UK expands Russia sanctions and EU clarifies due diligence for tanker vessel sales

This alert summarises the key features of the expanded UK restrictions, before turning to the new EU guidance on vessel sales.

New UK Russia sanctions

An overview

On the 19 May 2026, the UK significantly expanded its sanctions regime against Russia with numerous additions and amendments to the Russia (Sanctions) (EU Exit) Regulations 2019. 

Key changes include the introduction of: 

• New restrictions on the import into the UK of refined oil products processed from Russian crude oil;
• New restrictions on the maritime transportation of liquefied natural gas;
• New restrictions on the trade of uranium into the UK or to a third country; and
• New restrictions on the provision of services to, and on the chartering or operating of, sanctioned ships;

Additional to the above, existing prohibitions on the provision of professional and business services to persons connected with Russia has been expanded to include the provision of construction services, alongside an expansion of the list of goods critical to Russia's military-industrial capabilities and economic development subject to export restrictions. Further amendments have been made to strengthen the provisions on enforcement and reporting. 

The amendments entered into effect on the 20 May 2026.

On the same date as the expansion of the Russia sanctions regime, the UK Department for Business & Trade also issued a Notice - NTI 2953: Russia import sanctions, providing an overview of the import prohibitions in force on certain goods imported into the UK, as well as specific guidance covering the import of iron and steel, and of third country processed Russian diamonds and synthetic diamonds. Additional updates have been made to the statutory guidance to the Russia sanctions. 

Due to the scope of the recent changes, we encourage all our clients with a direct or indirect exposure to UK sanctions to familiarise with the restrictions and consider whether any of the changes may be applicable to its line of business. Please note that indirect exposure likely is present through existing banking or insurance agreements, or with respect to counterparties or other third parties established in the UK.  

In the following, we will cover some of the key changes made to the regulation. 

Import of Relevant Processed Oil Products

With the introduction of the new Chapter 4IB, prohibitions apply to the import into the United Kingdom of relevant oil products processed in a third country using Russian crude oil. In a Guidance on third country processed oil product measures, the UK Department for Business & Trade explains the following reasoning behind the new restrictions:

«Third country processing may allow Russian oil to enter the UK via the ‘back door’, and this measure is targeted at addressing that and further reducing Kremlin revenues. Our approach is aligned with the EU’s to maximise the impact of these measures on Russia».

The measures target import into the UK of petroleum products (CN code 2710) that has been processed in a third country from oil or oil products (CN code 2709) originating in Russia. 

The Guidance explains that while the prohibition apply to comingling of crude oil of Russian and non-Russian origin, it is not contravened where the oil originate in another country, is not Russian owned, and has only transited through or departed from Russia, such as crude oil transported through the Caspian Pipeline Consortium, or where non-Russian crude oil has been mixed with an unpumpable quantity of substance remaining from a previous transport of Russian crude oil. 

Ancillary prohibitions apply to the provision of technical assistance, brokering services, financial services or funds, towards restricted imports.

The UK government has published the General trade licence for sanctioned processed oil products, permitting the import into the UK of jet fuels falling under CN code 2710 19 21 and diesels falling under CN codes 2710 19 42 and 2710 19 44 derived from Russian crude oil. This means that the import of jet fuel and diesel falling under said CN-codes processed from Russian crude in a third country remains permissible under the GTL.

Any person relying on the license must comply with the record-keeping obligations set out in regulation 76 of the Russia Regulations, requiring operators to maintain adequate records of all activities carried out under the licence. 

The license is of indefinite duration, though the Secretary of State may revoke it on four months' notice. 

Maritime Transportation of Russian LNG

Pursuant to the provisions set out in the new Chapter 4LA, prohibitions apply to the direct or indirect supply or delivery by ship of LNG (CN code 2711 11 00) originating in or consigned from Russia, from Russia to a third country or between third countries. 

The prohibition applies broadly to owners, charterers and operators of vessels carrying the LNG, and covers ship-to-ship transfers. Ancillary prohibitions on financial services, funds and brokering services apply under regulations 46Z29C and 46Z29D respectively.

