Recent Developments in UK, EU, and Norway

This Sanctions Alert provides an overview of recent key sanctions developments across the UK, EU, and Norway.

Updates

On 12 September, the UK introduced further sanctions under the Russia (Sanctions) (EU Exit) Regulations 2019, with 30 new designations and 70 specified vessels added to the consolidated sanctions list. These measures form part of the UK's response to recent Russian air strikes violating NATO airspace in Poland and damaging government buildings in Kyiv. The newly sanctioned entities and individuals include key suppliers of military components, such as electronics, chemicals, and explosives, as well as companies involved in Russia's shadow fleet for oil exports. Vessel designations are made against vessels operating in the Russian oil market, and the UK now targets more oil tankers than any other country, intensifying its pressure on Russia's key revenue streams.

Those sanctioned are subject to asset freezes, trust service restrictions and reporting obligations. UK businesses and financial institutions must check whether they hold accounts or resources for designated persons or entities, freeze such resources, refrain from making funds or services available to those listed, and report any findings to the Office of Financial Sanctions Implementation (OFSI). Failure to comply or attempts to circumvent sanctions may constitute a criminal offence.

Separately, on 8 September 2025, the UK issued an update to the official 'UK sanctions guidance for non-UK businesses', specifically amending section 3.2 'Who must comply with UK sanctions'. The guidance reiterates that UK sanctions apply to all persons within UK territory and territorial waters, as well as UK nationals and entities wherever they operate globally. Any connection to the UK, known as 'UK nexus', may trigger UK enforcement powers – even if the breach occurs outside the UK. 

EU Commission Consolidated FAQ Updates

On 8 September, the EU Commission updated its consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 on state-owned enterprises and infrastructure transaction bans set out in Articles 5aa and 5ae of Regulation 833/2014. 

Article 5aa prohibits the direct or indirect engagement in transactions with a Russian entity listed under Annex XIX to the Regulation, a non-EU entity owned by an Annex XIX-listed entity, or any entity acting on behalf or at the direction of such entities.  

In Question 17 included in chapter 5 part G of the FAQ, the EU Commission provides guidance on the scope of the transaction ban in relation to EU subsidiaries of Russian parent companies listed under Annex XIX. The Commission states that an EU entity is likely to be considered acting on behalf of or at the direction of a Russian parent company where it is executing instructions given directly or indirectly from the parent company or it is acting following approvals obtained from the parent company pursuant to inter-corporate agreements or other legal arrangements requiring such approval to be obtained. The appointment or dismissal of authorised representatives or instructions routed through intermediary, non-operational entities are given as examples for when an EU entity may be subject to the transaction ban. 

Regardless of the above, it follows from paragraph 2f of Article 5aa that the transaction ban will not apply where a public trusteeship or similar firewall measure has been imposed by competent national authorities. The EU Commission states that the importance of the transaction ban necessitates competent national authorities to apply strict criteria when imposing public trusteeships or similar firewall measures.

Following the inclusion of a new exemption to the transaction ban in Article 5ae, allowing for transactions with listed ports necessary for the transport of non-Russian origin or owned coal products, the EU Commission has made a brief update to Questions 3 and 6 of chapter 16, part G to the EU FAQ, specifying the effect of the new exemption. 

Norway Implements the New Lower EU Price Cap on Russian Oil

On 5 September 2025, Norway adopted a reduced price cap on Russian crude oil, aligning domestic sanctions with the European Union's latest measures, which took effect on 3 September 2025 (our previous alert regarding these measures can be read here). This adjustment is part of a broader international effort to restrict Russia's oil revenues, which remain substantial source of funding for its war in Ukraine. The new cap sets the maximum price for Russian crude at USD 47.60 per barrel, down from the previous ceiling of USD 60.

Norway's updated regulations mirror those of the EU's 18th sanctions package and will impact both the direct trade and the provision of related services such as financing, shipping, and insurance for Russian oil sold above the cap. The measures aim to limit Russia's access to international markets and further erode its ability to finance ongoing military aggression.

The revised oil cap will be reviewed and potentially updated every six months, staying at least 15% below the average market price of Russian Urals blend, a mechanism designed to ensure continued financial pressure. Norwegian authorities underline that companies are expected to maintain clear and sufficient documentation to evidence compliance with the oil price cap. Intentional violations may result in significant consequences, including blacklisting of vessels or companies and exclusion from international markets. Actors in financial and service sectors should exercise heightened due diligence.

All bans and restrictions have been implemented through Regulation 2014-08-15-1076 ("Norwegian Ukraine Regulation"), and the amendments entered into force immediately. Further guidance on sanctions in response to Russia's military aggression against Ukraine are available on the Norwegian Directorate for Export Control and Sanctions ("DEKSA") website.