Russia/Ukraine Sanctions Update - Month of July 2026

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

I. US Sanctions

• U.S. Senators Reach Agreement with Trump Administration on Russia Sanctions Legislation: According to Reuters, on July 10, four U.S. Senators stated that they reached an agreement with the Trump administration to move forward with S. 5025, the Lindsey O. Graham Sanctioning Russia Act of 2026. According to Politico, on July 28, the U.S. Senate then voted to advance the legislation for final passage in the upper chamber. If passed, this legislation would establish a broad range of sanctions targeting Russian officials, military personnel, and entities linked to the Russian government, including blocking assets, prohibiting investments in energy and defense sectors, and banning transactions involving Russian sovereign debt or financial institutions. Read more >>, Read more >>
• OFAC Issues Amended Lukoil-Related General License and FAQs: On July 24, OFAC issued General License 131H, which extends the authorization of certain transactions that are ordinarily incident and necessary to the negotiation of and entry into 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 through 12:01 a.m. eastern daylight time, August 22, 2026, provided that the performance of any such contract is made expressly contingent upon the receipt of separate authorization from the Office of Foreign Assets Control (“OFAC”). OFAC also amended two associated Frequently Asked Questions (“FAQs”). Read more >>
• U.S. Secretary of State Meets with Russian Foreign Minister: On July 23, U.S. Secretary of State, Marco Rubio, met with Russian Foreign Minister, Sergey Lavrov. The parties “discussed the U.S.-Russia relationship and the need to end the Russia-Ukraine war.” Read more >>
• OFAC Issues Amended Russia-Related General License Relating to Directive 4: On July 8, OFAC amended a general license authorizing U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. 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 U.S. persons or entities, through 12:01 a.m. eastern daylight time, October 9, 2026. OFAC also amended two FAQs associated with the license. Read more >>  

