Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

On 1 June 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that FTI Consulting, Inc. (NYSE: FCN), a global business-advisory and expert-witness firm, agreed to pay $1,050,000 to settle apparent civil liability for six indirect dealings in prohibited debt of VTB Bank OAO between April 2019 and May 2021 — constituting violations of the Russia Harmful Foreign Activities Sanctions Regulations (RuHSR) and the then-applicable Directive 1 debt-tenor restrictions. FTI had been engaged via an intermediary global law firm to provide expert economic consulting services supporting VTB in Singapore litigation; invoices issued through that intermediary went unpaid or were paid far beyond the permissible 14-day tenor, extending prohibited debt on six occasions totalling approximately $353,862. OFAC determined the conduct was non-egregious and not voluntarily self-disclosed, and imposed a penalty of $1,050,000 — double the $525,000 base penalty — citing the foundational principle that a party may not do indirectly what it cannot do directly.

On 26 May 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £1,000,920.59 monetary penalty on Sabre Global Technologies Limited (SGTL), a UK-registered travel-technology firm, for repeated breaches of UK financial sanctions. SGTL continued to provide Russian carrier Ural Airlines access to its Global Distribution System (GDS) service for seven months after Ural Airlines was designated by the UK in May 2022, and during July–August 2022 actively explored routing payments through a US bank account to avoid detection by its UK bank — the conduct that makes this the **first OFSI penalty issued for a circumvention offence**. At £1,000,921 this is also OFSI's **largest financial-sanctions penalty since Russia's 2022 invasion of Ukraine**, surpassing the prior record (HSF £465k).

The UK laid the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) before Parliament on 19 May 2026; it came into force on 20 May 2026. The instrument inserts a new Chapter 4KA (regulations 46Z23A-46Z23G) into the Russia (Sanctions) (EU Exit) Regulations 2019, prohibiting the import into the UK of uranium (HS 2844.10/2844.20/2844.30) that originates in or is consigned from Russia, the direct or indirect acquisition of Russian-origin or Russia-located uranium, and the supply or delivery of uranium from Russia to a third country — plus associated technical assistance, financial services/funds, and brokering services. Each prohibition carries a criminal offence with a reasonable-cause-to- suspect defence, subject to narrow exceptions and licensing grounds at regulations 16-19 of the amending instrument. The same instrument separately extends the existing ban on imports of relevant (2709-origin) Russian crude to cover oil products refined from that crude in a third country (new regulations 46Z9F-46Z9I).

On 30 April 2026, the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch (DBLB) for breaching regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019. DBLB processed two payments totalling £635,618.75 in June and July 2022 to Okko LLC, a Russian streaming-platform operator wholly owned by sanctioned entity JSC New Opportunities. The breach arose because DBLB's third-party sanctions-screening provider failed to identify that Okko had become majority-owned by the designated entity post-listing. DBLB voluntarily disclosed the breach to OFSI in September 2022, qualifying for a 45% reduction from the £300,000 baseline penalty. This is the second resolution under OFSI's new Settlement Scheme (introduced February 2026) and the first involving a major investment-bank counterparty.

On 23 April 2026, the Council of the European Union adopted the 20th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2026/506 amending Regulation 833/2014 (sectoral sanctions) and Council Regulation (EU) 2026/511 amending Regulation 269/2014 (asset-freeze listings — 120 additional individuals and entities, the largest single tranche in two years). The package operationalises and extends the crypto-sanctions architecture introduced in the 19th package and constructs the legal scaffolding for a future full prohibition on maritime services to vessels carrying Russian crude/petroleum products. Headline measures: (i) full sectoral prohibition on transactions with crypto-asset service providers and exchange platforms established in Russia or Belarus, plus designation of the rouble-backed stablecoin RUBx and the digital rouble (CBDC) on Annex LIII — effective 24 May 2026, with EU support for the digital rouble's development banned outright; (ii) 36 new energy-sector listings spanning upstream extraction, refining and transportation; (iii) prohibition on providing technical, financial, brokering and insurance services to Russia-flagged, Russian-certified or Russian-managed LNG tankers and icebreakers effective 25 April 2026, extending to foreign-flagged vessels operating in Russian interests by January 2027 and culminating in a categorical ban on LNG terminal services to Russian-controlled entities on 1 January 2027; (iv) full transaction ban on 20 Russian banks plus four third-country banks listed for SPFS connectivity / sanctions circumvention; (v) 46 newly listed shadow-fleet vessels and new tanker sale-due-diligence obligations on EU shipping operators; (vi) 58 designations of companies and associated individuals in the Russian military-industrial complex including drone developers/manufacturers; (vii) further Annex IV third-country circumvention enabler listings (China, Hong Kong, Turkey, UAE); (viii) parallel measures against Belarus. Entry into force on 24 April 2026 (day following publication in OJ L_202600506), except for measures with explicit deferred application dates.

