Statutory guidance

Russia sanctions: statutory guidance

Updated 25 March 2026

Introduction

This guidance is about the financial, director disqualification, trade, transport and immigration sanctions imposed by The Russia (Sanctions) (EU Exit) Regulations 2019 (‘the Regulations’).

About the Regulations

The regulations impose sanctions for the purposes of encouraging Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.

For more details see regulation 4: Purposes.

The legislation.gov.uk webpage tells you if the Regulations are up to date or if there are outstanding amendments.

You can look up amendments to the Russia Regulations made by statutory instruments. You can also view previous versions using the timeline on legislation.gov.uk and a list of the legislation that has affected the regulations.

About this guidance

As required by section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Secretary of State for Foreign, Commonwealth and Development Affairs has provided this guidance to support compliance with the Regulations.

This guidance is designed to give an overview of the prohibitions and requirements, the enforcement of these, and the circumstances in which exceptions and licences may be used. Where appropriate, it directs you to further detailed guidance to read alongside. See all updates to check this guidance is current.

1. Prohibitions and requirements

Sanctions regulations apply to: 

• any individual, business or organisation undertaking activities anywhere in the UK (including the territorial sea)
• any business or organisation incorporated or constituted under the law of any part of the UK undertaking activities anywhere in the world
• any UK national, wherever they are in the world

Accordingly, the prohibitions and requirements imposed by the regulations apply to all companies established in any part of the UK, and they also apply to branches of UK companies operating overseas.

For full details see section 21 of the Sanctions Act. 

The maritime enforcement powers contained in Part 10 of the Regulations apply in relation to British ships in international or foreign waters, ships without nationality in international waters and foreign ships in international waters.

It is prohibited to intentionally participate in any activities if you know that the object or effect of them is directly or indirectly to circumvent the prohibitions imposed by the Regulations or to enable or facilitate a breach of those prohibitions.

If you are unclear about any aspects of the Regulations, in particular about whether action you are considering taking could breach the Regulations, you are advised to seek independent legal advice.

1.1 Non-government controlled territory of Ukraine

The territorial scope of certain measures in the regulations is ‘non-government controlled Ukrainian territory’. This is defined in regulation 2 as ‘Crimea and non-government controlled areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts’.

‘Crimea’ is further defined as the Autonomous Republic of Crimea and the City of Sevastopol.

1.2 Designation of persons

Designation of persons provisions are contained in Part 2 of the Regulations.

The regulations provide that the Secretary of State may designate persons by name for the purposes of the financial and/or director disqualification and/or immigration and/or aircraft and/or shipping and/or internet services sanctions if they are, or have been, involved in a relevant activity (as defined in regulation 6 of the Russia (Sanctions) (EU Exit) Regulations 2019 (as amended)).

The regulations also make provision for the Secretary of State to provide that persons of a specified description are designated persons for the purposes of the financial and/or immigration and/or aircraft and/or shipping and/or internet services sanctions.

The UK Sanctions List contains the names of all designated persons (DPs) and the sanctions that have been imposed on them. Checking the UK Sanctions List is an essential part of due diligence for many firms and other organisations.

1.3 Specification of ships

Specification of ships provisions are contained in Part 6 of the Regulations.

The regulations provide that the Secretary of State may specify a ship for the purposes of shipping sanctions if the ship is, has been, or is likely to be, involved in a relevant activity (as defined in regulation 57F of the Russia (Sanctions) (EU Exit) Regulations 2019 (as amended)).

The regulations also provide that the Secretary of State must specify a ship by its International Maritime Organization number or, where it is not reasonably practicable to identify it by that number, by any other means that the Secretary of State considers appropriate.

The UK Sanctions List provides details of the ships specified under the regulations, and details of the sanctions in respect of which they have been specified.

The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2024

These regulations came into force on 31 July 2024. They amend regulation 57F (specification of ships) so that a ship may be specified for any activity whose object or effect is to:  

• destabilise Ukraine or undermine or threaten the territorial integrity, sovereignty, or independence of Ukraine, or to
• obtain a benefit from or support the Government of Russia

This includes, but is not limited to, carrying military or dual-use goods from a third country to Russia, as well as oil or oil products that originated in Russia. Ships specified under Regulation 57F will be subject to ‘shipping sanctions’, namely measures in regulations 57A to 57E. Where shipping sanctions apply, a specified ship:  

• is prohibited from entering a port in the UK
• may be given a movement or a port entry direction
• can be detained, and
• will be refused permission to register on the UK Ship Register or have its existing registration terminated

These regulations also amend regulation 6 (designation criteria) to include additional activities for which a person may designated, namely:  

• providing financial services, or making available funds, economic resources, goods or technology to persons involved in obtaining a benefit from or supporting the Government of Russia (as defined in the Regulations); and
• owning or controlling directly or indirectly, or working as a director, trustee, other manager or equivalent of a person, other than an individual, involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine

The former expands the criteria under the Regulations to designate entities, including foreign financial institutions that facilitate transactions on behalf of, or in support of, specified sectors of strategic significance to the Government of Russia. This in line with G7 commitments to further curtail Russia’s use of the international financial system which Russia is using to facilitate its war in Ukraine. 

An explanatory memorandum accompanies the regulations, providing further information on their provisions.

1.4 Financial sanctions

Financial sanctions provisions are contained in Part 3 of the Regulations.

Asset freeze and making available provisions

The Regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly.

These prohibitions also apply in relation to entities owned or controlled by a designated person.

If you find out that a person or organisation you are dealing with is subject to the financial sanctions detailed in the Regulations, you must immediately:

• stop dealing with them
• freeze any assets you are holding for them
• inform OFSI as soon as possible

The Office of Financial Sanctions Implementation (OFSI) is the authority responsible for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK. See more about how OFSI implements financial sanctions.

Other financial and investment restrictions

The regulations prohibit a person from directly or indirectly dealing with a transferable security or money market instrument if it has a maturity exceeding 30 days, and was issued after 1 August 2014 by:

• Sberbank, VTB bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank (as listed in Schedule 2)
• an entity incorporated or constituted in a country other than the UK which is owned by one or more of the 5 banks listed above
• an entity acting on behalf of or at the direction of those 5 banks named above or an entity incorporated or constituted in a country other than the UK which is owned by one or more of those 5 banks

It is also prohibited for a person to directly or indirectly deal with a transferable security or money market instrument if it has a maturity exceeding 30 days, and was issued after 12 September 2014 by:

• OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft or Gazprom Neft (as listed in Schedule 2)
• an entity incorporated or constituted in a country other than the UK which is owned by one or more of the 6 entities listed above
• an entity acting on behalf of or at the direction of those 6 entities named above or an entity incorporated or constituted in a country other than the UK which is owned by one or more of those 6 entities

It is prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued on or after 1 March 2022 by:

• an entity incorporated or constituted under the law of the UK and owned by one or more of the entities listed in Schedule 2
• an entity acting on behalf or at the direction of the above

It is prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued on or after 1 March 2022 by:

• a person connected with Russia (this is defined in regulation 19A(2), and is subject to the exclusions in regulation 16(4D)(a))
• an entity owned by such persons
• an entity acting on behalf or at the direction of any of the above

It is prohibited for a person to directly or indirectly deal with a transferable security or money market instrument if it was issued:

• on or after 15 December 2022
• by a relevant entity (i.e. a person who is not a person connected with Russia)
• for the purposes of making an investment in relation to Russia (see below)

It is also prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument which was issued on or after 1 March 2022 by the Government of Russia (as defined in regulation 6).