II. EU Sanctions

• EU Adopts 21st Package Against Russia and Parallel Sanctions on Belarus: On July 23, the EU adopted its 21st package of sanctions targeting Russia, along with parallel amendments to sanctions against Belarus. This package, designed to ramp up pressure on the finance, energy and military industrial sectors, targets both Russia and those who help Russia evade sanctions. These latest measures target Russia's finance, energy, crypto, and military-industrial sectors through expanded individual designations and tighter trade controls (including freezing the oil price cap and new measures related to liquefied natural gas). The package also closes loopholes in energy and crypto-asset services and reinforces the “carrot-and-stick” approach to discourage third parties from helping Russia evade sanctions. Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>, Read more >>
• EU Imposes Additional Sanctions on Russia Over Cyber-Attacks: On July 13, the EU added nine Russian individuals and four entities to the list of persons subject to asset freeze and/or travel ban measures in connection with cyber-attacks carried out against Member States and EU partners. Read more >>, Read more >>, Read more >>, Read more >>
• EU Imposes Additional Sanctions on Russia Over Human Rights Violations: On July 13, the EU added eight individuals and one entity responsible for serious human rights violations against Ukrainian prisoners of war and civilian detainees to the list of persons subject to asset freeze measures and/or travel ban measures under the EU human rights sanctions regime. Read more >>, Read more >>
• EU Imposes Additional Sanctions on Russia In View of the Situation in Russia: On July 13, the EU added 11 individuals and five entities to the list of persons subject to asset freeze measures and/or travel ban measures under the EU sanctions regime in view of the situation in Russia. Read more >>, Read more >>
• EU Imposes Additional Sanctions on Russia Over Deadly Strikes on Kyiv: On July 17, the EU added one individual and five entities to the list of persons subject to asset freeze measures and/or travel ban measures under the EU sanctions regime in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Read more >>, Read more >>
• EU Reaffirms its Role in Ukraine Peace Process: On July 2, High Representative/Vice-President Kaja Kallas responded to a parliamentary question on the EU's role in international mediation initiatives on the war in Ukraine. The HR/VP stated that the EU supports all genuine diplomatic efforts to end Russia's war of aggression and remains in close coordination with the US, Ukraine and other like-minded partners. The HR/VP confirmed that the EU will maintain pressure on Russia through sanctions and continue supporting Ukraine to create the conditions for meaningful negotiations, while contributing to security guarantees and ensuring accountability for Russia's violations of international law. Read more >>, Read more >>
• Preventing Charter Platforms and Intermediaries from Being Used to Circumvent EU Sanctions: On July 3, the European Commission responded to a question from a Member of the European Parliament regarding allegations that Russian brokers linked to the Russian elite have been using a Swedish digital charter platform to circumvent EU sanctions by restructuring or re-registering operations through countries such as Türkiye, Cyprus and the United Arab Emirates. The Commission confirmed that digital charter platforms and other intermediaries based in Member States must comply with Regulation (EU) No 833/2014 and ensure their services do not enable Russian customers or brokers, directly or indirectly via third countries, to access the European private aviation market. The Commission recalled that those entities are subject to the anti-circumvention provisions and must report any attempt of circumvention to competent authorities. The Commission also referred to its FAQ (Question 21), which clarifies the need for involved entities to undertake appropriate due diligence with their customers. Read more >>, Read more >>
• Circumvention of EU Sanctions in the Aviation Sector: On July 16, the European Commission responded to a parliamentary question concerning reports that entities linked to Russia's aviation sector, including S7 Engineering LLC and S7 Airlines, continued to appear after February 2022 in contracts, invoices, freight records and maintenance records involving intermediaries in the United Arab Emirates, Jordan and Kyrgyzstan. The Commission reaffirmed that Member States are primarily responsible for the implementation and enforcement of EU sanctions, including conducting investigations into possible circumvention cases. The Commission indicated that it continuously monitors developments and engages with Member States and relevant third countries where credible information emerges regarding circumvention activities and will not hesitate to propose additional measures where necessary to safeguard the effectiveness of EU sanctions. Read more >>, Read more >>
• EU Assesses Venice Biennale's Admission of Russian Delegation for Possible Sanctions Breach: The participation of a Russian government-funded delegation at the Venice Biennale is being assessed for a possible breach of EU restrictive measures. The European Education and Culture Executive Agency (EACEA) is reviewing a Creative Europe MEDIA grant awarded to the Foundation and has formally notified it of its intention to suspend or terminate the grant if grounds of grave professional misconduct and serious breach of contractual obligations are established, in particular in relation to potential non-compliance with EU sanctions against Russia and disrespect for EU fundamental values. Read more >>, Read more >>
• EU's Court of Justice Dismisses Action Against EU Sanctions Brought by Three Individuals and One Entity: By its judgments delivered on July 16, the Court of Justice dismissed actions against EU sanctions brought by Elena Petrovna Timchenko, Gennady Nikolayevich Timchenko, Bogoljub Karić and Dana Astra IOOO. Read more >>, Read more >>, Read more >>, Read more >>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Three Individuals: By its judgments delivered on July 8 and 15, the General Court dismissed actions against EU sanctions brought by Oleg Vladimirovich Deripaska, Dimitry Aleksandrovich Beloglazov and OT. Read more >>, Read more >>, Read more >>
• EU Court of Justice Interprets the Scope of the Broadcast Prohibition Targeting Russia Today: By its judgment delivered on July 2, the Court of Justice answered the preliminary ruling question referred by a German court by holding that the prohibition on broadcasting content from the channel RT - Russia Today under Council Regulation No 833/2014 applies also to a website accessible to the public free of charge. The Court ruled that the concept of "operator" covers any person responsible, directly or indirectly, for making the prohibited content available, including in the context of a non-remunerated activity or in the operation of a website financed by voluntary contributions from third parties. The Court further clarified that that classification depends neither on the extent nor on the duration of the broadcasting. Read more >>
• Advocate General’s Opinion on Appeal by German Khan Against EU Sanctions: On July 2, AG Biondi recommended dismissal of Mr. Khan's appeal against the General Court's judgment upholding his asset freeze under the EU's Russia sanctions regime. Mr. Khan, a Russian businessman and former major shareholder of ABH Holdings, the parent company of Alfa Bank, was listed under "criterion (g)." In its initial form, this criterion targeted influential businesspersons active in economic sectors providing substantial revenue to the Russian government. Following its June 2023 amendment, criterion (g) was split into three distinct limbs: (i) influential businesspersons active in Russia, (ii) their close family members, and (iii) businesspersons active in sectors providing substantial revenue to the Russian government. On the meaning of "influential," the AG concluded that the term carries the same meaning under both the initial and the amended version of criterion (g): it refers to a person's economic importance in their sector of activity, assessed by reference to factors such as professional status, scale of investments, or corporate functions. Under the amended first limb, this no longer requires that the person's sector provide substantial revenue to the Russian government, nor that the person have a personal link to that government. Turning to the legal basis of criterion (g), the AG found that the General Court committed an error of law by failing to verify that an objective link exists between the targeted persons and Russia, as required by Article 215(2) TFEU. Nevertheless, the AG concluded that this error does not warrant annulment of the initial judgment since it follows from settled case-law that, where the grounds of a decision of the General Court disclose an infringement of EU law, but the operative part of that decision appears well founded on other legal grounds, such an infringement is not such as to lead to the annulment of that decision, and a substitution of grounds must be carried out. Read More >>
• Finnish Businessman Sentenced to Prison for Circumventing EU Sanctions Against Russia: The South Karelia District Court in Finland sentenced the owner of Idän Liikenteenvälitys IL Oy to 3 years and 8 months in prison for violation of the EU sanctions. The court also ordered the forfeiture of approximately €600,000 in illegal profits and confiscation of assets worth €6 million. The court found that in 2022–2023, the company exported 164 trucks and trailers to Russia using a circumvention scheme in which companies in Turkey and Kazakhstan were listed as buyers, while the vehicles were ultimately delivered to Russia. Read More >>
• Germany Strengthens EU Sanctions Enforcement Through Coordinated Authorities: Germany has established a comprehensive legal and institutional framework for enforcing EU sanctions, built primarily on the Foreign Trade and Payments Act (AWG), the Foreign Trade and Payments Ordinance (AWV) and the Sanctions Enforcement Act (SanktDG). Recent enforcement cases include a seven-year prison sentence for exporting electronic components used in Russian military drones (Higher Regional Court of Stuttgart), a five-year sentence and €5.5 million confiscation for smuggling luxury vehicles to Russia via sham Belarusian purchasers (Regional Court of Marburg), and concerted dawn raids against pharmaceutical companies in Q1 2026. Read More >>
• EU Purchases Record Amount of LNG from Russia's Yamal Facility Ahead of Import Ban: According to the media reports, EU purchases from Yamal LNG, controlled by Russia's Novatek, reached a record 9.89 million tonnes in H1 2026, 18% more than in the same period last year, with France, Belgium and Spain as the main buyers. Europe may have paid as much as €6 billion for these shipments. From January 1, 2027, an EU ban on long-term Russian LNG imports comes into effect, forcing Russia to seek alternative routes. Asia-bound volumes from Yamal fell 74% in the same period, partly due to shipping and insurance concerns over EU sanctions exposure. Read More >> 

