OFAC also amended FAQ 1225. Read More >>

II. EU Sanctions

• EU Extends Sanctions Regime Targeting Russia’s Hybrid Activities Until October 2027: On October 8, the EU extended the restrictive measures in view of Russia’s destabilising activities until 9 October 2027. These sanctions currently apply to 80 individuals and 20 entities. At the same time, the entries concerning eight individuals were amended and one entry was deleted. Read more >>
• EU Imposes Sanctions on Russian Businesswoman Olga Belyavtseva: On October 8, the EU added Ms. Olga Belyavtseva, owner of companies active in the agriculture, manufacturing, finance, consulting, construction and real estate sectors, to the list of persons subject to asset freeze and travel ban measures in view of Russia’s actions against Ukraine’s territorial integrity, after her entry under the hybrid threats regime was deleted. 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 >>, Read more >>, Read more >>
• EU Adopts Largest-Ever Package of Listings Targeting Russia’s Military-Industrial Complex: On October 12, the EU added 826 entities and 743 individuals to the list of persons subject to asset freeze and travel ban measures for belonging to, or acting as executives of, entities of Russia’s military-industrial complex. The 1,569 listings, the largest set ever agreed by the EU, target suppliers of key components for missiles, UAVs and aircraft and bring the total number of listings under the regime concerning Ukraine’s territorial integrity to close to 4,600. Read more >>, Read more >>
• EU Sanctions 77 Individuals Over Illegal State Duma “Elections” in the Occupied Territories of Ukraine: On October 12, the EU added 77 individuals involved in the so called Russian State Duma "elections" held in September 2026 in the temporarily occupied territories of Ukraine, to the list of persons subject to asset freeze and travel ban measures. Read more >>
• EU Removes Two Individuals from the Belarus Sanctions List: On October 13, the EU removed Mr. Mikail Gutseriev and Mr. Viktar Shautsou from the list of persons subject to restrictive measures in view of the situation in Belarus. Read more >>, Read more >>
• EU Lists Three Individuals and Nine Entities for Circumventing EU Sanctions: On October 15, the EU added three individuals and nine entities to the list of persons subject to asset freeze and/or travel ban measures for their involvement in the import of sanctioned goods into Russia and in the circumvention of EU sanctions relating to oil and financial transactions. The listings include logistics operators, a payment agent and trading companies based in Russia and Türkiye, as well as entities based in the United Arab Emirates, India and the Seychelles forming part of Russia’s “shadow fleet ecosystem”.  Read more >>, Read more >>
• Commission Issues FAQ on Energy Exports to Russia: On October 23, the Commission issued its FAQ on energy exports to Russia, confirming that EU operators may not export refined petroleum products, such as diesel, to Russia under Article 3k of Council Regulation No 833/2014. The Commission also recalled that Article 3c separately prohibits the export of jet fuel and fuel additives, and that the prohibitions extend to related technical assistance, brokering services, financing and financial assistance. Read more >>
• EU’s General Court Partially Annuls Sanctions Listings of IRISL and Its Director: By its judgments delivered on September 30, the General Court annulled the November 2024 acts listing the Islamic Republic of Iran Shipping Lines (IRISL) and its director, Mr. Khiabani, under the sanctions regime targeting Iran’s military support to Russia’s war of aggression against Ukraine, but upheld the July 2025 acts maintaining their listings. The Court found that evidence that vessels of IRISL subsidiaries had transported a missile propellant precursor from China to Iran sufficed to justify the maintenance of the listings. Read more >>, Read more >>
• EU’s General Court Annuls Sanctions Listing of Mr. Boguslayev: By its judgment delivered on October 7, the General Court annulled the acts maintaining Mr. Vyacheslav Boguslayev, former president of JSC Motor Sich, on the Russia-related sanctions lists. The Court found that, by re-adopting identical reasons on the same factual basis as earlier acts already annulled, without new evidence, the Council had failed to comply with Article 266 TFEU and committed a sufficiently serious breach of EU law, but dismissed the claim for damages for lack of proof of the alleged harm.  Read more >>
• EU Court of Justice Rules That the Inclusion of Aircraft on the Flight Ban List May Be Challenged: By its judgment delivered on October 8, the Court of Justice set aside the General Court’s order dismissing as inadmissible the action brought by Kyrgyz airline Global 8 Airlines against the inclusion of its aircraft on the list of aircraft subject to the EU flight ban under Council Regulation No 833/2014. The Court held that the Commission’s decision to include the aircraft on that list is an act having binding legal effects that may be challenged, and referred the case back to the General Court. Read more >>
• EU’s General Court Annuls Sanctions Listing of Mr. Kharkovsky: By its judgment delivered on October 21, the General Court annulled the listing of Mr. Andrei Kharkovsky under the sanctions regime targeting Russia’s hybrid activities. The Court found that the evidence did not establish that he represented the Union of Cossack Warriors of Russia and Abroad in Germany, organised military gatherings or took part in acts of violence. Read more >>
• French Navy Boards Suspected Shadow Fleet Tanker: On October 12, President Macron announced that the French Navy had intercepted and boarded the oil tanker DF Peak in the Indian Ocean, south of Réunion, on suspicion of sailing under a false flag and of involvement in illicit fuel trafficking. According to Ukrainian intelligence, the vessel transports Russian crude oil and is associated with Sovcomflot. Read more >>
• Lithuania Imposes National Sanctions on Usmanov and Fridman: On October 14, the Lithuanian Government froze the funds and economic resources of Alisher Usmanov and Mikhail Fridman, following their removal from the EU sanctions list. On 24 September 2026, both men had been placed on Lithuania's list of foreigners banned from entering the country for five years. Read more >>
• Commission Regrets U.S. Waiver of Graham Act Sanctions: On October 20, the Commission described as “regrettable” the Trump Administration’s decision to waive the application of the principal sanctions, restrictions and tariffs on Russia required under the Lindsey Graham Act, stating that it “impairs international pressure on Russia to end its war”. It concluded that Europe must not lift sanctions until Russia agrees to stop its war and Ukraine obtains a just and lasting peace. Read more >>
• Romania Investigates Supply of Dual-Use Machine Tools to Belarus: Romania’s Directorate for Investigating Organized Crime and Terrorism (DIICOT) is investigating two managers of World Machinery Works S.R.L. for the supply of two dual-use machine tools to an enterprise of the EU-sanctioned BelAZ holding through intermediaries in Germany, India and Kazakhstan. One machine tool reached Kazakhstan, while the second was seized by German customs authorities. Read more >> 
• Experts Call for a European Sanctions Enforcement Agency: In an article published on October 22, two experts of the European Council on Foreign Relations argued that the EU should establish its own sanctions enforcement agency, as U.S. and EU sanctions enforcement priorities increasingly diverge. As a fallback, they proposed a non-executive sanctions-tracing clearing house to collect and analyse intelligence and support national enforcement authorities. Read more >>