On 19 March 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £390,000 monetary penalty on Apple Distribution International Limited (ADI), the Ireland-incorporated subsidiary of Apple Inc. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. ADI's failure to cancel the payments amounted to conduct in the UK that breached regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019, which prohibits making funds available to a person owned or controlled by a designated person. The enforcement is notable as the **first use of OFSI's new settlement mechanism** (introduced February 2026), which allows OFSI and a subject of an enforcement action to resolve a civil monetary penalty case via time-bound negotiation. OFSI applied a 35% discount to the £600,000 baseline penalty to reach the £390,000 final figure, reflecting ADI's voluntary self-disclosure (made 4 October 2022) and cooperation.

On 25 February 2026 the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (Ukraine Ordinance) and the Ordinance on Measures against Belarus, completing implementation of the EU's 19th sanctions package with effect from 26 February 2026. Headline measures: a complete ban on the purchase and import of Russian LNG taking effect 25 April 2026 (transition period until end-2026 for pre-existing long-term contracts); a complete prohibition on the provision of crypto-asset services to Russian persons and companies; new service bans covering advanced-technology / AI / high-performance-computing services and tourism-related services; expansion of the dual-use end-user list (Annex 2) including additional Chinese entities; SECO authority to grant divestment-exemption licences until end-2026 under Art. 30a; and parallel adoption of the EU October 2025 Belarus measures via amendment to the Belarus Ordinance.

Ukrainian President Volodymyr Zelenskyy signed Decree No. 102/2026 on 7 February 2026, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 27 legal entities: 22 based in Russia and 5 based in China and Hong Kong. The designees are described as active in defense manufacturing, precision engineering, optics, electronics, aerospace, and applied research, technology and banking/trading activity that Ukraine assesses as supporting Russian weapons production and its financing. The decree entered into force on 10 February 2026.

On 7 February 2026 Ukrainian President Volodymyr Zelenskyy signed Presidential Decree No. 103/2026, enacting a National Security and Defence Council (NSDC) decision to apply personal special economic and other restrictive measures (sanctions) against 42 individuals and 35 legal entities based in Russia, Kyrgyzstan and the United Arab Emirates. The tranche specifically targets the "A7" cryptocurrency payment ecosystem, which Ukraine assesses is used to settle payments for components supplied for Russian missile production, alongside wider financial-sector sanctions-circumvention activity. Designation imposes asset freezes and a bar on commercial transactions and investment instruments involving the designees; the decree entered into force on 10 February 2026.

On 29 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 28 of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), lowering the price cap on Russian seaborne crude oil from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. The amendment prohibits Swiss-domiciled operators from providing financial and transport (maritime, insurance, brokering) services related to Russian crude oil priced above the new cap. Switzerland is not an EU member but autonomously aligns its Ukraine Ordinance with EU sanctions packages; this cut mirrors the EU's Implementing Regulation 2026/124 and the UK OFSI general licence amendment adopted two weeks earlier under the same six-monthly dynamic-adjustment formula.

On 10 November 2025, OFSI imposed a £160,000 monetary penalty on Bank of Scotland Plc (a Lloyds Banking Group subsidiary trading as Halifax) for processing 24 payments totalling over £77,000 in February 2023 to and from a personal current account held by Dmitrii Ovsyannikov, a designated person under the Russia (Sanctions) (EU Exit) Regulations 2019, in breach of Regulations 11 and 12. The screening failure arose because Ovsyannikov had opened the account under a UK-passport spelling variant of his name that defeated Halifax's exact-string sanctions-screen. The base penalty of £320,000 was halved to £160,000 following a 50% voluntary-disclosure discount after Lloyds Banking Group self-reported the breach. The penalty notice was published on 26 January 2026 and OFSI issued a compliance-lessons blog post on 23 February 2026.

