Russia/Ukraine Sanctions Update - Month of January 2026

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

I.  US SANCTIONS

• Ukraine-Russia Peace Talks End without Agreement: According to Reuters, on January 24, Ukraine and Russia talks, brokered by the U.S., ended without a deal but with more talks expected the following weekend. Statements after the talks did not indicate that any agreements had been reached, and Russian airstrikes knocked out power for over one million Ukrainians that evening. Read more>>
• State Secretary Call with G7 Foreign Ministers Discusses Russia-Ukraine War: On January 7, Secretary of State, Marco Rubio, spoke with G7 foreign ministers. The leaders discussed several topics and “reiterated support for ongoing negotiations to end the Russia-Ukraine war.” Read more>>

• OFAC Issues New and Amended Russia-Related General Licenses: On January 6 and 14, OFAC issued a general license, amended a general license, and issued two amended Frequently Asked Questions under the Russia sanctions program. The general licenses authorize certain administrative transactions prohibited by Directive 4 under Executive Order 14024 and certain transactions for the negotiations/contingent contracts for the sale of Lukoil International GmbH and related maintenance activities. Read more>>

II.  EU Sanctions

• EU Adds Russia to List of High-Risk Third Countries for Money Laundering: On January 9, the Commission's delegated Regulation was published, adding Russia to the list of high-risk countries for money laundering and terrorist financing. EU entities covered by the AML framework are required to apply enhanced due diligence to transactions involving these jurisdictions. Read more>>
• EU Lowers Russian Oil Price Cap Level: On January 15, the EU lowered the price cap for Russian crude oil to $44.10 per barrel, effective February 1. Starting January 15, contracts concluded under the previous price cap may be executed for 90 days. This decision stems from the EU’s 18th sanctions package, which lowered the cap from $60.00 to $47.60 and introduced an automatic and dynamic mechanism for setting the future price cap for crude oil. The new mechanism ensures that the cap is always 15% lower than the average market price for Urals crude in the previous reference period (22 weeks). The price cap will be subject to regular review every six months by the European Commission, although extraordinary reviews are possible where duly justified by developments in the oil markets or other unforeseen circumstances. Read more>>, Read more>>
• Council Gives Final Green Light to Stepwise Ban on Russian Gas Imports: On January 26, EU Member States formally adopted the regulation phasing out Russian imports of both pipeline gas and liquified natural gas (LNG) into the EU. A full ban will take effect for LNG imports from the beginning of 2027 and for pipeline gas imports from autumn 2027. The new rules also include measures on effective monitoring and diversification of energy supply. The regulation will be published in the Official Journal of the EU and will enter into force one day after publication, applying directly in all EU Member States. The European Commission also plans to propose legislation to phase out Russian oil imports by the end of 2027. Read more>>
• EU Imposes Additional Sanctions in view of Iran's Support for Russia's War: On January 29, the Council added four persons and six entities to the list of natural and legal persons subject to asset freeze and/or travel ban measures under the EU's dedicated sanctions regime, with a specific focus on the Iranian state-sponsored program for the development and production of unmanned aerial vehicles (UAVs). Read more>>, Read more>>
• EU Commission Updates its Guidance on Sanctions Against Russia and Belarus: In January, the European Commission issued updated guidance on the oil price cap and on the provision of services. The Commission has also issued new guidance on the Nord Stream infrastructure ban, providing details about what the EU regulator expects from EU operators with regard to transactions involving Nord Stream infrastructure. Read more>>, Read more>>, Read more>>
• OLAF Coordinates International Investigation into Suspected Circumvention of EU Sanctions: The European Anti-Fraud Office (OLAF) has coordinated a complex cross-border investigation into the suspected circumvention of European Union sanctions against Russia involving the export of over 760 transport vehicles from the EU, with the assistance of national authorities. The investigation was launched following information provided by the Polish authorities, who identified suspicious exports of used vehicles from several EU Member States. Although the vehicles were declared as destined for Türkiye, evidence gathered by Polish customs suggested that their actual destination was Russia. Through data analysis and cross-checking of customs, trade, and transport information, OLAF uncovered a broader scheme involving multiple exporters in the EU and declared importers in third countries, including Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Moldova. Cooperation with the authorities of those countries enabled OLAF to establish that a total of 766 vehicles had never been imported into the declared destinations. Read more>>
• Continuation of EU Sanctions Against Belarus: On January 21, the European Commission reiterated that the EU's policy towards Belarus aims to apply pressure on the Belarusian authorities while supporting the people of Belarus and their democratic aspirations. The EU will remain steadfast in its support for a democratic Belarus and will continue to condemn the actions of the regime and call for the release of all political prisoners and an end to repression. Read more>>, Read more>>
