Sanctions Tracker: UK Introduces New Trade And Transport Sanctions – Including Restrictions On LNG And Refined Oil Products

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (the “2026 Regulations”) amend the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”) with effect from 20 May 2026. They introduce a range of new trade and transport sanctions. An overview of the amendments made by the 2026 Regulations can be found in the Explanatory Memorandum and the UK Russia statutory guidance has been amended to reflect the changes introduced by the 2026 Regulations. 

In this post, we examine the key changes introduced by the 2026 Regulations. At the time of writing, these had not been reflected in the consolidated version of the Russia Regulations available on the legislation.gov.uk website. Therefore it is important (at present) to have regard to both the Russia Regulations and the 2026 Regulations to understand the restrictions in force.

LNG: Maritime services ban

The UK first announced its intention to ban Russian-origin LNG in November 2025. Since then, significant EU measures have been implemented (via both Regulation 833/2014 and the RePOWER EU Regulation) – but the UK position has remained in limbo. 

The 2026 Regulations have now introduced a maritime services ban on Russian liquified natural gas (“LNG”). These measures prohibit:

• the supply or delivery of Russian-origin LNG by ship (whether from Russia to a third country or from one third country to another), 
• the provision of funds or financial services in pursuance of or in connection with arrangements for such supply or delivery; and 
• the provision of brokering services relating to such arrangements.

In common with the equivalent EU measures, services may be provided until January 2027 where this is in connection with an obligation arising under an LNG contract concluded before 17 June 2025, provided that the duration of the contract exceeds one year and certain other conditions are met.

Exemptions are available for related derivative trading and in respect of events likely to have a serious and significant impact on health and safety, infrastructure or the environment.

A General Trade Licence has also been issued in respect of these measures, permitting the supply of LNG from the Sakhalin-2 or Yamal terminals in Russia (together with the provision of ancillary services) where the activity taking place is under a contract with a duration of one year or less. The licence will expire on 1 January 2027 and is subject to a requirement that notification is made to the Office of Trade Sanctions Implementation (“OTSI”).

Import restrictions: including refined oil products

The 2026 Regulations also introduce restrictions on the import into the UK of certain Russian-origin goods, namely uranium and, more significantly, refined oil and oil products that have been processed from Russian-origin crude in third countries. This latter category of goods is referred to in the Russia Regulations as “relevant processed oil products”. As is typical for trade sanctions restrictions included in the Russia Regulations, the new restrictions are also accompanied by ancillary restrictions on technical assistance, financial services and funds, and brokering services. 

For the avoidance of doubt, the import of Russian-origin crude was and remains prohibited, but the ability (until now) to import refined products was regarded as a lacuna in the UK’s sanctions regime.

The introduction of these measures has been overshadowed in the press by the issuance in parallel of a new General Trade Licence in respect of relevant processed oil products. This authorises transactions which would otherwise contravene the new measures where they relate to diesel and jet fuel. The licence is stated to be of indefinite duration but will be periodically reviewed; according to the licence the UK government will endeavour to provide four months’ notice of any decision to revoke the licence. 

The Department for Business and Trade has updated its notice to importers to reflect the new import measures.

Export restrictions

The amendments include the addition of various types of “restricted goods” to the existing Russian trade sanctions restrictions which prohibit the export or supply of a wide range of items to Russia (and ancillary services). The additions cover: (i) various types of industrial chemicals, metals and machinery, (ii) articles of carbon fibre, (iii) chemicals used in riot control agents, and (iv) goods relating to emerging technologies. 

As ever, companies should carefully check the schedules to the Russia Regulations for detail of the items which are now subject to sanctions.

Certain other minor amendments have been made to the existing schedules of restricted goods in the Russia Regulations.

Construction services

“Construction services” have been added to the list of prohibited professional and business services contained in Regulation 54C of the Russia Regulations. These services are defined by reference to the Central Product Classification and include pre-erection work at construction sites, construction work for buildings, construction work for civil engineering, assembly and erection of prefabricated constructions, special trade construction work, installation work, building completion and finishing work and renting services related to equipment for construction etc.

Such services may no longer be provided to persons connected with Russia (“PCWRs”) (a definition which includes all Russian-incorporated companies), subject to licensing by OTSI and exceptions relating to: (i) the performance of pre-existing contractual obligations (for a three-month period) and, (ii) acts of essential maintenance.

Shipping and transport-related restrictions

The 2026 Regulations prohibit a range of services (as listed in new Regulation 46AA) in relation to “specified ships” (i.e. individually listed vessels), together with the chartering or operating of such ships, and also expand the criteria under which a ship can be specified. As noted in the Explanatory Memorandum, these new sanctions will not automatically apply to ships that are already specified, although the UK may review existing specifications to consider whether these measures should be imposed. 

The 2026 Regulations introduce a new restriction on the acquisition of a “detained transport asset” (namely ships or aircraft subject to directions made under the Russia Regulations) from or for the benefit of a designated person or a PCWR. 

OTSI has updated its licensing guidance to reflect the licensing regime applicable to construction services and services related to specified ships. 

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.