III. UK Sanctions

• UK announces new sanctions packages targeting Russia: On 1 and 8 October 2026, the UK announced new sanctions packages under the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). The 1 October sanctions package targets Russia's LNG shadow fleet, including vessels providing bunkering services, Kremlin disinformation networks and those responsible for the torture of Ukrainian civilians and the indoctrination of Ukrainian children. The 8 October package targets the Russian oil companies Zarubezhneft and INK Capital, further shadow fleet tankers, crypto exchanges and payment platforms used to circumvent financial sanctions, and suppliers of goods critical to Russia's military. Following the designation of Zarubezhneft, OFSI issued General Licence INT/2026/11080040, permitting the wind-down of transactions involving Zarubezhneft JSC, until 21 November 2026. Read more >>, Read more >>, Read more >>
• OTSI issues general trade licences for LNG imports to Japan and South Korea: On 1 October 2026, OTSI issued two general trade licences under the Russia Regulations. They permit certain shipping, financial, brokering and legal advisory services for the import of Sakhalin-2 LNG into Japan and South Korea under supply contracts concluded before 17 June 2025, subject to notification and record-keeping requirements. The licences take effect on 1 January 2027.  Read more >>, Read more >>
• OFSI amends General Licence INT/2026/8893924: On 7 October 2026, OFSI amended General Licence INT/2026/8893924 under the Russia Regulations, which permits the wind-down of insurance and reinsurance contracts written by Maritime Mutual entities before their designation. The amendment allows UK banks and payment firms to process wind-down payments under contracts placed outside the UK market, and extends the term of the General Licence to 6 October 2027. Read more >>
• House of Lords questions Government on shadow fleet tanker Leruo: On 26 October 2026, Baroness Goldie asked a Private Notice Question on the decision not to intercept the sanctioned shadow fleet vessel Leruo. In response, while the Government declined to comment on operational decisions, they said any interception would be subject to strict legal procedures and would comply with domestic and international law, and had challenged more than 700 suspected shadow fleet vessels since 2024. Read more >>
• OFSI issues new Legal Services General Licence INT/2026/11112108: On 26 October 2026, OFSI issued General Licence INT/2026/11112108 under most UK autonomous sanctions regimes, including the Russia Regulations, replacing General Licence INT/2026/9512597, which expired on 28 October 2026. The General Licence permits UK law firms and counsel who have provided legal advice to a designated person to receive payment from that person without a specific licence, subject to its terms, clarifying the scope of permitted expenses and introduces monthly reporting requirements. The General Licence expires on 28 April 2027. FAQs 64, 71 and 75 were amended to reflect the updated General Licence. Read more >>, Read more >>
• OTSI publishes guidance on certain professional services and trade sanctions: On 27 October 2026, OTSI published new guidance on the prohibition on providing construction services to persons connected with Russia, which has applied since 20 May 2026. OTSI further updated its guidance on professional and business services sanctions to reflect the construction services prohibition and to clarify the scope of business management, consultancy and public relations services. OTSI also published new guidance on trade sanctions relating to specified ships, including ships specified under the Russia Regulations. The guidance covers the prohibitions on UK persons providing brokering, chartering, crew, financial, operating and technical services to such ships, and on procuring services from them. Read More >>, Read More >>, Read More >>
• OFSI extends General Licence INT/2025/7895596: On 28 October 2026, OFSI amended General Licence INT/2025/7895596 under the Russia Regulations, which authorises the continuation of business operations with four Lukoil Bulgaria entities, to extend the term of the General Licence to 26 February 2027. Read More >>

