Russia/Ukraine Sanctions Update - Month of March 2026

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

I. U.S. Sanctions 

• Russian Lawmakers Make First U.S. Visit Since 2022 Invasion of Ukraine: According to Reuters, on March 26, a delegation of Russian lawmakers arrived in the U.S. for meetings with U.S. lawmakers. The delegation is reported to include Vyacheslav Nikonov, a lawmaker who is the grandson of Joseph Stalin's foreign minister, Vyacheslav Molotov, according to Russian media reports. On March 27, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) removed the designations of individuals with apparent close ties to the Russian government. Read more >>
• U.S. Announces $25 Million Effort to Return and Rehabilitate Forcibly Relocated Ukrainian Children: On March 26, the U.S. Department of State announced “$25 million in new assistance to support the identification, return, and rehabilitation of Ukrainian children and youth who have been forcibly transferred or otherwise held away from their families and communities.” Read more >>
• Russia States it Remains in Contact with U.S. on Ukraine Settlement: According to Reuters, on March 25, Kremlin spokesman, Dmitry Peskov, stated that Russia remains in contact with the U.S. regarding a possible settlement of the conflict in Ukraine and "welcome[s] the continued efforts by the American side to create the necessary conditions for reaching a settlement in the Ukrainian issue." Read more >>
• OFAC Issues New and Amended Russia-Related General Licenses Regarding the Sale of Russian Oil: On March 5, OFAC amended a general license authorizing certain transactions ordinarily incident and necessary to the sale, delivery, or offloading of deliveries and sales of crude oil and petroleum products of Russian Federation origin loaded on vessels on or before 12:01 a.m. Eastern Standard Time, March 5, 2026, through 12:01 a.m. Eastern Daylight Time, April 4, 2026, to India. On March 12, OFAC issued a new 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 on or before 12:01 a.m. Eastern Daylight Time, March 12, 2026, through 12:01 a.m. Eastern Daylight Time, April 11, 2026. On March 19, OFAC replaced and superseded this license with an amended version that added an exclusion for transactions involving persons located in or organized under the laws of Iran, North Korea, Cuba, the Covered Regions of Ukraine (as defined by Executive Order 14065), or the Crimea Region of Ukraine (as defined by Executive Order 13685), as well as any entity owned or controlled by, or in a joint venture with, such persons. Read more >> and Read more >>
• OFAC Issues Amended Russia-Related General License for Two Petroleum Processing Companies: On March 5, OFAC amended a general license authorizing certain transactions involving Rosneft Deutschland GmbH and RN Refining & Marketing GmbH. Read more >> 