On 14 January 2026 the European Commission adopted Implementing Regulation (EU) 2026/124, amending Annex XXVIII to Council Regulation (EU) No 833/2014, lowering the price cap on seaborne Russian crude oil (CN code 2709 00) from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. This is the first application of the automatic dynamic-adjustment mechanism introduced by the 18th sanctions package (Council Regulation (EU) 2025/1494, July 2025), which re-indexes the cap every six months to 15% below the 22-week trailing average Urals market price. Contracts concluded before 31 January 2026 with cargo offloaded by 16 April 2026 remain subject to the prior USD 47.60/bbl cap. The UK aligned with an equivalent reduction the same day.

On 15 January 2026 the UK Office of Financial Sanctions Implementation (OFSI), acting under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, amended the 'Oil Price Cap' General Licence (INT/2024/4423849) to lower the price cap on Russian seaborne crude oil from USD 47.60 to USD 44.10 per barrel, effective 23:01 on 31 January 2026. Contracts signed at the prior USD 47.60 cap before that time are subject to a wind-down period, remaining valid provided the oil is offloaded at the port of destination by 22:59 on 16 April 2026. The cut applies the six-monthly dynamic-adjustment formula (15% below the 22-week trailing average Urals price) and was announced in lockstep with the EU's equivalent Implementing Regulation 2026/124.

On 12 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annexes 8, 14, 15b and 33 of the Ordinance on Measures in Connection with the Situation in Ukraine, with effect from 23:00 on 13 January 2026. The amendment adds 5 natural persons, 4 organisations (one Vietnam-based, three based in the UAE and Russia), and 41 vessels to the asset-freeze and port-access-prohibition annexes, and makes technical corrections to 7 existing entries. The measure is a routine incremental listing update continuing Switzerland's autonomous alignment with the EU's Russia sanctions regime, following the first EU 19th-package tranche adopted 12 December 2025 ([switzerland-19th-eu-sanctions-package-december-listings](2025-12-12-switzerland-19th-eu-sanctions-package-december-listings.md)) and preceding the substantive package completion of 25 February 2026 ([switzerland-19th-eu-sanctions-package-russia-belarus](2026-02-25-switzerland-19th-eu-sanctions-package-russia-belarus.md)).

Ukraine's President Volodymyr Zelenskyy signed Decree No. 8/2026 on 3 January 2026, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 95 individuals and 70 legal entities, the large majority of them Russian citizens, residents, and companies. The designees manufacture or supply communications equipment, radio-electronic warfare (REB) systems, and microelectronics for Russia's defense-industrial complex, alongside chemical, mining, metallurgical, and fuel-and-energy-sector entities and their managers. The decree entered into force on 6 January 2026, the date of official publication.

Presidential Decree No. 1011 of 31 December 2025 amends the standing Decree No. 302 (25 April 2023) list of foreign-owned assets under "temporary management," adding 100 percent of the shares in Rockwool LLC and 68 percent of the shares in Rockwool-Volga LLC — the Russian operating subsidiaries of Danish insulation producer ROCKWOOL A/S — and transferring control to Construction Assets Development JSC (Развитие Строительных Активов, "RSA"), a newly formed Russian administrator. The decree entered into force on its date of official publication (13 January 2026) despite being signed two weeks earlier, and covers four ROCKWOOL factories (Moscow, Leningrad and Chelyabinsk regions, and Tatarstan) producing heat and sound insulation. ROCKWOOL A/S disclosed in a 13 January 2026 regulatory announcement to Nasdaq Copenhagen that it has determined it has lost control of the four plants.

Presidential Decree No. 1012 of 31 December 2025 amends the standing Decree No. 302 (25 April 2023) list of foreign-owned assets under "temporary management," adding 100 percent of the shares in Can-Pak LLC (owned by Poland's Canpack S.A.) and Can-Pak Packaging Plant LLC (owned by Tapon France) — the two Russian operating subsidiaries of the CANPACK Group's aluminium-beverage-can business — and transferring control to StalElement LLC, a newly formed Russian administrator. The decree entered into force on its date of official publication (13 January 2026) despite being signed two weeks earlier, and covers Can-Pak's Volokolamsk (Moscow region) and Novocherkassk plants, which together hold an estimated 25-35% share of Russia's aluminium-can market. It is one of a running series of company-specific amendments to Decree 302, Russia's mechanism for placing Russian assets of "unfriendly state" companies under state administration in reciprocal response to Western sanctions and asset freezes.