Loan and credit arrangements

The regulations prohibit a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit, with a maturity exceeding 30 days to:

• the entities listed in Schedule 2
• an entity which is incorporated or constituted under the law of a non-UK country and owned by one or more of the entities listed in Schedule 2, or an entity acting on behalf of or at the direction of either that entity or an entity listed in Schedule 2
• an entity which is incorporated or constituted under the law of the UK and owned by an entity listed in Schedule 2, on or after 1 March 2022
• a person connected with Russia (this is defined in regulation 19A(2), and is subject to the exclusions in regulation 17(5))

The regulations prohibit granting a new loan or credit arrangement to a relevant entity for the purposes of making an investment in relation to Russia.

The regulations prohibit a person from providing funds to a relevant entity where the purpose of making those funds or economic resources available is to enable a relevant entity to grant a loan that is otherwise prohibited under regulation 17.

The regulations also prohibit a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit to the Government of Russia (as defined in regulation 6), on or after 1 March 2022.

Correspondent banking relationships and sterling payments

The Regulations prohibit a UK credit or financial institution from establishing or continuing a correspondent banking relationship with a designated person (or a credit or financial institution which is owned or controlled by such a designated person). In this context, a ‘designated person’ is a person designated for the purposes of regulation 17A.

The Regulations also prohibit a UK credit or financial institution from processing a payment (in any currency) to, from or via, a designated person, or a credit or financial institution owned or controlled by a designated person.

The Regulations make clear that, for the purposes of the prohibition in regulation 17A(2), processing does not include the initial crediting of a payment to an account which is in the name of a UK credit or financial institution (and not in the name of a customer).

Investments in relation to non-government controlled Ukrainian territory

The Regulations prohibit:

• directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in land located in non-government controlled Ukrainian territory
• directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in an entity which has a place of business located in non-government controlled Ukrainian territory (‘a relevant entity’)
• directly or indirectly granting any loan or credit, entering into any arrangement to grant a loan or credit or otherwise provide funds, including equity capital, to a relevant entity or for the purpose of financing the relevant entity
• directly or indirectly establishing any joint venture in non-government controlled Ukrainian territory or with a relevant entity
• providing investment services directly related to the activities referred to in the 4 bullet points above

Provision of financial services for the purpose of foreign exchange reserve and asset management

The Regulations prohibit a UK individual or entity from providing financial services for the purpose of foreign exchange reserve and asset management to:

• the Central Bank of the Russian Federation
• the National Wealth Fund of the Russian Federation
• the Ministry of Finance of the Russian Federation
• a person owned or controlled directly or indirectly by any of the persons above; or
• a person acting on behalf of or at the direction of any of the persons above

‘Foreign exchange reserve and asset management’ means activities relating to the reserves or assets of the persons listed above. Such reserves or assets include money market instruments (including cheques, bills and certificates of deposit); foreign exchange; derivative products (including futures and options); exchange rate and interest rate instruments (including products such as swaps and forward rate agreements); transferable securities; other negotiable instruments and financial assets (including bullion, such as gold); and special drawing rights. For example, it is prohibited to provide financial services to carry out transactions with the Central Bank of the Russian Federation involving its gold.

Investments in relation to Russia

The Regulations prohibit:

• direct acquisition of any ownership interest in Russian land and persons connected with Russia
• indirect acquisition of any ownership interest in Russian land and persons connected with Russia for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia
• direct or indirect acquisition of any ownership interest in entities (which are not persons connected with Russia) for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia
• establishing joint ventures with a person connected with Russia
• opening representative offices and establishing branches and subsidiaries in Russia; or
• the provision of investment services directly related to all activities above

Trust services

The Regulations prohibit:

• the provision of trust services to or for the benefit of persons designated for the purposes of this measure, and
• the provision of trust services to or for the benefit of persons connected with Russia unless those services were provided immediately prior to the day the regulations come into force pursuant to an arrangement that has effect at that time

‘Trust services’ means:

• the creation of a trust or similar arrangement
• the provision of a registered office, business address, correspondence address or administrative address for a trust or similar arrangement
• the operation or management of a trust or similar arrangement
• acting or arranging for another person to act as trustee of a trust or similar arrangement
• acting as a nominee shareholder

Trust services are provided ‘for the benefit of’ where the person (‘P’):

• is a beneficiary of a trust or similar arrangement,
• is a potential beneficiary in a document from the settlor relating to a trust or similar arrangement (such as a letter of wishes), or
• having regard to all the circumstances, P might reasonably be expected to obtain, or be able to obtain, a significant financial benefit from the trust or similar arrangement

‘Beneficiary’, ‘potential beneficiary’ and ‘settlor’, in relation to an arrangement similar to a trust, means those individuals who hold equivalent or similar positions to those described in the sub-paragraphs above in respect of a trust.

Suspension of Banking Act 2009 requirement to recognise third-country resolution actions

The regulations disapply the Bank of England’s statutory duty under section 89H(2) of the Banking Act 2009 to make a decision in respect of recognition notifications from third-country resolution authorities where:

• the resolved bank or financial institution is a designated person subject to an asset freeze; or
• the resolved bank or financial institution is owned or controlled directly or indirectly by such a designated person

This means that the Bank of England will not make a decision under section 89(H)(2), that is to recognise, partially recognise or refuse to recognise a third-country resolution action, for as long as the resolved institution in question is designated as subject to an asset freeze or is owned or controlled directly or indirectly by a person who is designated as subject to an asset freeze under the Russia Regulations.

1.5 Director disqualification sanctions  

Director disqualification provisions are contained in Part 3A of the Regulations.

Persons designated under regulation 5 for the purpose of director disqualification sanctions under regulation 19B are disqualified from:

• being a director of a UK company
• directly or indirectly taking part in or being concerned in the promotion, formation or management of a UK company
• being a director of a foreign company that has sufficient connection to the UK, even if it is not registered, for example, if it carries out business or has assets in the UK

under the provisions of:

• section 11A of the Company Directors Disqualification Act 1986 (CDDA)
• Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 (CDD(NI)O)

Companies House and the Department for the Economy (Northern Ireland) are responsible for recording information about director disqualification sanctions in their respective Disqualified Director Registers. Companies House is responsible for annotating the Companies Register and preventing registration of a disqualified director’s appointments.

See more information about director disqualification sanctions.