II. EU Sanctions

• EU Imposes New Sanctions on Russian Individuals Responsible for Hybrid Attacks: On March 16, the Council added four individuals responsible for Russia’s continued hybrid activities against the EU and its Member States to the list of natural and legal persons subject to asset freeze and/or travel ban measures. Read more >> and Read more >>
• EU Imposes New Sanctions on Russian Individuals Responsible for Bucha Massacre: On March 16, the Council added nine individuals who played a major role in the Bucha massacre to the list of natural and legal persons subject to asset freeze and/or travel ban measures. Read more >> and Read more >>
• EU Extends Sanctions over Ukraine's Territorial Integrity: On March 14, the EU extended sanctions targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for another six months, until September 15, 2026. In the context of the sanctions' review, the EU also decided to update information concerning 132 individuals and 77 entities, to remove five deceased persons and to delete two others from the list. Read more >> and Read more >>
• EU Extends Sanctions in View of the Situation in Ukraine: On February 26, the EU extended sanctions directed against certain persons, entities and bodies in view of the situation in Ukraine for another year, until March 6, 2027, and updated information regarding the rights of defence and the right to effective judicial protection. Read more >> and Read more >>
• EU Commission Issues Guidance on Sanctions Against Russia and Belarus: On March 13, the European Commission issued a new guidance on theprovision of payments services, such as crypto-asset services and certain payment and e-money services, to Russian nationals, natural persons residing in Russia and legal persons, entities or bodies established in Russia. Read more >>
• France advances first steps to transpose the EU Sanctions Enforcement Directive: On March 3, a draft bill was submitted to the French National Assembly to create a dedicated section within the French Customs Code specifically addressing offences relating to EU sanctions as a first formal step toward implementing Directive (EU) 2024/1226, which requires all EU Member States to criminalise the violation and circumvention of EU restrictive measures. Read more >>
• EU-based Banks Operations in Russia: Although the EU has adopted sanctions against Russia, several EU-based banks, notably Raiffeisen Bank International and UniCredit, continue to maintain substantial operations in Russia. The European Commission informed that in close coordination with the European Central Bank and the European Banking Authority, it is monitoring the de-risking strategies of these banks. In addition, the European Commission recalled that in order to preserve the integrity of the EU financial system, Russia has recently been added to the EU’s high-risk third-country list for anti-money laundering purposes. Read more >> and Read more >>
• Designation of Rosatom under EU Sanctions: When questioned on when will the EU adopt measures to prohibit commercial operations by designated Rosatom entities within the EU, the European Commission indicated that in the nuclear sector, the EU has put in place comprehensive export control restrictions limiting Russia’s access to nuclear-related goods and technology. In addition, the EU has imposed targeted export restrictions against Rosatomflot (a Rosatom subsidiary) due to its involvement in the Russian military-industrial complex, prohibiting the export of dual-use or sensitive goods to the company. Additionally, Rosatomflot is subject to fully fledged restrictive measures (asset freeze and a prohibition on providing economic resources to it) for providing a substantial source of revenue to the government of the Russian Federation. Read more >> and Read more >>
• Use of Frozen Russian Assets: When questioned on the use of frozen Russian assets, the European Commission recalled that in December 2025 it proposed a "Reparations Loan" to Ukraine, funded by borrowing cash balances that accumulate due to restrictions on transactions involving the Central Bank of Russia's assets, with these balances not being the property of Russia or protected by sovereign immunity. The European Commission also emphasised that the Council and European Parliament were tasked with continuing work on the technical and legal aspects of the loan instruments, while the Commission committed to exploring measures to protect EU citizens and companies against potential Russian retaliation. Read more >> and Read more >>
• EU Court of Justice Judgment on Freezing of the Funds of a Non-listed Company: By its judgment delivered on March 12, the Court of Justice ruled that the assets of a company not included on the list of persons subject to sanctions may be frozen if it is controlled by a person included on that list. First, the Court held that the freezing of funds pursuant to EU sanctions against Belarus also covers the funds and economic resources of a company not included on the list, provided that those funds and economic resources are owned, held or controlled by a person, entity or body which is included on that list. According to the Court, such an interpretation is necessary to achieve the objective pursued by the EU sanctions. Second, the Court stated that it is for the Member States to establish a procedure enabling not only the legal persons, entities and bodies not included on the list whose funds or economic resources have been frozen, on the ground that those funds or economic resources were presumed to be held or controlled by a person included on the list, but also that latter person, to challenge that freezing measure and, where appropriate, to have it lifted. Such a presumption must be rebuttable. Read more >>
• EU Court of Justice Judgment on Exercise by a Sanctioned Person of the Shareholder Rights: By its judgment delivered on March 12, the Court of Justice ruled that the freezing of funds prevents, absolutely and unconditionally, a holder of depositary receipts, or a person or entity associated with him, her or it, from attending a general meeting of shareholders and from voting in that meeting. Read more >>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Five Individuals: By its judgments delivered on March 26, the General Court dismissed action against EU sanctions brought by Mr. Dmitry Alexandrovich Pumpyanskiy, Mr. Tigran Khudaverdyan, Mr. Viktor Filippovich Rashnikov, Mr. Dmitry Arkadievich Mazepin and Mr. German Khan. Read more >>
• Kyrgyzstan Prepares to Take EU to Court Over Russia Sanctions: Kyrgyzstan has threatened to take legal action against the EU if the bloc imposes sanctions over allegations that Kyrgyz companies are re-exporting militarily useful goods to Russia. The European Commission has proposed banning the sale of certain dual-use goods to Kyrgyzstan, marking a significant test of Brussels' ability to enforce its sanctions regime. 