The Council of the European Union adopted Regulation (EU) 2025/2618 on 18 December 2025, amending Regulation (EU) No 833/2014, to add 41 vessels to Annex XLII of the Russia sanctions regime. Of these, 36 vessels are designated for transporting Russian crude oil and petroleum products while engaging in irregular and high-risk shipping practices characteristic of the "shadow fleet," 5 vessels are designated for transporting stolen Ukrainian grain and cultural property, and 1 vessel (GT HONOR) is designated for facilitating violation or circumvention of EU sanctions. Listed vessels are banned from access to EU member-state ports and locks and from a broad range of maritime-transport-related services, effective 19 December 2025. The measure is an incremental listing update between the 19th (Regulation 2025/2033, October 2025) and 20th (Regulation 2026/506, April 2026) numbered sanctions packages, rather than a new package itself.

HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a Russia-regime notice on 18 December 2025 designating five individuals and 19 entities under the Russia (Sanctions) (EU Exit) Regulations 2019. Of the 19 entities, six are based in Russia, eight in the United Arab Emirates, four in Uzbekistan and one in Kyrgyzstan — reflecting OFSI's continued focus on third-country intermediaries used to route sanctioned Russian trade and finance. Designated persons are subject to a full asset freeze and are barred from commercial transactions and investment instruments with UK persons.

On 15 December 2025 the Council of the European Union adopted Council Implementing Regulation (EU) 2025/2588 and Council Decision (CFSP) 2025/2594, giving effect to Regulation (EU) No 269/2014 (Ukraine territorial-integrity asset-freeze regime) by adding 9 new designations: 5 individuals who own or control companies enabling Russian oil shipments and controlling a significant share of Russia's "shadow fleet," and 4 shipping companies headquartered in Russia, the United Arab Emirates and Vietnam that manage shadow-fleet tankers and engage in irregular, high-risk shipping practices. Listed persons and entities are subject to an EU asset freeze (and, for the individuals, a travel ban); EU persons and companies are prohibited from making funds or economic resources available to them.

On 12 December 2025 the Swiss Federal Council adopted the first tranche of listings aligning with the EU's 19th Russia sanctions package (Council Regulation (EU) 2025/2033, 23 October 2025), amending the Ordinance on Measures in Connection with the Situation in Ukraine and the Belarus Ordinance with effect from 13 December 2025. The decision adds asset freezes and entry/transit bans for 22 natural persons and 42 entities tied to Russia's military-industrial complex, energy sector and shadow-fleet vessel management; extends purchase/sale/insurance bans to over 100 additional tankers; imposes transaction restrictions on 5 Russian banks and 4 Russian-bank branches in Belarus and Kazakhstan for use of specialised financial-messaging services; sanctions Chinese and Hong Kong trading companies and refineries implicated in circumventing the G7 oil price cap; and designates 5 Belarusian persons linked to military-industrial activities. Divestment-exemption deadlines for Swiss persons winding down Russian holdings are extended to end-2026. This is a partial, listings-only tranche — the more substantive measures of the EU's 19th package (Russian LNG import ban, crypto-services prohibition, AI/HPC service bans) were not adopted until the Federal Council's follow-on decision of 25 February 2026.

The UK government designated Russian media entity Rybar LLC and its director-general Mikhail Zvinchuk, alongside Aleksandr Dugin, the Foundation for the Support and Protection of the Rights of Compatriots Living Abroad (Pravfond), and affiliated entities Euromore, Golos, and the Center for Geopolitical Expertise, under the Russia (Sanctions) (EU Exit) Regulations 2019. The designations impose asset freezes and bans on commercial transactions and investment instruments with the named parties, on the basis that Rybar runs a foreign information manipulation and interference (FIMI) network promoting Russian state interests and destabilising Ukraine. Pravfond's network was separately alleged to have moved funds across at least 11 EU member states to fund pro-Kremlin media outlets while concealing state ties.

Ukraine's President signed Decree No. 870/2025 on 29 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 26 Russian legal entities involved in crude petroleum and natural gas extraction, petroleum-product refining, and related energy-sector activity. The decree imposes asset freezes and bars commercial transactions and investment dealings with the designated entities. It entered into force on 2 December 2025, the date of official publication.

Ukraine's President signed Decree No. 871/2025 on 29 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against a list of Russian legal entities and individuals identified by the Security Service of Ukraine (SBU) as involved in the production, supply, or operational support of unmanned aerial vehicles (UAVs/drones) used by Russia. The decree imposes asset freezes and restrictions on commercial transactions and investment instruments with the designated parties. It entered into force on 2 December 2025, the date of official publication.