1.6 Trade sanctions

Trade sanctions provisions are contained in Part 5 of the Regulations.

The regulations impose trade prohibitions relating to:

• military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
• anything which falls within Chapter 93 of the Goods Classification Table, other than military goods (as specified in Chapter 2 of Part 5 regulation 23)
• defence and security goods and defence and security technology (as specified in Schedule 3C to the Regulations and including interception and monitoring goods and interception and monitoring technology)
• dual-use goods and technology (as specified in Annex I to Council Regulation 428/2009 as retained by the European Union (Withdrawal) Act 2018 (‘the Dual-Use Regulation’))
• special materials and related equipment and materials processing (as specified in Parts 1A and 1B of Schedule 2A to the Regulations)
• critical-industry goods and technology (as specified in Schedule 2A to the Regulations)
• quantum computing and advanced materials goods and technology (as specified in Schedule 2E to the Regulations)
• aviation and space goods and technology (as specified in Schedule 2C to the Regulations)
• jet fuel and fuel additives (as specified in Part 8 of Schedule 2A to the Regulations)
• maritime goods and maritime technology (defined by reference to Chapter 4 (Navigation Equipment) and Chapter 5 (Radio-Communication Equipment) of Annex 1 of Merchant Shipping Notice 1874(a))
• infrastructure-related goods (as specified in Part 3 of Schedule 3 to the Regulations)
• energy-related goods and technology (as specified in Part 2 of Schedule 3 to the Regulations) and energy-related services (as specified in chapter 4 of Part 5 of the Regulations)
• oil refining goods and technology (as specified in Schedule 2D to the Regulations)
• luxury goods (as specified in Schedule 3A to the Regulations)
• G7 dependency and further goods and technology (as specified in Schedule 3E to the Regulations)
• goods originating in non-government controlled Ukrainian territory (as specified in Chapter 5 of Part 5 of the Regulations)
• iron and steel products (as specified in Schedule 3B to the Regulations)
• iron and steel products processed in a third country (as specified in Part 1, 2 and 3 of Schedule 3B to the Regulations)
• metals (as specified in Schedule 3BA to the Regulations)
• oil and oil products (as specified in Schedule 3F of the Regulations)
• the supply or delivery by ship of oil and oil products under the commodity codes 2709 and 2710 from Russia to and between third countries and related services (as specified in Schedule 3F of the Regulations)
• coal and coal products (as specified in Schedule 3H to the Regulations)
• liquefied natural gas (as specified in Chapter 4L of the Regulations)
• gold, gold jewellery and products related to gold (as specified in Schedule 3G to the Regulations)
• banknotes denominated in sterling and any official currency of the European Union (as specified in Schedule 3A to the Regulations)
• goods which generate significant revenues for Russia (as specified in Schedule 3D and Schedule 3DA to the Regulations)
• diamonds and diamond jewellery (as specified in Schedule 3GA to the Regulations)
• certain natural diamonds processed in third countries (as specified in Chapter 4JC of Part 5 of the Regulations)
• certain synthetic diamonds processed in third countries (as specified in Chapter 4JD of Part 5 of the Regulations)
• Russia’s vulnerable goods and technology (as specified in Schedule 3I to the Regulations)
• sectoral software and technology (as specified in Schedule 3IA to the Regulations)
• provision of technical assistance, armed personnel, financial services or funds, or associated brokering services where such provision enables or facilitates the conduct of certain military activities (as specified in Chapter 2 of Part 5 of the Regulations, regulation 30)
• services relating to a relevant infrastructure sector in non-government controlled Ukrainian territory (as specified in Chapters 5 and 6 of Part 5 of the Regulations)
• services relating to tourism in non-government controlled Ukrainian territory (as specified in Chapter 6 of Part 5 of the Regulations)
• internet services (as specified in Chapter 6A of Part 5 of the Regulations)
• professional and business services (as specified in Chapter 6B of Part 5 of the Regulations)

Further guidance is provided on some of these prohibitions.

Technical Guidance on interception and monitoring

complying with sectoral software sanctions.

Complying with technology transfer santions.

There are circumstances (set out in the relevant lists of controlled items) in which certain items are not controlled, for example when body armour or a helmet is accompanying a person for that person’s own protection. Please check the relevant lists as applicable.

Energy-related goods, infrastructure-related goods, aviation and space goods, oil refining goods, G7 dependency and further goods, luxury goods, iron and steel products, metals, revenue generating goods, Russia’s vulnerable goods, coal and coal products, oil and oil products, gold and diamonds are identified by reference to commodity codes in the Goods Classification Table. The UK Tariff sets out a system for the classification of goods for importers to ascertain the applicable rate of import duty for their goods. It is this system of classification that is used in the regulations in order to determine whether these goods are within scope of the prohibitions.

This means that where commodity codes are used in the regulations, the relevant goods are those which would be classified under the relevant commodity code (applying the rules in the UK Tariff) if the goods were being imported to the UK.

Some of the listings of commodity codes in the regulations have an ‘ex’ before the code. Where this ‘ex’ appears before a commodity code this means the prohibitions in the regulations do not apply to all of the items under that commodity code. The prohibitions will only apply to those items that (1) would be classified under the commodity code and (2) match the description given next to the relevant ‘ex’ code entry in the regulations.

European Union sanctions measures that pertain to the import and export of goods automatically apply in Northern Ireland. Traders should refer to the UK Integrated Online Tariff and the Northern Ireland Integrated Online Tariff to confirm what import duties apply in Northern Ireland. EU import and export restrictions on goods are detailed in Council Regulations (EU) No 833/2014 as amended from time to time. Be sure to consider the most recently updated version of that regulation.

Further detail on these trade prohibitions, including key terminology used, is explained below. The Regulations contain full definitions of all terms.

Export of goods

The concept of ‘export’ is set out in customs legislation, but is further detailed in Paragraph 32 of Schedule 1 to the Sanctions Act,. This clarifies that ‘export’ means export from the UK but does not capture where goods are removed to the Isle of Man from the UK. For the purposes of Chapter 4JA (gold jewellery and relevant processed gold), the concept of ‘export’ refers to export from Russia, which is defined within the chapter itself.

The following regulations prohibit the export of certain good to Russia as well as exports that are for use in Russia. This means that even if the immediate destination is not Russia, the prohibition may still apply.

• Regulation 22 (relating to restricted goods)
• Regulation 40 (relating to energy-related goods)
• Regulation 46B (relating to luxury goods)
• Regulation 46L (relating to bank notes)
• Regulation 46N (relating to jet fuel and fuel additives)
• Regulation 46Y (relating to G7 dependency and further goods)
• Regulation 46Z30 (relating to Russia’s vulnerable goods)

Prohibitions in regulation 46B (relating to luxury goods) apply a ‘sales price’ threshold, which means that a product is captured by the regulations according to the price of the item or a quantity specified excluding value added taxes but including freight/transport costs. These are set out in Part 2 of Schedule 3A (Luxury Goods).

Regulation 22 prohibits the export of maritime goods for the placing on bard of a Russian-flagged vessel.

