Russia/Ukraine Sanctions Update - Month of November 2025

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

I. U.S. Sanctions 

• U.S. Department of the Treasury Imposes $4.7 Million Penalty on Real Estate Investor for Dealing in Russian Blocked Property: On November 24, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $4,677,552 civil penalty against a U.S. individual who, acting through an Atlanta-based real estate investment company, willfully mortgaged, renovated, and sold a blocked residential property owned by a Russia‑sanctioned person. Treasury emphasized that this action—the largest to date against an individual—underscores that all U.S. persons, including individual investors and real estate professionals, must comply with OFAC’s sanctions regulations and orders. Additional information on this action is available here. Read more>>
• United States, Australia, and United Kingdom Sanction Russian Cybercrime Infrastructure Supporting Ransomware: On November 19, OFAC, in coordination with Australia and the United Kingdom, designated Media Land, “a Russia‑based bulletproof hosting (BPH) provider for its role in supporting ransomware operations and other forms of cybercrime.” OFAC also designated three members of Media Land’s leadership and three sister companies (including ML Cloud), as well as Hypercore Ltd., an alleged front company of Aeza Group LLC, a BPH service provider designated by OFAC earlier this year. Under Secretary of the Treasury for Terrorism and Financial Intelligence, John K. Hurley, emphasized that this coordinated action demonstrates a “collective commitment to combatting cybercrime and protecting our citizens.” Read more>>
• Ukraine Indicates Readiness to Advance Peace Plan with U.S. Involvement: According to Reuters, on November 25, Ukrainian President, Volodymyr Zelenskiy, indicated he was ready to advance a U.S.-backed framework for ending the war with Russia. According to CBS, on November 26, Russian Presidential Press Secretary, Dmitry Peskov, stated it is “premature” to say whether the situation in Ukraine was close to a resolution. Read more>> and Read more>>
• U.S. House Pushes to Force Russia Sanctions Vote: According to Politico, a bipartisan coalition of pro Ukraine lawmakers is seeking to force a House vote on legislation that would sanction countries doing business with Russia, if Russia refuses to negotiate a peace deal with Ukraine. The vote is expected when the House returns from Thanksgiving recess. President Donald Trump has previously indicated he would sign the measure, “as long as he retains ultimate decision-making authority over any such measures.” Read more>> and Read more>>
• OFAC Issues New and Amended Russia-Related General Licenses: On November 14 and 21, OFAC issued several general licenses authorizing limited transactions relating to the Caspian Pipeline Consortium/Tengizchevroil/Karachaganak Projects, Lukoil retail stations outside Russia, certain Lukoil entities in Bulgaria, divestment arrangements (short of sale), maintenance, and wind down of Lukoil International GmbH and its assets and subsidiaries, and transactions involving Paks II Civil Nuclear Power Plant. Read more>> and Read more>>