Ukraine's President signed Decree No. 860/2025 on 25 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 41 legal entities that collectively own 56 maritime vessels. The vessels are alleged to have made illegal port calls at Sevastopol and Feodosia — Ukrainian ports under temporary Russian occupation — to load and export stolen Ukrainian wheat, sunflower seeds, and other food commodities between 2022 and 2025. The sanctions (asset freezes, restrictions on commercial transactions and transit, and foreign- customer limitations) apply for a term of 10 years and entered into force on 27 November 2025, the date of official publication.

On 24 November 2025, OFAC assessed a civil monetary penalty of USD 4,677,552 — the statutory maximum and the largest single OFAC penalty ever imposed against an individual — against an Atlanta-based real-estate investor operating through King Holdings LLC. Between April 2023 and March 2024 the respondent willfully purchased, mortgaged, renovated, and resold US residential property beneficially owned by a family member of a Russian oligarch sanctioned under EO 14024, in direct violation of a prior OFAC cease-and-desist order and in defiance of an administrative subpoena. OFAC found the violations egregious and non-self-disclosed; both aggravating factors drove the penalty to the statutory ceiling.

On 19 November 2025, the U.S. Treasury's Office of Foreign Assets Control (OFAC), in a coordinated action with Australia's Department of Foreign Affairs and Trade and the UK's Foreign, Commonwealth and Development Office, designated 5 individuals and 7 companies linked to two Russia-based "bulletproof hosting" (BPH) providers, Media Land and Aeza Group, under Executive Order 13694. Media Land and its subsidiaries (Media Land Technology, Data Center Kirishi, ML Cloud) supplied server infrastructure to ransomware groups including LockBit, BlackSuit and Play. The designations also targeted three companies Aeza Group used to evade its July 2025 OFAC designation and rebrand its infrastructure: Hypercore Ltd. (United Kingdom), Smart Digital Ideas DOO (Serbia), and Datavice MCHJ (Uzbekistan). All designated persons' U.S.-nexus assets are blocked and U.S. persons are prohibited from transacting with them.

Canada made SOR/2025-228, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-11-06 and announced by Minister Anand on 2025-11-12. The regulations add 13 individuals to Part 1 of Schedule 1, 11 entities to Part 2 of Schedule 1, and 100 vessels (by IMO number) to Schedule 1.1, freezing their Canadian assets and prohibiting dealings. Targets include Russian LNG-trading entities, drone-programme developers, cyber-infrastructure suppliers for hybrid operations against Ukraine, and Kyrgyzstan-based financial enablers (including Capital Bank of Central Asia and the A7 payments platform) used to evade earlier Russia sanctions. The 100-vessel designation targets Russia's "shadow fleet" used to move crude oil, LNG and arms while evading the G7 price cap and flag-state controls.

New Zealand's 33rd sanctions round under the Russia Sanctions Act 2022 designated 65 "shadow fleet" tanker vessels involved in transporting Russian-origin crude oil, together with seven entities and two individuals based in Russia, Belarus, North Korea and Iran that refine or transport Russian oil or facilitate oil-related payments. Designated parties are subject to asset freezes and prohibitions on the supply of services (including port access, insurance, chartering and cargo handling) by New Zealand persons. The measure targets the revenue chain funding Russia's war in Ukraine rather than imposing a new tariff or trade-flow control.

On 29 October 2025 the Swiss Federal Council amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 662, completing Switzerland's alignment with the remaining goods, finance and services elements of the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025) and tightening the parallel Belarus regime. The amendment took effect 30 October 2025 and adds: an export ban covering additional structural-metal, general-purpose-machinery and machine-tool goods; an import ban on further petroleum-oil products and waste/scrap categories; and expanded controls on commercial transactions and investment instruments spanning financial services, investment banking, crude-petroleum trade and motor-vehicle/trailer goods. The Federal Department of Economic Affairs (WBF) had already taken over the measures within its own competence on 12 August 2025; this decision closes the remainder. In parallel, the Federal Council's asset-freeze annexes were extended to 14 individuals and 41 companies/organizations.

On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.

On 23 October 2025, the Council of the European Union adopted Council Regulation (EU) 2025/2041 (amending Regulation (EC) No 765/2006) and Council Decision (CFSP) 2025/2040 (amending Decision 2012/642/CFSP), widening the EU's Belarus restrictive-measures regime in lockstep with the 19th Russia sanctions package adopted the same day. The package widens the export ban to industrial goods (salts, ores, rubber articles, tyres, millstones, construction materials, electronic components, rangefinders, propellant chemicals, metals/oxides/alloys), extends the import ban to all acyclic hydrocarbons, introduces a new prior-licensing requirement for services supplied to Belarus, its government, or public bodies, and mirrors the Russia regime's space, AI, and high-performance/ quantum-computing service restrictions. A companion instrument, Council Implementing Regulation (EU) 2025/2039, adds 5 new asset-freeze listings (2 individuals + 3 entities, including JSC Holography Industry, Horizont Holding, and ICT Horizont). Entered into force 24 October 2025.