The export prohibitions in Chapter 2A and Chapter 5 prohibit certain exports to and for use in non-government controlled Ukraine territory. this means that even if the immediate destination is not non-governmental controlled Ukraine territory, the prohibition may still apply.

The goods that are captured by these regulations are outlines by their commodity code in the schedules to the Regulations.

Exporters should check the ultimate end use of goods and may apply for a licence or contact the Export Control Joint Unit (ECJU) if they know or think the items may be used in Russia or in non-government controlled Ukrainian territory.

A sanctions licence is not required for exports of non-military goods covered by the regulations from Northern Ireland to an EU Member State where the final destination is Russia or non-government controlled Ukrainian territory (as applicable). You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to Russia or non-government controlled Ukrainian territory. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.

Import of goods

The concept of ‘import’ is set out in customs legislation but is further detailed in Paragraph 33 of Schedule 1 to the Sanctions Act. This clarifies in particular that goods removed to the UK from the Isle of Man are not to be regarded as imported. Paragraph 34 details limited exceptions to this.

The following regulations prohibit the import of certain goods that are consigned from Russia and goods that originated in Russia. This mean that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply:

• Regulation 23 (relating to arms and related materiel)
• Regulations 46D and 46IB (relating to iron and steel products)
• Regulation 46IG (relating to metals)
• Regulations 46S and 46XB (relating to Schedule 3D and 3DA revenue generating goods)
• Regulation 46Z4 (relating to oil and oil products)
• Regulation 46Z18 (relating to coal and coal products)
• Regulation 46Z16K (relating to diamonds and diamond jewellery)
• Regulation 46Z25 (relating to liquefied natural gas)

Regulation 46Z11 (Chapter 4J) prohibits the import of gold that originated in Russia, where exported from Russia on or after 21 July 2022. This means that even if the immediate place the goods were shipped from or processed in was not Russia, the prohibition may still apply .

The import prohibition in regulation 46Z16C (Chapter 4JA) prohibits the import of processed gold, defined as gold (Part 2 of Schedule 3G) that has been processed in a third country and incorporates gold that, on or after 21 July 2022, originated in and has been exported from Russia. This means that even if the immediate place the goods were shipped from or processed in was not Russia, the prohibition may still apply if the goods incorporate gold that originated in and has been exported from Russia on or after 21 July 2022.

The import prohibitions in regulation 46Z16B (Chapter 4JA) prohibit the import of gold jewellery (Part 3 of Schedule 3G) that originates in Russia, where this is exported from Russia on or after 29 October 2022. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply if the Russian origin gold jewellery was exported from Russia on or after 29 October 2022.

Therefore, importers should check the original place goods were consigned or exported from and apply for a licence or contact DBT’s Import Sanctions Team if they think the items may have originated in or have been consigned from Russia or non-government controlled Ukrainian territory.

A sanctions licence is not required for imports from an EU Member State into Northern Ireland of non-military goods covered by the regulations which originate in or are consigned from Russia or non-government controlled Ukrainian territory (as applicable). You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the original import into the customs territory of the EU. You will also have to comply with any other licensing requirements under UK import control legislation as applicable.

The import prohibition in regulation 46IA and 46IB (Chapter 4CA) on relevant iron and steel products processed in third countries which incorporate relevant iron and steel products of Russian origin applied from 30 September 2023. Please refer to the Notice for Importers for specific guidance on the scope of the measure, and how businesses can demonstrate compliance.

The import prohibition in regulation 46Z16R (Chapter 4JC) on certain natural diamonds which were mined in Russia and have been processed in third countries applies from 1 March 2024 for diamonds larger than or equal to 1 carat or 0.2 grams (or equivalent) in weight. From 1 September 2024 it applies to certain mined diamonds larger than or equal to 0.5 carats or 0.1 grams (or equivalent) in weight. Please refer to the Notice for Importers for specific guidance on the scope of the measure and how business can demonstrate compliance.

The import prohibition in regulation 46Z16W (Chapter 4JD) on certain synthetic diamonds which were manufactured in Russia and processed in third countries applies from 24 April 2025 for synthetic diamonds larger than or equal to 0.5 carats or 0.1 grams (or equivalent) in weight. Please refer to the Notice for Importers for the specific guidance on the scope of the measure and how business can demonstrate compliance.

The import prohibition in regulation 47 covers imports of goods which originated in non-government controlled Ukrainian territory. This means that even if the immediate place the goods were shipped from was not non-government controlled Ukrainian territory, the prohibition may still apply.

Goods in transit

The import prohibitions specified in the Russia Sanctions Regulations prohibit the import, acquisition, and supply and delivery of certain products, as well as the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition or supply and delivery of those products.

These cover goods that are consigned from, are located in or originate in Russia, as applicable under the relevant regulations. This means that even if the initial point from which the goods were shipped was not Russia, the prohibition may still apply.

The prohibitions may apply even if the products are not of Russian origin and even if transiting through Russian territory is part of a complete journey where the start and end point is not Russia.

Supply and delivery of goods

The regulations include prohibitions on the direct or indirect supply or delivery of certain goods from a third country to a place in Russia, or from a place in Russia to a third country (other than those in Chapter 2A and Chapter 5 which apply to non-governmental controlled Ukraine territory).

The following regulations prohibit the direct or indirect supply or delivery of certain goods from a third country to a place in Russia:

• Regulation 24 (relating to restricted goods)
• Regulation 41 (relating to energy-related goods)
• Regulation 46B (relating to luxury goods)
• Regulation 46N (relating to jet fuel and fuel additives)
• Regulation 46Y (relating to G7 dependency and further goods)
• Regulation 46Z9B (relating to maritime transportation of certain oil and oil products to and between third countries)
• Regulation 46Z30 (relating to Russia’s vulnerable goods)

Regulation 22 prohibits the direct or indirect supply or delivery of maritime goods from a third country for the placing on board a Russian-flagged vessel.

The following regulations prohibit the direct or indirect supply or delivery of certain goods from a place in Russia to a third country:

• Regulation 24 (relating to restricted goods)
• Regulation 46F (relating to iron and steel products)
• Regulation 46II (relating to metals)
• Regulation 46XD (relating to Schedule 3DA revenue generating goods)
• Regulation 46Z9B (relating to maritime transportation of certain oil and oil products to and between third countries)
• Regulation 46Z16M (relating to diamonds and diamond jewellery)

Regulation 30C prohibits the direct or indirect supply or delivery of relevant restricted goods from a third country to a place in non-government controlled Ukrainian territory.

Regulation 49 prohibits the direct or indirect supply or delivery of infrastructure-related goods from a third country to a place in non-governmental controlled Ukrainian territory.

Regulations 24(4) and 41(4) specify that for the purposes of those prohibitions a ‘third country’ is a country that is not the UK, Isle of Man or Russia. Regulation 49(4) specifies that for the purposes of that prohibition a ‘third country’ is a country that is not the UK, Isle of Man or non-government controlled Ukrainian territory.