II. EU Sanctions

• EU Imposes New Sanctions on Russian Individuals: On November 20, the Council added ten individuals responsible for serious violations or abuses of human rights and the repression of civil society and democratic opposition in Russia to the list of natural and legal persons subject to asset freeze and/or travel ban measures. Read more>> and Read more>>
• EU Commission Updates its Guidance on Sanctions Against Russia and Belarus: On November 21, the European Commission issued updated guidance on (i) the import ban on liquefied natural gas, (ii) the infrastructure transaction ban, and (iii) the prohibition on engaging with certain state-owned enterprises. Read more>>, Read more>> and Read more>>
• EU Commission Comments on Activities of Danish Companies Indirectly Supporting Russia’s War Efforts: Members of the European Parliament brought to the European Commission’s attention the fact that a Danish company is still importing large quantities of Russian crude steel, in spite of the EU’s sanctions against Russia, while another Danish company is still servicing Russian vessels that are transporting natural gas (LNG) to Europe under other nations’ flags. In response, the European Commission emphasized that all EU steel imports from Russia are under sanctions, with two specific types of semi-finished products being subject to a gradually declining quantitative limit (quota) until September 2028. On the other hand, the European Commission explained that EU sanctions do not currently prohibit servicing tankers transporting natural gas of Russian origin unless they are designated by the EU and that the EU has designated 557 vessels, including 15 LNG tankers. Read more>> and Read more>>
• EU Commission Comments on Sanctions Against EU Actors Knowingly Enabling Russia’s War Machine: Members of the European Parliament also questioned the European Commission about the role of EU-based shipping companies – primarily Greek – in the continued sale of vessels to actors linked to Russia’s shadow fleet, which is transporting Russian oil. Reports indicate that Okeanis Eco Tankers, listed on the New York Stock Exchange, and Kyklades Maritime Corporation, both owned by the Alafouzos family, have continued shipping Russian oil. While the EU’s 15th-18th sanctions packages have expanded vessel listing, no individual EU ship-owners have faced personal sanctions. The European Commission’s response explained that the EU has strengthened its restrictive measures related to Russia by adding the possibility to impose asset freezes, prohibitions on making funds available and, as appropriate, travel bans on individuals and entities supporting the Russian shadow fleet. The Commission added that several designations have been adopted since then, covering in particular oil traders, shipping and managing companies in Russia and third countries, supportive flag registries as well as a captain of a shadow fleet vessel. The European Commission and the European External Action Service remain committed to increasing the pressure on shadow fleet networks and will work closely with Member States to develop further measures. Read more>> and Read more>>
• EU Commission Comments on Actions of the Commission Concerning the Russian Shadow Fleet: The European Commission commented on the significant ecological, financial, and political risks posed by the Russian shadow fleet. The Commission indicated that the EU has imposed full-fledged sanctions on several actors supporting the Russian shadow fleet, including supportive or false flag registries that allow the continued operation of shadow fleet tankers by creating a fraudulent impression of compliance with certification requirements. The EU is said to be fully engaged in discussions in relevant formats with like-minded partners, including the G7 - Nordic-Baltic 8 ++ Shadow Fleet Task Force, to further facilitate the preparation of additional measures. The EU also continues to conduct outreach to flag states to ensure that ship registers do not allow shadow fleet tankers to sail under their flag. Read more>> and Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Mr. Bazhaev: By its judgment delivered on November 26, the General Court dismissed the actions brought by Musa Yusopovich Bazhaev challenging his listing. Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by SBK Art: By its judgment delivered on November 26, the General Court dismissed the actions brought by the company SBK Art OOO challenging its listing. Read more>>
• OLAF and Europol Join Forces to Strengthen the Fight Against Sanctions Circumvention: The European Anti-Fraud Office (OLAF) and Europol have intensified their cooperation to address the growing threat of sanctions circumvention linked to Russia and Belarus. To this end, the two organizations held a dedicated meeting on November 17- 18, marking a step toward examining new trends and strengthening coordinated action. Read more>>
• EU Calls on Greece to Take Action Against Russia’s ‘Shadow Fleet’: The EU’s High Representative for Foreign Affairs and Security Policy, Kaja Kallas, is increasing pressure on Greece and has called on government to step up its efforts to curb the activities of the “shadow fleet” used by Russia to export oil, circumventing European sanctions. Read more>>
• Bulgarian President Vetoes Law Regulating Sale of Lukoil Assets: On November 12, Bulgarian President Rumen Radev vetoed legal changes that would allow the government to seize control of Lukoil's Burgas oil refinery and sell it to protect the plant from the impact of U.S. sanctions. Radev returned the legislation to parliament for further discussion, saying the changes failed to provide protection against future financial claims against the state, violated Bulgaria's constitution and posed a risk to public finances. Read more>>