On October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.

On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.

Russian Government Resolution No. 1545 of 6 October 2025 amends Resolution No. 851 (11 May 2022) to add Renault SAS to Russia's list of foreign legal entities subject to "special economic measures" tied to military-technical cooperation. Renault is listed as entry No. 75 and becomes subject to prohibitions on commercial transactions and on the use of investment instruments (securities/equity dealings) involving the company. The designation follows reporting that Renault planned to help manufacture unmanned aerial vehicles (drones) for Ukraine; a related GTA-tracked intervention imposes an export ban on the same entity under the same resolution.

Presidential Decree No. 710 of 6 October 2025 amends the standing list of foreign-owned assets under "temporary management" (established by Decree No. 302 of 25 April 2023) to add 100 percent of the shares in Vonorus LLC — the Russian operating subsidiary of Silgan Metal Packaging Mitterdorf GmbH, the Austrian unit of US-listed Silgan Holdings Inc. (NYSE: SLGN) — transferring control of the company to Rosimushchestvo. The decree entered into force on its date of official publication (6 October 2025) and is one of a running series of company-specific amendments to Decree 302, Russia's mechanism for placing Russian assets of "unfriendly state" companies under state administration in reciprocal response to Western sanctions and asset freezes.

On 19 September 2025 the UK Foreign, Commonwealth and Development Office designated two Georgian nationals — Otar Partskhaladze and Levan Vasadze — and two companies, UK-based Aeza International Ltd and Russia-based HeliCo Group LLC, under the Russia (Sanctions) (EU Exit) Regulations 2019, citing their roles in supporting Russian disinformation and Georgia's Kremlin-aligned political network. In the same package OFSI proscribed two oil tankers, Bavly and Karakuz, for allegedly delivering Russian-origin crude to the port of Batumi, Georgia, barring both vessels from UK ports and the UK Ship Register. Designated individuals face asset freezes, travel bans and director-disqualification sanctions.

Australia aligned with the EU/G7's 18th-package price cap by lowering its own cap on Russian-origin crude oil from USD 60 to USD 47.60 per barrel, and designated 95 additional "shadow fleet" tanker vessels used to circumvent the cap, under the Autonomous Sanctions Regulations 2011. Foreign Minister Penny Wong framed the measure as intended to depress the market value of Russian crude and reduce war-financing oil revenue. The listings bring Australia's cumulative shadow-fleet vessel designations to over 150 since June 2025 and its total Russia-related sanctions actions since 2022 to roughly 1,600.

Japan lowered its price cap on Russian-origin crude oil from USD 60 to USD 47.60 per barrel, effective for contracts concluded on or after 12 September 2025, aligning with the EU's July 2025 cut under its 18th sanctions package. The measure bars Japanese entities from importing, or providing shipping, insurance, financing or other services for, Russian crude priced above the new cap. In the same package Japan added 47 Russian entities and 9 individuals, 6 Crimea/Donbas-linked persons and entities, and 3 third-country entities to its asset-freeze list (transactions now require Ministry of Finance approval), and imposed export prohibitions on 2 Russian entities and 9 entities in third countries. Japan's own Russian crude imports are minimal (~0.1% of total crude imports, Jan-Jul 2025), so the measure is primarily a coalition-alignment and shipping/insurance-chokepoint action rather than a material change to Japan's own energy sourcing.

New Zealand's 32nd sanctions round under the Russia Sanctions Act 2022 (Russia Sanctions Amendment Regulations (No 4) 2025, SL 2025/195) lowered the price cap on Russian-origin crude oil (HS 2709) from US$60/bbl to US$47.60/bbl, a roughly 21% cut, aligning New Zealand with the EU, UK and Canada's most recent price-cap reductions. The same instrument designated 19 individuals and entities plus 19 vessels, including Russia's GRU cyber unit 29155 (implicated in malware attacks on Ukrainian government networks), actors involved in chemical-weapons use and disinformation, additional "shadow fleet" tankers, alternative payment providers, and third-country facilitators based in North Korea and Iran supporting Russia's war effort.