IV. Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In October 2026, Ukraine extended the sanctions to 127 legal entities, 191 individuals and 2 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 >>, and Read More >>
• Russia Places Metro’s Russian Assets Under Temporary State Management: President Vladimir Putin has transferred three Russian subsidiaries of German retailer Metro, including Metro Cash & Carry Russia, to temporary management by JSC UK Torg Rus under a decree published on 28 September 2026. The management company was established in September and is headed by Johannes Maria Tolay, allowing the existing management to remain in place while foreign owners lose corporate control. The move follows similar measures affecting the Russian assets of Auchan, Nestlé and other foreign companies. Read more >>
• EU Removes Mikhail Gutseriev From Belarus-Related Sanctions List: The EU has removed Russian billionaire Mikhail Gutseriev and Belarusian businessman Viktor Shevtsov from its sanctions list targeting individuals accused of supporting Alexander Lukashenko’s regime, following successful legal challenges. In Gutseriev’s case, EU courts annulled several earlier sanctions decisions after finding that the Council had not provided sufficient evidence that he continued to support or benefit from ties to Lukashenko’s government. However, Gutseriev remains subject to separate EU sanctions imposed in July 2026 over his business activities in Russian economic sectors generating significant state revenue and his alleged support for the Russian government through investment projects. Read more >>
• Moscow Court Rejects Euroclear’s Appeal Against €200 Billion Award To Russian Central Bank: The Moscow Arbitration Court has rejected Euroclear’s cassation appeal, upholding earlier rulings awarding the Bank of Russia approximately €200.1 billion in damages over its loss of access to funds, securities and related income held through the Belgian-based securities depository since February 2022. The claim was fully upheld in May 2026, and subsequent appeals by Euroclear, including a request to suspend enforcement, have been unsuccessful. The case comes amid the EU’s indefinite freezing of approximately €210 billion in Russian assets and ongoing debate over using those funds to finance support for Ukraine, a move Moscow opposes on legal and financial grounds. Read more >>
• Latvia Calls For EU-Wide Ban On Tourist Visas For Russian Citizens: Latvian Prime Minister Andris Kulbergs has urged EU countries to stop issuing tourist visas to Russian citizens, arguing that travel restrictions are needed to prevent hybrid threats allegedly orchestrated by Moscow. The proposal comes amid growing European security concerns following incidents involving drones and suspected sabotage. At the same time France is considering tighter visa restrictions and Germany has called for limits on both personal visits and business travel by Russians. Read more >>

V. Other Notable Developments

• Partner Countries Issue Joint Statement on DPRK Sanctions: On October 28, Australia, Canada, France, Germany, Italy, Japan, the Netherlands, New Zealand, the Republic of Korea, the UK, the U.S. and the EU issued a joint statement on sanctions imposed in October by the EU, Australia and the U.S.. The sanctions target, among other things, actors involved in unlawful DPRK-Russia cooperation, and aim to counter unlawful DPRK-Russia military cooperation. Read more >>
• Canada Criticizes U.S.–Russia Diesel Deal: On October 11, Canadian Prime Minister Mark Carney told President Zelenskyy that the U.S.–Russia diesel agreement "is in direct opposition to the efforts of Ukraine, Canada, and our allies to create peace and stability in Europe" and "will provide additional revenue for Russia". Carney said Canada will maintain and, where effective, tighten its sanctions against Russia. Read more >>
• Australia Says It Will Not Buy Russian Fuel: On October 10, following the U.S.–Russia diesel agreement, Australian Energy Minister Chris Bowen said Australia does not "need or want Russian fuel" and will keep its ban on Russian fuel purchases in place. Bowen said Russia "should not be rewarded for their illegal and immoral invasion of Ukraine". He added that Australia did not want President Putin to benefit from the war in the Middle East. Read more >>
• Japan Expands Russia Sanctions and Export Restrictions: On October 2, Japan imposed asset freezes on 33 entities and nine individuals of the Russian Federation. It also prohibited exports to four specific entities in countries other than Russia and Belarus, and restricted service and capital transactions involving 35 specific vessels. Japan also introduced an additional prohibition on exports to Russia of items that could contribute to the enhancement of Russian industrial capabilities, which took effect on October 16. Read More >>