Making available or acquiring goods, technology and software

The regulations also include prohibitions on making certain goods, technology or software available directly or indirectly for use in Russia or to ‘a person connected with Russia’ (other than those in Chapter 2A and Chapter 5 which apply to non-government controlled Ukrainian territory).

Regulation 21 sets out when a person is to be regarded as ‘connected with’ Russia as:

• an individual who is, or an association or combination of individuals who are, ordinarily resident in Russia
• an individual who is, or an association or combination of individuals who are, located in Russia
• a person, other than an individual, which is incorporated or constituted under the law of Russia, or
• a person, other than an individual, which is domiciled in Russia

Regulation 21 also sets out when a person is to be regarded as ‘connected with’ non-governmental controlled Ukrainian territory as:

• an individual who is, or an association or combination of individuals who are, ordinarily resident in non-government controlled Ukrainian territory
• an individual who is, or an association or combination of individuals who are, located in non-government controlled Ukrainian territory, or
• a person, other than an individual, which has its registered office, central administration or principal place of business located in non-government controlled Ukrainian territory

The following regulations prohibit making sanctioned goods, technology and software available for use in Russia or to a ‘person connected with Russia’ in:

• Regulation 25 (relating to restricted good and technology)
• Regulation 42 (relating to energy-related goods and technology)
• Regulation 46B (relating to luxury goods)
• Regulation 46L (relating to banknotes)
• Regulation 46N (relating to jet fuel and fuel additives)
• Regulation 46Y (relating to G7 dependency and further goods and technology)
• Regulation 46Z30 (relating to Russia’s vulnerable goods and technology)
• Regulation 46Z34 (relating to sectoral software and technology)

Regulation 30D prohibits making restricted goods and technology for use in non-government controlled Ukrainian territory or to a ‘person connected with non-government controlled Ukrainian territory’.

Regulation 50 prohibits making infrastructure-related goods available including directly or indirectly making them available for use in non-government controlled Ukrainian territory or to a ‘person connected with non-government controlled Ukrainian territory’.

The following regulations prohibit directly or indirectly acquiring certain goods or technology which originate in Russia, or which are located in Russia with the intention of these goods entering the United Kingdom:

• Regulation 46T, Schedule 3D (relating to revenue generating goods)
• Regulation 46Z5 (relating to oil and oil products)
• Regulation 46Z19 (relating to coal and coal products)
• Regulation 46Z26 (relating to liquified natural gas)

The following regulations prohibit the direct or indirect acquisition of certain goods which originate in Russia, or which are located in Russia, regardless of whether the person acquiring them intends to bring the goods into the United Kingdom:

• Regulation 46E (relating to iron and steel products)
• Regulation 46IH (relating to metals)
• Regulation 46XC of (relating to Schedule 3DA revenue generating goods)
• Regulation 46Z16L (relating to diamonds and diamond jewellery)
• Regulation 46E (relating to iron and steel products)

There is also a prohibition on the acquisition of gold (regulation 46Z12) and gold jewellery (regulation 46Z16D), which originated in and is located in Russia with the intention of those goods entering the United Kingdom.

Transfer of technology

Some prohibitions in the regulations apply to the transfer of certain technology to a place in Russia or a person ‘connected with Russia’.

The following regulations prohibit the transfer of technology related to goods or software sanctioned in their corresponding chapters:

• Regulation 26 (relating to restricted technology)
• Regulation 42A (relating to energy -related technology)
• Regulation 46YA (relating to G7 dependency and further technology)
• Regulation 46Z30A (relating to Russia’s vulnerable technology)
• Regulation 46Z35 (relating to sectoral software and technology)

‘Transfer’ is defined in Paragraph 37 of Schedule 1 to the Sanctions Act.

‘Technology’ is defined differently depending on the type of technology and where it is captured in the Regulations.

• Restricted goods and technology under regulation 26 that are subject to export controls take the definition of ‘technology’ found in Part 1, Paragraph 2 of the Export Control Order 2008
• Any other restricted technology under regulation 26 take the definition of ‘technology’ found in the General Technology Note of Annex I to the Dual Use Regulation (2009).
• Technologies captured by regulations 42A, 46YA, 46Z30A and 46Z35 are defined in Paragraph 37 of Schedule 1 to the Sanctions Act.

Guidance has been produced on:

exporting military or dual-use technology.

complying with sectoral software sanctions.

Complying with technology transfer santions.

Where technology is contained within a good, the good itself would be classified, as a good under the accompanying goods-related provisions. This includes goods such as USB memory devices, laptops and tablets and the like.

It is prohibited to provide services ancillary to the export of sanctions goods as well as to any technology related to them (see technical assistance, financial services and brokering services sections below).

Guidance has been produced on technology transfer and sectoral software sanctions.

Technical assistance

The term ‘technical assistance’ in relation to goods or technology is defined in regulation 21, which states that it means:

• technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or
• any other technical service relating to the goods or technology

Prohibitions apply where the technical assistance relates to certain specified goods or technology.

The prohibitions apply to the direct or indirect provision of such technical assistance in relation to goods covered by an export prohibition (1) to persons ‘connected with Russia’ or (2) for use in Russia, except those in Chapter 5 which apply where the provision applies (1) to persons ‘connected with non-government controlled Ukrainian territory’ or (2) for use in non-government controlled Ukrainian territory.

This means that, even if the person to whom you are providing the relevant technical assistance is not in or ‘connected with Russia’ (or non-government controlled Ukrainian territory, for Chapters 2A and 5), the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Russia (or non-government controlled Ukrainian territory, for Chapters 2A and 5). Therefore, if you are providing technical assistance, you should check whether the goods or technology may be used in Russia or non-government controlled Ukrainian territory, as appropriate, and apply for a licence or contact ECJU if so.

Regulation 46A prohibits the direct or indirect provision of technical assistance to or for the benefit of persons designated for the purpose of this regulation, where that assistance relates to an aircraft or ship. The persons designated for the purposes of this provision are set out in the UK Sanctions List under ‘sanctions imposed’.

The prohibition applies in relation to any aircraft or ship. You should carry out your own checks to determine to whom, or for whose benefit, you are providing technical assistance related to aircraft or ships.

In relation to goods covered by prohibitions on import, [supply and delivery or acquisition], the measures apply to the direct or indirect provision of technical assistance relating to the import, [supply and delivery] or acquisition of the prohibited goods.