III. UK Sanctions

• OFSI amends General Licence relating to the Continuation of Business of Lukoil Bulgaria Entities: On November 20, OFSI amended General Licence INT/2025/7895596, which authorises UK persons to continue business operations with certain Bulgarian subsidiaries of PJSC Lukoil. In particular, the general licence was extended to cover dealings with Lukoil Aviation Bulgaria EOOD and Lukoil Bunker Bulgaria EOOD. The general licence expires on February 14, 2026. Read more>>
• OFSI amends FAQ regarding the continuation of business operations with Lukoil Bulgaria entities: On November 20, OFSI amended FAQ 173, noting that General Licence INT/2025/7895596 permits the continuation of business with respect to Lukoil Aviation EOOD and Lukoil Bunker Bulgaria EOOD, in addition to the Lukoil Bulgaria entities that were included within the scope of that general licence on November 14, 2025. Read more>>
• UK Government adds one entry on the UK Sanctions list under the Russia regime: On November 19, the UK Government added Aeza Group LLC to the UK sanctions list under the Russia regime. According to the UK Government, this entity has provided ‘bulletproof’ hosting services to support the work of the Social Design Agency, a Russian disinformation agency sanctioned by the UK in 2024 for its attempts to destabilise Ukraine and undermine democracies around the world. Read more>> and Read more>>
• OFSI updates financial sanctions guidance where licence applications involve Russia divest investors: On November 18, OFSI updated its general financial guidance to explain when OFSI can grant a divestment licence where a Russian divest investor is involved. In particular, a UK entity applicant can acquire an interest held in a UK entity held by a designated person or the Russian Government if the whole consideration for the acquisition is a transfer of funds to the designated person or the Russian Government and subject to certain other terms and conditions. Read more>>
• OFSI issues General Licence permitting continuation of business with Lukoil Bulgaria entities and publishes related FAQ: On November 14, OFSI issued General Licence INT/2025/7895596, which authorises UK persons to continue business operations and process payments involving Lukoil Bulgaria EOOD, Lukoil Neftochim Burgas AD and their subsidiaries, under the Russia sanctions regime. The general licence expires on February, 14 2026. OFSI also issued FAQ 173 in which OFSI acknowledges the work in Bulgaria to determine the future status of Lukoil Bulgaria’s operations and notes that this general licence is valid for three months, but subject to potential renewal based on the aforementioned factual situation. Read more>> and Read more>>
• OFCOM confirms that it has not used its powers to request information under the Russia regime to date: On November 10, in response to a freedom of information request, OFCOM, the UK’s regulator for communications services, confirmed that it has not to date used its powers to request information under Regulation 77A of the Russia (Sanctions) (EU Exit) Regulations 2019, and that it has not issued any monetary penalties in relation to the provision of internet services to or for the benefit of designated persons. Read more>>
• OFSI amends General Licence relating to payments made between third parties and sanctioned financial institutions in 2022: On November 5, OFSI amended General Licence INT/2024/5394840, which authorises the processing of certain payments made in 2022 that have been processed by a sanctioned credit or financial institution at some point in the chain of payments. Among other things, the General Licence was extended to November 7, 2027, and its reporting conditions were updated. Read more>>
• OTSI publishes guidance for the freight and shipping sector on countering sanctions evasion: On November 3, the Office of Trade Sanctions Implementation (“OTSI”) published new guidance on countering Russian sanctions evasion targeted at businesses operating in the freight and shipping sectors.  The guidance contains: (i) information on the range of goods at heightened risk of being diverted to Russia; (ii) suggestions for compliance best practice and enhanced due diligence procedures; (iii) red flag indicators of potential sanctions evasion via circumvention; and (iv) additional resources to aid businesses in managing their risk and meeting their compliance obligations. Read more>>
• HMRC publishes case study on £1.1 million compound settlement for breach of Russia sanctions: On November 3, HM Revenue and Customs published a case study under which a UK exporter paid a £1.1 million compound settlement for making goods available to Russia in breach of UK sanctions.  The case study highlighted the risks of exporting to third countries and of being informed of trade sanctions.  The case study also provided guidance on the meaning of ‘connected with Russia’ and the scope of the ‘making available’ prohibitions under the UK Russia regulations. Read more>>

IV. Russia/Ukraine Sanctions

• Ukraine imposes sanctions on 56 vessels that illegally entered Ukrainian ports: On November 25, President Volodymyr Zelenskyy signed a decree which imposes sanctions on 56 maritime vessels that, between 2022 and 2025, illegally entered Ukrainian ports temporarily occupied by Russia and exported Ukrainian food products. Many of the vessels were already under sanctions imposed by other countries, including the European Union, the United States, and Switzerland. The individuals who carried out these logistics operations, which are prohibited by Ukraine, profited financially and paid taxes into the Russian state budget – enabling Russia to finance its war machine. Read more>>
• Ukraine prepares proposals for the 20th sanctions package against Russia: On November 9, President Volodymyr Zelenskyy affirmed that Ukraine, together with its partners in the European Union, is preparing proposals for the 20th package of sanctions against Russia, which is expected to include Russian legal entities and individuals that are still profiting from energy resources, and impose sanctions on companies from countries purchasing Russian oil, the infrastructure of the shadow fleet; the Russian military-industrial complex; entities involved in gas extraction in the Arctic; Russian oligarchs; and companies attempting to circumvent restrictions. Read more>>
• Ukraine imposes sanctions on senior officials of the Aggressor State and Russian publishing houses: On November 9, President Volodymyr Zelenskyy signed two decrees enacting decisions of the National Security and Defense Council of Ukraine on the application of personal special economic and other restrictive measures. The first decree imposes sanctions on eight Russian-related individuals involved in crimes against Ukraine and Ukrainians, such as appropriating agricultural property and introducing Russian educational standards with anti-Ukrainian narratives in the temporarily occupied territories of Ukraine. The second decree imposed sanctions on five Russian-related legal entities involved in activities such as publishing and spreading Russian propaganda and instilling anti-Ukrainian sentiment in the temporarily occupied territories. Read more>>

V. other notable developments

• Australia Sanctions Russian Cyber Firm: As outlined above, on November 20, Australia, in coordination with the U.S. and the UK, announced sanctions against a Russia-based web company, Media Land, determined to have supported Russian ransomware operations. Read more>>
• Canada Sanctions Russian Drone Makers and Shadow Fleet Vessels: On November 12, Canada announced sanctions against Russian drone makers and 100 vessels from Russia’s “shadow fleet.” Canada’s announcement emphasizes these sanctions are intended to “increase the economic costs on Russia for its unprovoked and unjustified invasion of Ukraine by targeting its energy revenues and financial enablers, while also degrading its conventional and hybrid military capabilities.” Read more>>