III. UK Sanctions

• HMRC names subject of compound penalty for the first time: On June 29, HM Revenue & Customs announced that Petrofac Facilities Management Limited ("PFML") had paid a compound settlement of £569,157.07 for offences under the Russia (Sanctions) (EU Exit) Regulations 2019. This is the first time that a party paying a compound penalty for sanctions or export control violations has been named by HMRC. (Notice to exporters 2026/15) Please see our alert on this here: HMRC Names Subject of Compound Penalty for the First Time | Insights | Mayer Brown
• NCA brings civil forfeiture application against UK-sanctioned Sergei Tregub: The UK's National Crime Agency ("NCA") has brought a civil forfeiture application to permanently confiscate funds worth $357,000 from UK-sanctioned individual Sergei Sergeevich Tregub. Mr Tregub was sanctioned in 2023 for being "associated with" his father, Sergei Vadimovich Tregub, under the Russia (Sanctions) (EU Exit) Regulations 2019, who was in turn sanctioned for being associated with Alexei Miller and carrying on business in the Russian construction sector. Read More >>
• UK delists oil tanker 'Zangazur' from Russia shadow fleet sanctions list: On July 7, the UK delisted the oil tanker 'Zangazur' (IMO 9420617) from the UK Sanctions List. Read More >>
• R v Hauser & Wirth Gallery Ltd – UK Court provides guidance on "making available" and "ordinarily resident": In R v Hauser & Wirth Gallery Ltd & Anor [2026] EWCR 7, the Crown Court dismissed charges brought under the regulation 46B(2) Russia (Sanctions) (EU Exit) Regulations 2019 (the "Regulations") against an art gallery, Hauser & Wirth Gallery Ltd ("H&W"), and a fine art logistics company, Artay Rauchwerger Solomons Ltd (“ARS”), for the sale of artwork (a luxury good for the purposes of the Regulations) to Alexander Popov ("Mr Popov"). The Court considered whether the artwork had been “made available” to Popov and whether he was a “person connected with Russia” and in particular whether he was “ordinarily resident” in Russia. The Court held that the artwork was “made available” because of the combination of transfer of legal title to Popov, payment by Popov and release into the control of parties acting on Popov’s instructions. Notably the Court also held that mere entitlement or transfer of legal title was not sufficient for "making available". The Court held that “ordinary residence” is a question of fact and degree and “requires evidence that Russia remained part of the settled and regular order of the person’s life at the material time”. On the facts of the case, the Court held that Popov was not ordinarily resident in Russia at the relevant time. Read More >>
• UK and EU impose joint cyber sanctions package on Russia: On July 13, the UK and the EU imposed a joint cyber sanctions package on Russia. 24 individuals and entities were added to the UK Sanctions Lists. Read More >>, Read More >>, Read More >>
• OFSI amends arbitration costs General Licence INT/2025/5787748: On July 16, OFSI amended the reporting requirements under General Licence INT/2025/5787748 which permits payments to arbitration associations and arbitrators to cover fees and expenses that would otherwise be prohibited under the UK’s Russia and Belarus sanctions regulations. Read More >>
• OFSI extends General Licence INT/2025/6641960: On July 13, OFSI extended until 16 July 2027 General Licence INT/2025/6641960 under the Russia and Belarus Regulations which allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker. Read More >>
• OFSI amends and extends General Licence INT/2026/8893924: On July 6, OFSI extended until 7 October 2026 General Licence INT/2026/8893924 which allows for the winding down of insurance policies written by Maritime Mutual entities and their subsidiaries before their designation. OFSI also introduced a reporting requirement Read More >> 