The following regulations prohibit the direct or indirect provision of technical assistance to specific arrangements:

• Regulation 27 (relating to restricted goods and restricted technology)
• Regulation 30F (relating to relevant restricted goods and relevant restricted technology in relation to non-government controlled Ukrainian territory)
• Regulation 43 (relating to energy-related goods and technology)
• Regulation 46A (relating to aircraft and ships)
• Regulation 46BA (relating to luxury goods)
• Regulation 46G (relating to iron and steel products)
• Regulation 46IC (relating to relevant processed iron and steel products)
• Regulation 46O (relating to jet fuel and fuel additives)
• Regulation 46V (relating to Schedule 3D revenue generating goods)
• Regulation 46XE (relating to Schedule 3DA revenue generating goods)
• Regulation 46Z (relating to G7 dependency and further goods and technology)
• Regulation 46Z7 (relating to oil and oil products)
• Regulation 46Z14 (relating to gold)
• Regulation 46Z16E (relating to gold jewellery)
• Regulation 46Z16F (relating to relevant processed gold)
• Regulation 46Z16N (relating to diamonds and diamond jewellery)
• Regulation 46Z16S (relating to certain natural diamonds processed in a third country)
• Regulation 46Z16X (relating to certain synthetic diamonds processed in a third country)
• Regulation 46Z21 (relating to coal and coal products)
• Regulation 46Z27 (relating to liquefied natural gas)
• Regulation 46Z31 (relating to Russia’s vulnerable goods and technology)
• Regulation 46Z364 (relating to sectoral software and technology)
• Regulation 51 (relating to infrastructure-related goods in relation to non-government controlled Ukrainian territory)

Financial services and funds related to goods and technology

‘Financial services’ refers to any services of a financial nature in many different forms including insurance and banking. Financial services include payment and money transmission services. The full definition of ‘financial services’ can be found in Section 61 of the Sanctions Act.

‘Funds’ means financial assets and benefits of every kind, including cash, securities and interest. The full definition of ‘funds’ can be found in Section 60 of the Sanctions Act.

Trade sanctions prohibitions on the provision of financial services and funds apply where they relate to certain specified goods or technology.

The prohibitions in the regulations apply to the direct or indirect provision of financial services, and the direct or indirect making available of funds to persons connected with Russia (or non-government controlled Ukrainian territory, in respect of Chapters 2A and 5).

These prohibitions also prohibit the direct or indirect provision of financial services or funds in pursuance of or in connection with specific arrangements involving Russia (or non-government controlled Ukrainian territory in respect of Chapters 2A and 5).

The following regulations prohibit the direct or indirect provision of financial services to specific arrangements:

• Regulation 28 (relating to restricted goods and restricted technology)
• Regulation 30G (relating to relevant restricted goods and relevant restricted technology in relation to non-government controlled Ukrainian territory)
• Regulation 44 (relating to energy-related goods and technology)
• Regulation 46BB (relating to luxury goods)
• Regulation 46H (relating to iron and steel products)
• Regulation 46ID (relating to relevant processed iron and steel products)
• Regulation 46P (relating to jet fuel and fuel additives)
• Regulation 46W (relating to Schedule 3D revenue generating goods)
• Regulation 46XF (relating to Schedule 3DA revenue generating goods)
• Regulation 46Z1 (relating to G7 dependency and further goods and technology)
• Regulation 46Z8 (relating to oil and oil products)
• Regulation 46Z9C (relating to maritime transportation of certain oil and oil products)
• Regulation 46Z15 (relating to gold)
• Regulation 46Z16G (relating to gold jewellery)
• Regulation 46Z16H (relating to relevant processed gold)
• Regulation 46Z16O (relating to diamonds and diamond jewellery)
• Regulation 46Z16T (relating to certain natural diamonds processed in a third country)
• Regulation 46Z16Y (relating to certain synthetic diamonds processed in a third country)
• Regulation 46Z22 (relating to coal and coal products)
• Regulation 46Z28 (relating to liquefied natural gas)
• Regulation 46Z32 (relating to Russia’s vulnerable goods and technology)
• Regulation 46Z374 (relating to sectoral software and technology)
• Regulation 52 (relating to infrastructure-related goods in relation to non-government controlled Ukrainian territory)

Brokering services

The definition of ‘brokering services’ is set out in regulation 21, which states that it means any service to secure, or otherwise in relation to, an arrangement, including (but not limited to):

• the selection or introduction of persons as parties or potential parties to the arrangement
• the negotiation of the arrangement
• the facilitation of anything that enables the arrangement to be entered into, and
• the provision of any assistance that in any way promotes or facilitates the arrangement

The regulations prohibit the direct or indirect provision of brokering services where they relate to specific arrangements. Those arrangements are set out in:

• Regulation 29 (non-UK activity relating to restricted goods and restricted technology)
• Regulation 30H (non-UK activity relating to the non-government controlled Ukrainian territory limited goods and non-government controlled Ukrainian territory limited technology)
• Regulation 45 (non-UK activity relating to energy-related goods and technology)
• Regulation 46BC (relating to luxury goods)
• Regulations 46I and 46IE (relating to iron and steel products)
• Regulation 46Q (relating to jet fuel and fuel additives)
• Regulation 46X (relating to Schedule 3D revenue generating goods)
• Regulation 46XG (relating to Schedule 3DA revenue generating goods)
• Regulation 46Z2 (relating to G7 dependency and further goods and technology)
• Regulation 46Z9 (relating to oil and oil products)
• Regulation 46Z9D (relating to maritime transportation of certain oil and oil products)
• Regulation 46Z16 (relating to gold)
• Regulation 46Z16I (relating to gold jewellery and relevant processed gold)
• Regulation 46Z16P (relating to diamonds and diamond jewellery)
• Regulation 46Z16U (relating to certain natural diamonds processed in a third country)
• Regulation 46Z16Z (relating to certain synthetic diamonds processed in a third country)
• Regulation 46Z23 (relating to coal and coal products)
• Regulation 46Z29 (relating to liquefied natural gas)
• Regulation 46Z33 (relating to Russia’s vulnerable goods and technology)
• Regulation 46Z38 (relating to sectoral software and technology)
• Regulation 53 (non-UK activity relating to infrastructure-related goods and goods from non-government controlled Ukrainian territory)

Other service provisions

Certain other services are prohibited in the regulations. These include the provision of certain services which enable or facilitate certain military activities, insurance and reinsurance services, energy-related services, infrastructure-related services, tourism-related services, internet services, other professional and business services, which in the regulations refers to accounting, advertising, architectural, auditing, business and management consulting, engineering, IT consultancy and design, public relations services, and legal advisory services.

As set out in regulation 30, the direct or indirect provision of the following services is prohibited where such provision enables or facilitates the conduct of military activities carried on or proposed to be carried on by the Russian military or any other military end-user who is a person connected with Russia:

• technical assistance
• armed personnel
• financial services or funds, or
• brokering services in relation to an arrangement whose object or effect is to provide, in a non-UK country, any of the services mentioned in the points above

Provisions on insurance and reinsurance services are set out in regulation 29A and prohibit the direct or indirect provision of insurance and reinsurance services where it relates to aviation and space goods and aviation and space technology.

The prohibitions apply to the direct or indirect provision of insurance and reinsurance services (1) to persons ‘connected with Russia’ or (2) for use in Russia. This means that, even if the person to whom you are providing the relevant insurance or reinsurance service is not in or ‘connected with Russia’ (as defined in regulation 21), the prohibition may still apply if the goods or technology to which the service relates are for use in Russia.