• China's Retaliatory Measures Against Lithuanian Financial Institutions: The European Commission was questioned on its views concerning China's decision of August 13, 2025, to impose sanctions on two Lithuanian financial institutions, UAB Urbo Bankas and AB Mano Bankas, restricting their access to the Chinese market and financial services, further to the EU's 18th sanctions package against certain Chinese financial institutions involved in helping Russia evade sanctions. The Commission indicated that it is following the situation closely and is currently engaging in bilateral discussions with China to address the issue. While the Commission is considering its next steps at the EU level, it is not in a position to disclose the details of the actions under consideration. Read more>>, Read more>>
• Aircraft Grounded as a Result of EU Sanctions Against Russia: In response to a question on aircraft that have been grounded in the EU since 28 February 2022 as a result of sanctions against Russia, the European Commission indicated that it does not possess specific data regarding the total number of aircraft currently grounded in the EU. Read more>>, Read more>>
• Frozen Russian Assets in Denmark: The European Commission was questioned on revelations by the Danish press that 25% of frozen Russian assets – assets belonging to Putin's inner circle of oligarchs, among others – have disappeared over the past few years. These include both financial resources and goods such as thousands of tonnes of Russian steel. The Commission responded that EU sanctions provide for several derogations, with the effect that where national competent authorities decide to grant an authorization to that end, the overall value of frozen assets decreases. Overall, the variations observed in the total amounts frozen are not necessarily indicative of funds "disappearing" but can instead reflect market fluctuations and possible authorizations granted to release funds under the available derogations. As far as interest is concerned, as a rule, interest owed to the owner of the frozen funds continues to accrue to the owner but remains equally frozen. As part of its regular contacts with Member States on frozen assets reporting, the Commission has reached out to the Danish authorities on the matter raised. Read more>>, Read more>>
• Sanctions Evasion Networks and Implications for the EU's Eastern Partnership Policy: In response to a question on Georgia's role in EU sanctions evasion, the European Commission indicated that addressing circumvention of sanctions, which is now a crime under EU law, is a key priority for the EU. The Commission monitors trade flows, especially goods on the Common High Priority (CHP) and Economically Critical Goods (ECG) lists, from the EU to third countries considered to be at high risk of being used as a platform for circumvention, including Georgia, and from these countries to Russia. The Commission indicated that the latest data from Georgian authorities indicate that no exports of CHP items from Georgia to Russia were reported between January 2024 and October 2025. In November 2025, Georgia committed to halt re-exports of ECGs. Nonetheless, re-export of these items from Georgia to Russia remains a concern for the EU, and the Commission has called on Georgia to step up efforts to prevent its territory or operators from being used to circumvent EU sanctions. As a candidate country, Georgia is subject to heightened expectations and scrutiny regarding its alignment with the EU acquis, including the Common Foreign and Security Policy and EU restrictive measures. Read more>>, Read more>>
• Circumvention of EU Sanctions Through Imports of Petrochemical Products Derived from Russian Crude Oil: The European Commission explained that it is continuously monitoring the scale and routes of EU imports of petroleum products possibly obtained from Russian crude oil. An important step towards blocking such imports was the adoption of a ban on imports into the EU of refined oil products (falling under CN code 2710) produced in third countries using Russian crude oil. This ban took effect on 21 January 2026. In light of this measure, the EU has analyzed detailed customs data and identified imports from third countries possibly containing Russian crude oil. The Commission has also contacted relevant Member States' authorities to enhance checks and to ensure that adequate awareness and due-diligence practices are put into place. Data analysis with Member States to monitor these specific flows will continue in a working group set up for this purpose. Read more>>, Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Euro Asia Cargo Private Ltd: By its judgment delivered on January 14, the General Court dismissed the actions brought by the company Euro Asia Cargo Private Ltd. challenging its listing. Read more>>
• Italy Introduces New Criminal Offences and Corporate Fines for EU Sanctions Breaches: On January 9, Legislative Decree No. 211 of 30 December 2025 was published, implementing EU Directive 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures. The Decree entered into force on January 24, 2026. Read more>>
• France Seizes Russia-Linked Oil Tanker in the Mediterranean: On January 22, France announced that it seized an oil tanker in the Mediterranean suspected of being part of Russia's sanctions-evading "shadow fleet." French President Emmanuel Macron said the tanker, named the Grinch, was "subject to international sanctions and suspected of flying a false flag". Read more>>
• Sanctioned Russian Steel Found in Finland: On January 1, Finnish customs authorities confirmed that the cargo of the detained vessel Fitburg included Russian-origin structural steel. The structural steel found onboard was classified by customs experts as construction-grade material included in the scope of EU sanctions imposed in response to Russia's invasion of Ukraine. Read more>>