III. UK Sanctions

• UK Government updates its guidance on the Russia sanctions regulations: On March 25, the statutory guidance on the Russia sanctions regulations was updated to include a summary of the regulations’ purpose, scope and prohibitions. The transport sanctions section was also updated for better clarity and usability. Read more >>
• OFSI issues General Licence for activity in relation to the supply, purchase, transportation or delivery of Kazakh oil: On March 18, OFSI issued General Licence INT/2026/9247168 which authorises PJSC Transneft and its subsidiary to conduct activities in connection with the supply, purchase, transportation or delivery of Kazakh oil, provided that the Kazakh oil is not owned by a person connected with Russia, and that the Kazakh oil is only being loaded in, departing from, or transiting through Russia, subject to certain terms and conditions. This General Licence expires on 18 March 2028. Read more >>
• FCDO varies UK Sanctions List entries under the Russia sanctions regulations: On March 17, the Foreign, Commonwealth and Development Office (“FCDO”) varied the entry for Viatcheslav Kantor, to reflect his activities in the Russian chemicals and extractive sectors and his position as Chairman of the Coordinating Board of PJSC Acron. It also corrected the entries for JSC BBR Bank, Transcapitalbank, JSCB FORA-BANK, Nikolay Dmitrievich Peskov and removed the entry for German Belous under the Russia (Sanctions) (EU Exit) Regulations 2019. Read more >> and Read more >>
• OTSI updates its guidance for businesses on countering Russian sanctions evasion: On March 17, the Office of Trade Sanctions Implementation (“OTSI”) updated its guidance, reminding businesses that they are responsible for assessing their sanctions risk exposure and implementing appropriate safeguards. The updated guidance expands the list of goods considered at higher risk of circumvention to include crushing or grinding machines for mineral substances, enamels and lacquers, and certain heterocyclic compounds. The updated guidance also adds Israel to the list of third countries warranting enhanced due diligence to prevent re-export of at-risk products to Russia. Read more >>
• FCDO amends one entry on the UK sanctions list under the Russia sanctions regulations: On March 12, the FCDO amended the listing for Gulbakhor Ismailova under the Russia sanctions regime.  The variation adds that there are reasonable grounds to suspect Gulbakhor Ismailova is the sister of Alisher USMANOV, who is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 and was designated by the UK on 3 March 2022. Read more >> and Read more >>
• OTSI updates guidance on countering Russian sanctions evasion: On March 12, OTSI updated its guidance which is intended to support UK businesses in understanding Russian circumvention practices and in reducing the risk of their business being targeted by those seeking to evade sanctions. This guidance provides information regarding goods at greater risk of being diverted to Russia, red flag indicators of sanctions evasion, and suggestions for enhanced due diligence. Read more >>
• FCDO removes one entry from the UK sanctions list under the Russia sanctions regulations: On March 2, FCDO removed John Ormerod from the UK sanctions list under the Russia regime. According to the UK Government, Ormerod was suspected of being involved in obtaining a benefit from or supporting the Government of Russia by owning or controlling directly or indirectly, or working as a director (whether executive or nonexecutive) of, a person, other than an individual, carrying on business in a sector of strategic significance to the Government of Russia. Read more >>
• House of Commons Library publishes overview of 2025 Russia sanctions: On February 27, the House of Commons Library published a research briefing providing an overview of UK, US and EU sanctions imposed on Russia since January 2025. In 2025, the UK, EU and US maintained their sanctions regimes established in response to the invasion of Ukraine. Read more >>