It would not apply where the insurance is for the benefit of the non-Russian owner of the items, rather than their user or operator. Nor does it apply where the items either remain in Russia as the result of the termination of a lease and against the lessor’s will; or are being flown out of Russia in the process of returning them to their owner.

The provision of insurance and reinsurance services in respect of a satellite where the only nexus with Russia is that it is orbiting over Russia, or broadcasting to Russia (and where the insurance and reinsurance services will not be provided to a person connected with Russia), would likewise not come within the scope of these prohibitions.

Therefore, if you are providing insurance or reinsurance services you should check whether the goods or technology may be used in Russia, and apply for a licence or contact ECJU if so.

Provisions on energy-related services are set out in regulation 46 and prohibit the direct or indirect provision of ‘relevant energy services’, defined as certain ‘specified services’ necessary for an ‘oil or gas exploration or production project’ in Russia. The specified services being drilling, well testing, logging and completion services, and the supply of specialised floating vehicles.

Provisions on infrastructure-related services and tourism-related services are set out in regulation 54 and prohibit the provision of services relating to certain specified infrastructure sectors or services relating to tourism in non-government controlled Ukrainian territory.

Provisions on internet services are set out in regulation 54A and require social media companies, and internet service providers, to take reasonable steps to prevent their users from encountering or accessing services or content online directly generated, shared or uploaded by a designated person. Application store providers must also take reasonable steps to prevent users from using their services to download or access internet services provided by a designated person. Designations for the purposes of these measures will be made by the Secretary of State and published on the UK Sanctions List.

Therefore, if you are an internet service provider, or provide a social media service or application store for internet service applications, then you should check whether an entity has been designated by the UK Government for this purpose and take the necessary action to ensure compliance with the prohibitions.

Regulation 46K prohibits the provision of interception and monitoring services to, or for the benefit of, the Government of Russia (as defined in regulation 6).

Technical guidance on interception and monitoring

Prohibitions on the provision of professional and business services (accounting, advertising, architectural, auditing, business and management consulting, engineering, IT consultancy and design, and public relations services) are set out in regulation 54C. These prohibit the direct or indirect provision of such services to persons connected with Russia.

The provision of legal advisory services is restricted under the regulations, including by the circumvention measures in regulations 19 and 55.

Regulation 54D supplements these general restrictions and specifically prohibits legal advisory services to a non-UK person, where the object or effect of those services is to enable or facilitate certain financial or trade activity which would be prohibited under the UK sanctions regime if the activity was done by a UK person or taking place within the UK.

Regulation 60DB provides for exceptions in relation to the prohibition on the provision of legal advisory services.

Provision of services via any or all of modes of service supply 1, 2, 3, or 4, as defined under the World Trade Organization’s General Agreement on Trade in Services (GATS), to any person connected with Russia is covered by the prohibitions. This would include the cross-border supply of such services by a UK services provider to another company incorporated under Russian law and the provision of services to Russian residents who are temporarily located in another country, including the UK.

Please refer to Schedule 3J in the regulations for the definitions of prohibited services. Several of these definitions are presented as references to Central Product Classification (CPC) codes. Where they are presented in this way, it is recommended that you review your activity against the correct version (for example: Provisional, 1.0, 1.1, 2, or 2.1) and individual code numbers (for example, ‘CPC 8671 – Architectural services’) that correspond to each prohibition. This information will enable you to navigate to the relevant definitions at the following link: CPC Codes.

Though the accounting and auditing services definitions are based on CPC codes, they are defined in Schedule 3J for clarity, given the differences in exceptions and licensing which apply to these 2 sectors. The definition of accounting services is based on the Provisional CPC Codes 1991 and includes CPC 86212 Accounting Review Services, CPC 86213 Compilation of Financial Statements services, CPC 86219 Other Accounting Services and CPC 86220 Bookkeeping Services, except tax returns. The definition of auditing services is also based on the Provisional CPC Code 1991, CPC 86211 Financial Auditing Services.

The definitions of business and management consulting and public relations services are not based on CPC codes, but instead on Extended Balance of Payments Services classification (EBOPS) 2010 and includes EBOPS 10.2.1.3 - (Business and management consulting and public relations services includes advisory, guidance and operational assistance services provided to businesses for business policy and strategy, and the overall planning, structuring and control of an organization.)

Trade sanctions enquiries

The Department for Business and Trade (DBT) leads on trade sanctions. For help with export controls or trade sanctions, contact the Export Control Joint Unit, part of DBT, on: exportcontrol.help@businessandtrade.gov.uk or tradesanctions@businessandtrade.gov.uk 

Helpline: +44 (0)20 7215 4594

For queries about trade sanctions relating to standalone services, and interception and monitoring services sanctions, contact the Office of Trade Sanctions Implementation (OTSI). 

For further information on import controls and sanctions, contact DBT’s Import Controls and Sanctions team on: importsanctions@businessandtrade.gov.uk

1.7 Transport sanctions

Transport sanctions provisions are contained in Parts 6 and 6A of the Regulations and impose transport prohibitions relating to aircraft and shipping.

Shipping sanctions

The Regulations prohibit Russian ships, and other ships specified by the Secretary of State, from entering ports in the United Kingdom. The regulations also confer powers on the Secretary of State and harbour authorities to issue port barring directions to the master or pilot of a specified ship. The regulations provide the Secretary of State with a power to control the movement of Russian ships or specified ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are.

The Regulations prohibit the registration of ships owned, controlled, chartered or operated by designated persons or persons connected with Russia on the UK Ship Register and confer powers on the Secretary of State to direct the UK Ship Registrar to terminate the registration of such ships and specified ships.

The Regulations also confer powers on the Secretary of State and harbour authorities to detain Russian ships or specified ships at ports or anchorages in the UK.

‘Russian ship’ is not a term used in the regulations. However, it is used in this shipping section of the guidance to aid understanding and readability. It means a ship which is:

• owned, controlled, chartered or operated by a designated person
• owned, controlled, chartered or operated by persons connected with Russia
• registered in Russia, or
• flying the flag of Russia

A ship is not controlled or operated by its Master or crew, unless they are a designated person.

These sanctions do not apply to other ships originating from or destined for Russian ports; ships carrying cargo to or from Russia are not within scope of the transport sanctions unless they fall within the definition of a Russian ship or specified ship as above.

The Regulations also provide the Secretary of State with the power to issue directions in relation to the movement of British cruise ships, preventing them from entering any ports located in Crimea, or in the non-government controlled areas of the Donetsk, Luhansk, Kherson, and Zaporizhzhia oblasts. Such a direction can be given to any master or pilot of a British ship which is a cruise ship (defined as a ship which is providing cruise services).

A Crimean Ports Direction under regulation 57 of the Regulations was made on 7 January 2021. The direction was issued to the masters and any pilots of all British ships that are cruise ships and it provides that any ship to which this direction applies is prohibited from entering ports located in Crimea.