III.  UK Sanctions

• UK Sanctions List: The UK government’s sanctions lists changed to a single list on Wednesday 28 January 2026. UK sanctions designations are now only detailed in the UK Sanctions List (UKSL), published by the Foreign, Commonwealth and Development Office. The Consolidated List of Asset Freeze Targets, which was published for HM Treasury by the Office of Financial Sanctions Implementation (OFSI) is no longer being updated. Read more>>
• OFSI publishes consultation outcome on improving civil enforcement processes for financial sanctions: On January 29, 2026, OFSI published the response to its July-October consultation, which sought views on proposed measures to enhance the effectiveness of its civil enforcement processes for financial sanctions and the Oil Price Cap. The response outlines a revised enforcement framework that will, according to OFSI “support compliance, give firms greater certainty and ensure our approach to enforcing financial sanctions is fair, effective and robust”. These changes apply only to OFSI’s civil enforcement powers. Read more>>, Read more>>
• ECJU publishes updated open licence returns guidance: On January 29, 2026, the Export Control Joint Unit (ECJU) published updated guidance for exporters submitting open licence returns. The guidance reflects changes in reporting requirements and includes an updated list of open general export licences (OGELs) that now require an open licence return (OLR), along with revised explanations of what information must be recorded and how returns should be submitted. Read more>>
• OFSI and partners clamp down on the abuse of crypto assets: On January 28, 2026, OFSI announced its collaboration with the Crypto Cash Fusion Cell (CCFC) to target criminal funds linked to sanctions offences. The CCFC is a multiagency initiative that brings together the National Crime Agency, the Metropolitan Police Service, His Majesty’s Revenue and Customs, the Financial Conduct Authority, City of London Police and OFSI. This multiagency initiative aims to improve how the UK enforcement and regulatory community identifies, understands and responds to criminal abuse of cryptoassets. Read more>>
• UK Government amends one entry on the UK sanctions list under the Russia Regime: On January 27, 2026, OFSI amended the entry for LLC RUSNEFTEGAZ GROUP on the UK sanctions list under the Russia sanctions regime. This entity is still subject to an asset freeze and trust services sanctions. Read more>>
• UK Government imposes penalty on Bank of Scotland for breach of financial sanctions: On January 26, 2026, OFSI published a notice regarding a penalty of £160,000 imposed on the Bank of Scotland for breaches under the Russia regime. Between 8 February and 24 February 2023, the Bank of Scotland processed 24 payments, totalling £77,383.39, to or from a personal current account held by a sanctioned individual. OFSI concluded that the processing of these 24 payments breached regulation 11 (dealing with funds) and regulation 12 (making funds available) of the Russia (Sanctions) (EU Exit) Regulations 2019. Read more>>
• UK Government amends one entry to the UK sanctions list under the Russian regime: On January 16, 2026, OFSI amended the entry for John Michael Ormerod on the UK sanctions list under the Russia regime. This individual is still subject to an asset freeze and trust services sanctions. Read more>>
• OFSI amends General License for Maritime Services Ban and Oil Price Cap: On January 15, 2026, OFSI amended General Licence INT/2024/4423849, which permits the supply or delivery by ship of Russian crude oil and oil products, as well as provision of associated services, so long as the price paid for Russian oil or oil products is at or below a price cap. The cap will be reduced from USD 47.60 per barrel to USD 44.10 per barrel effective from 23:01 GMT on 31 January 2026. The amendment also includes a transitional wind-down provision for any trades with an effective date of contracts before 23:01 GMT on 31 January 2026 that comply with the old cap of USD 47.60, ending 22:59 BST on 16 April 2026. On the same day, OFSI updated several related FAQs (FAQs 154-158 and 161) to align the guidance with the new price cap level. Lastly, the lowering of the cap was also reflected in the Maritime Services Ban and Oil Price Cap industry guidance. Read more>>