IV. Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In March 2026, the President of Ukraine adopted 4 Orders extending the sanctions to 59 legal entities and 181 individuals. The new sanctions were imposed by the Orders No. 231/2026 and 232/2026 dated 10 March 2026, No. 243/2026 and 244/2026 dated 14 March 2026. The full list of the sanctioned persons is available at the website of the State Sanctions Register of Ukraine. Read more >>
• Russia’s Central Bank Sues EU for Freezing its Assets: The Central Bank of Russia has filed a lawsuit against the European Union before the European Court of Justice over the indefinite freezing of its sovereign assets. The Russian Central Bank argues that the EU violated legal procedures and principles of state immunity. The case challenges emergency measures used by EU leaders to retain control over roughly €210 billion in Russian funds, which are used as a collateral against the financial loan issued to for Ukraine. Brussels has dismissed the claims, expressing confidence in the legality of its actions as legal disputes over sanctions continue to escalate. Read more >>
• Kyrgyzstan Prepares to Take EU to Court over Russia Sanctions: Kyrgyzstan has warned it will challenge the European Union in court if Brussels imposes sanctions over alleged re-exports of dual-use goods to Russia. Deputy Prime Minister Daniyar Amangeldiev said the country is complying with restrictions but lacks clear guidance from the EU on how to avoid penalties. The dispute could become a major test of the bloc’s ability to enforce sanctions and prevent circumvention through third countries.
• The US Has Authorized the Sale of Russian Oil Loaded onto Tankers: The United States has issued a temporary waiver allowing the sale of Russian oil already loaded onto tankers by March 12, with the measure valid until April 11 as part of efforts to stabilize global energy markets. US Treasury Secretary Scott Bessent emphasized the move is limited to oil in transit and is unlikely to significantly boost Russian revenues. The decision comes amid Middle East supply disruptions. Read more >>
• India Buys 60 Million Barrels of Russian Oil Following Suspension of Sanctions: India has secured roughly 60 million barrels of Russian oil scheduled for delivery next month, as refiners rush to lock in supplies amid disruptions caused by the near shutdown of the Strait of Hormuz. With shipments through the strait still limited, global supply chains are tightening, increasing concerns for import-reliant countries such as India. The cargoes were purchased at premiums ranging from $5 to $15 per barrel above Brent crude. These acquisitions were made possible by a US waiver permitting India to receive Russian crude shipments. Read more >>
• UK Businessman of Russian Origin Evgeny Shvidler Files a Lawsuit with the European Court of Human Rights over UK sanctions: Businessman Evgeny Shvidler has filed a landmark case with the European Court of Human Rights challenging UK sanctions imposed over his alleged ties to Roman Abramovich. The case, the first of its kind linked to Russia-related restrictions, could set a major legal precedent and potentially open the door for others to contest sanctions if the court rules in his favor. Despite losing previous appeals in UK courts, Shvidler argues the measures are unjustified, raising broader questions about how sanctions lists were compiled and enforced.
• Russian Court Declines the Right of Individual Investors to Join the Suit of the Russian Central Bank against Euroclear: A Russian appeals court has upheld a decision blocking private investors from joining the Central Bank of Russia’s multitrillion-rouble lawsuit against Euroclear. The case centers on frozen assets following 2022 sanctions, with investors arguing their holdings were not clearly separated from state funds, but both the regulator and Euroclear opposed their involvement. The ruling keeps the dispute limited to state interests, as Russia continues legal efforts to recover assets frozen in European financial institutions.

V. Other Notable Developments

• Canada Announces Additional Sanctions Against Russia: On March 26, Canada announced the addition of 100 more vessels from Russia’s shadow fleet to its sanctions list “to counter Russia’s sanctions evasion.” Read more >>
• Japan Contemplates Buying Russian Oil Following U.S. Sanctions Waiver: According to Reuters, on March 13, an industry ministry official stated that “Japan will consider whether to buy Russian crude after the U.S. issued a 30-day sanctions waiver amid the Iran war by taking into account international conditions and its national interests.” Read more >>