The UK government has published a General trade licence for maritime transportation of liquefied natural gas, providing authorisation for otherwise prohibited supply and delivery, financial services and funds, and brokering services in connection with LNG that is transported from or originating at the Sakhalin-2 or Yamal LNG terminals. A condition is that the supply and delivery is conducted pursuant to a contract with a duration of one year or less, and that the LNG originate from one of the said terminals. Specific reporting obligations also apply. 

Certain exemptions to the prohibition is also set out in Regulation 60L. 

Trade restrictions on Russian uranium

The newly introduced Chapter 4KA contain prohibitions on the import and acquisition of uranium originating, consigned from or that is located in Russia into the UK, and on the supply and delivery or uranium from Russia to a third country. 

Ancillary prohibitions apply to the provision of technical assistance, brokering services, financial services and funds related to said engagements. 

Certain exemptions apply following the provisions set out in Regulation 60K.

Restrictions targeting specified vessels

The new measures also significantly expands the scope of the trade and shipping sanctions related to specified ships. 

The new regulation 57ZA prohibits chartering or operating a specified ship with knowledge of, or reasonable cause to suspect, that the ship is a specified ship. 

A much-expanded Chapter 4A now includes a comprehensive set of prohibitions against: 

1. providing technical assistance, crew services, operating services, chartering services, brokering services in relation to a specified ship;
2. providing services relating to the acquisition, sale, transfer or supply of a specified ship; and
3. procuring services relating to a specified ship, with it being further specified that this includes in particular services involving the use of that specified ship. 

Chapter 4A previously only contained a relatively narrow prohibition against providing technical assistance relating to specified aircrafts or ships «to, or for the benefit of, a designated person». The new measures captures a much wider set of services, whether or not they benefit a designated person.

Certain exemptions apply to both the new shipping and trade sanctions, including in relation to safety and emergencies. 

New EU Guidance on Vessel Sales

On 22 May 2026, the European Commission updated its Frequently Asked Questions to provide new guidance addressing the due diligence requirements and contractual obligations applicable to EU operators when selling tanker vessels to third-country buyers under Article 3q of Regulation 833/2014. The guidance is of direct relevance to shipowners, sellers and brokers involved in tanker transactions.

Article 3q prohibits EU operators from selling or transferring tanker vessels for the transport of crude oil or petroleum products (HS code ex 8901 20) directly or indirectly to any person in Russia or for use in Russia. Where a vessel is sold to a third country buyer, the seller must: (i) conduct and document due diligence on the risk of retransfer to Russia, (ii) include a «no Russia clause» in the sale contract, and (iii) notify the competent authority of the transaction. Buyers are obliged to provide all information necessary for the seller to carry out that due diligence, cf. Article 3q(3).

On due diligence, FAQ 7 clarifies that inserting a no Russia clause is not sufficient on its own – sellers must conduct prior due diligence on the buyer and the transaction. The guidance provides a non-exhaustive list of screening criteria: (i) whether the buyer has a proven business record, and, where a broker is involved, whether the ultimate owner is identifiable, (ii) the extent to which the buyer's fleet is connected to Russia, (iii) whether the transaction chain is transparent and consistent with standard industry practice, and (iv) whether any party in the chain is subject to or controlled by a sanctioned entity. Risk assessments must be documented and kept up to date, and the guidance recommends retaining all relevant due diligence documentation for at least five years.

Turning to the contractual requirements, FAQ 8 confirms that operators are free to use their own wording on the no Russia clause, provided the requirements of Article 3q(5) and (6) are met. The Commission has nonetheless published a model clause as a reference point. The model clause contains three elements: (i) a direct prohibition on resale or transfer to Russia, (ii) an obligation on the buyer to observe that prohibition in its own dealings, and (iii) a cascading obligation requiring the buyer to pass equivalent restrictions down the chain in any onward sale. Sellers are recommended to retain copies of relevant clauses and contracts for at least five years.

Finally, under Article 3q(4), EU sellers must notify the competent authority of the Member State where they are established immediately upon completing any sale to a third-party buyer. The notification must include the identities of both parties (and, where relevant, their incorporation documents including shareholding and management), the IMO ship identification number and the vessel's call sign. The competent authority must then inform the other Member States and the Commission within two weeks.