IV.  Russia/Ukraine Sanctions

• Ukraine Extends the Sanction Lists: In January, the President of Ukraine adopted the Order No. 8/2026 dated 3 January 2026 and the Order No. 60/2026 dated 17 January 2026 extending the sanctions to 98 individuals and 72 legal entities. The full list of the sanctioned persons is available at the website of the State Sanctions Register of Ukraine. Read more>>, Read more>>
• Ukraine Introduces the List of Prohibited Software: On January 8, the State Service of Special Communications and Information Protection of Ukraine published the first list of prohibited software and network equipment. The prohibition is based on Article 4 of the Law of Ukraine No. 2163-VIII dated 05 October 2017 “On the Basic Principles of Ensuring Cybersecurity in Ukraine”. The Law prohibits use of the listed software in the IT systems processing governmental data and state secrets, as well as in the critical IT infrastructure. The current version of the list covers primarily the accounting software of Russian origin. Read more>>
• Ukraine Plans to Facilitate the Internal Exchange of Information on Sanctions: The Ukrainian government has registered a bill that will introduce automated exchange of information between Ukrainian government agencies on application of sanctions. The bill suggests to establish automated exchange of information to facilitate implementation of the decisions of the National Security and Defense Council of Ukraine and the court judgements concerning sanctions. Read more>>
• The Moscow Arbitration Court Hears the Central Bank's Lawsuit against Euroclear: On January 16, the Moscow Arbitration Court heard the Bank of Russia's 18.2 trillion-ruble lawsuit against the Belgian depository Euroclear. In December, the Bank of Russia stated that Euroclear was committing illegal actions that were causing losses and depriving the regulator of the ability to manage assets and securities. The Bank of Russia claims in its lawsuit against Euroclear, that the assets blocked in the depository are the property of Russia. Read more>>
• Russia has Banned Entry to 28 Canadian Citizens: Russia has imposed personal sanctions on 28 Canadian citizens, who will be denied entry to the country. The decision was made in response to sanctions against Russia introduced by Canada. Read more>>
• The Central Bank of Russia Listed the Information Subject to Non-disclosure Requirement: The Central Bank of Russia published the list of information which will not be publicly disclosed by the Bank in 2026. The list coves the financial statements and reports of the Russian banks and financial organizations, as well as the shareholders of certain financial organizations. Publication of the list extends the non-disclosure policy applied by the Central Bank of Russia in 2025. Read more>>, Read more>>
• Russia’s parallel imports of Western goods dropped by almost 50% in 2025: Russia’s parallel imports of Western goods dropped by almost 50% in 2025, according to officials and analysts, as stricter government oversight and border disruptions curtailed a crucial supply route that emerged after Western firms left the Russian market. Goods imported without trademark holders’ authorization declined by nearly half over the year. Read more>>
• Gazprom Neft Reaches Preliminary Deal to Sell Stake in Serbian Oil Company: The Russian majority shareholders of the Serbia’s largest oil firm, which is subject to U.S. sanctions, have provisionally agreed to sell their holding to Hungary’s energy group MOL. The proposed transaction will be submitted to U.S. authorities for approval as the company seeks to prevent another sanctions-driven shutdown of Serbia’s sole oil refinery. Sanctions imposed by Washington on the Petroleum Industry of Serbia (NIS) as part of broader measures targeting Russia’s energy sector forced the refinery to halt operations in early December. The plant provides roughly 80% of Serbia’s fuel supply. Read more>>