IV. Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In July 2026, Ukraine extended the sanctions to 38 legal entities and 57 individuals. The sanctions cover Russian companies and individuals supplying components for the military and missile industry. The full list of the sanctioned persons is available at the website of the State Sanctions Register of Ukraine. Read More >>, Read More >>
• Ukraine to Auction a Titanium Mining Plant Confiscated from a Russian Billionaire: Cabinet of Ministers of Ukraine approved a starting auction price of UAH 1.82 billion for the sale of the Demurinsky Mining and Processing Plant, one of the country's largest titanium ore producers, which was confiscated from Russian billionaire Mikhail Shelkov in 2023. The plant had been controlled by Shelkov through Russia's VSMPO-Avisma, and although ownership was formally transferred just before Russia's full-scale invasion, Ukrainian authorities concluded that he retained effective control. Read More >>
• Ukraine's Supreme Court Upholds Zelensky's Sanctions against Former Ukrainian President Poroshenko: Ukraine's Supreme Court rejected former President Petro Poroshenko's appeal against sanctions imposed by President Volodymyr Zelensky, leaving in place restrictions that Poroshenko argues are politically motivated and unlawful. The ruling comes amid growing controversy over the government's use of sanctions against Ukrainian citizens. Read More >>
• Russia Bans Estonian Trucking Companies from Transporting Goods across its Territory: Russia's government has prohibited freight transport within its territory by trucks owned by Estonian carriers, extending its retaliatory transport restrictions against countries that have imposed road freight measures on Russian operators. The ban amends the Decree of the Russian Government No. 1728 adopted in 2022 concerning reciprocal restrictions and removes previous exemptions that had allowed certain categories of goods to be transported. Read More >>
• Moscow Court Orders Euroclear Bank to Pay USD 194 Million over Blocked Russian Securities: A Moscow arbitration court partially upheld a claim by Russian investment company Silicium-2, ordering Belgium's Euroclear Bank to pay more than $194 million in damages related to securities blocked under international sanctions. The claimant had originally sought over $2.2 billion in compensation, arguing that Euroclear's freezing of its assets caused substantial losses, but the court awarded an amount close to Euroclear's own calculation. The ruling is the latest in a series of Russian lawsuits against Euroclear over frozen assets, following a separate judgment ordering the depository to pay the Bank of Russia approximately 18.2 trillion roubles in damages. Read More >>  
• European Banks Sue Linde over Losses from Russia Sanctions: Deutsche Bank, UniCredit, and Commerzbank have filed lawsuits against industrial gases company Linde, seeking nearly EUR 1 billion in compensation for assets frozen in Russia after the company halted its Russian projects in response to EU sanctions. The dispute stems from Linde's withdrawal from a major gas processing plant project in Ust-Luga, after which Russian courts enforced bank guarantees and seized the lenders' assets. The cases, now before German courts, could set an important precedent on whether companies or their financing banks should bear the financial consequences of sanctions-related contract disruptions. Read more >>

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