Transport sanctions include powers for the Secretary of State to issue directions. The Secretary of State may notify a person that the existence or content of a port barring, entry or movement direction, or anything done under such directions, is to be treated as confidential.

Aircraft sanctions

The regulations prohibit a Russian aircraft which is owned, chartered or operated by persons connected with Russia or designated persons from overflying or landing in the United Kingdom.

In addition, they provide a power for the Civil Aviation Authority (CAA) to refuse to register an aircraft or for the Secretary of State to direct the CAA to terminate the registration of an aircraft that is owned or operated by a designated person or chartered by demise by a designated person.

They confer direction-making powers on the Secretary of State, air traffic control and airport operators regarding aircraft movements in United Kingdom airspace and at United Kingdom airports. The regulations also provide a power for the Secretary of State to direct an airport operator to secure the detention of a Russian aircraft at an airport or to secure the movement of a Russian aircraft to a specified airport.

Russian aircraft is defined as an aircraft:

• owned, chartered or operated by a designated person, or a person connected with Russia, or
• registered in Russia

Transport sanctions include powers for the Secretary of State to issue directions. The Secretary of State may notify a person that the existence or content of any direction relating to the movement or detention of aircraft, or anything done under such directions, is to be treated as confidential.

The Department for Transport (DfT) is responsible for implementing the UK’s transport sanctions. See more guidance from DfT. 

For guidance on mandatory reporting to DfT, see Information and record keeping.

1.8 Immigration sanctions

Immigration sanctions provisions are contained in Part 4 of the Regulations.

The effect of the regulations is to impose a travel ban on persons designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. Such persons are excluded persons for the purposes of Section 8B of the Immigration Act 1971.

Designated individuals will be refused leave to enter or remain in the UK. Any application they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban under the regulations, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK.

If you are the subject of an immigration sanction and try to travel to the UK, carriers are required to deny you boarding.

See more information on how the Home Office deals with those who are subject to a travel ban.

1.9 Information and record keeping

Information and record-keeping provisions, including financial sanctions reporting obligations, are contained in Part 8 of the Regulations.

Financial sanctions reporting obligations and information requests

For the purpose of the financial sanctions, the Regulations place obligations on relevant firms to report information to HM Treasury (in practice to the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury) about known or suspected designated persons or about persons who may have breached a prohibition or failed to comply with an obligation under specified provisions of the Regulations.

Part 8 places further obligations on relevant firms to report to HM Treasury the nature and amount or quantity of any funds or economic resources that it knows or suspects that it holds for the Central Bank of Russia, Russian Ministry of Finance, Russian National Wealth Fund, persons owned or controlled directly or indirectly by these entities or persons acting on behalf of or at the direction of these entities.

OFSI has powers to request information from, among others, a designated person, including powers to request the production of documents. It is an offence to fail to comply with these requests or provide false information.

Part 8 of the regulations places an obligation on persons designated under the Russia regime to report the nature, value and location of their assets.

If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.

See more guidance about OFSI’s reporting obligations.

Trade and transport sanctions reporting obligations and information requests

The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) (TASSCER) Regulations (2024) place obligations on:

• relevant persons (providers of financial or legal services, or money service businesses, for example) in relation to suspected breaches of certain trade sanctions 
• relevant persons (a pilot, airport operator, ship’s master or harbour authority, for example) in relation to suspected breaches of aircraft and shipping sanctions

For details see:

• Trade sanctions: reporting obligations
• Transport sanctions: reporting obligations

The Regulations establish powers to request information in relation to the trade and transport sanctions and record-keeping responsibilities for licences. It is an offence to fail to comply with any of these requirements or intentionally obstruct an official in the exercise of these powers.

See more details about information you must provide:

• in response to a trade sanctions information request
• in response to a transport sanctions information request

If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.

2. Enforcement

Enforcement provisions are contained in Part 9 of the Regulations.

It is a criminal offence to breach sanctions, or to enable or facilitate a breach of, or to circumvent sanctions. The Regulations set out the mode of trial and penalties that apply to such offences.

In some cases, offences are contained in other legislation, such as the Customs and Excise Management Act 1979 (CEMA), or in the regulations made under the Sanctions Act that apply across regimes, such as the TASSCER regulations.

2.1 Financial sanctions enforcement

A breach of the main financial prohibitions or licensing provisions in the Regulations is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 7 years’ imprisonment or a fine, or both.

Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both.

The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose civil monetary penalties and refer cases to law enforcement agencies for criminal investigation and potential prosecution.

OFSI’s approach to compliance and enforcement is outlined in section 7 of OFSI’s general guidance.

For more information about how OFSI assesses suspected breaches and the possible enforcement outcomes, see OFSI’s enforcement guidance.

2.2 Director disqualification sanctions enforcement

A breach of the main prohibitions or licensing provisions is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both.

It is also an offence to provide misleading information to obtain a licence, act outside of permissions given or ignore conditions contained within a licence. A licensing offence carries a maximum sentence on conviction on indictment of 2 years’ imprisonment, or a fine, or both.

The Insolvency Service is responsible for investigating suspected breaches and licensing offences. It has the power to bring prosecutions for breaches and refer cases to other law enforcement agencies for criminal investigation and potential prosecution.

2.3 Trade sanctions enforcement

A breach of the trade sanctions prohibitions is triable either way and carries a maximum sentence on conviction on indictment of 10 years’ imprisonment or a fine, or both.

A breach of the trade sanctions licensing provisions is also triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both. 

Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both. 

HM Revenue and Customs (HMRC) is responsible for the enforcement of trade sanctions that fall within its remit as the UK’s customs authority and for the enforcement of trade sanctions measures that relate to strategic goods and technology.  

The Office of Trade Sanctions Implementation (OTSI), part of DBT, is responsible for monitoring compliance with certain other trade sanctions and investigating suspected breaches. OTSI also has the power to impose civil monetary penalties and refer cases to HMRC for criminal investigation.

If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible. If the irregularity was found on an Export Control Joint Unit compliance audit, the compliance inspector will have informed HMRC and you are strongly advised to do the same. Guidance is available on how to make a voluntary disclosure.

The Office of Trade Sanctions Implementation (OTSI), part of DBT, is responsible for the civil enforcement of certain trade sanctions including for standalone services and the movement of goods involving UK companies or persons that do not cross the UK border. For information about how OTSI assesses breaches and the possible enforcement outcomes, see OTSI’s enforcement guidance.

Ofcom is responsible for monitoring compliance with trade sanctions in relation to internet services, and for assessing suspected breaches. It has the power to impose monetary penalties for breaches of these sanctions.

Where appropriate and where permitted by law, Ofcom may share relevant information with parts of government, supervisory bodies and regulators.

By exception within trade sanctions, OFSI enforces civil penalties relating to the supply or delivery by ship of oil and oil products under the commodity codes 2709 and 2710 from Russia to and between third countries and services associated with that supply or delivery (such as financial services and brokering). OFSI can be contacted by emailing oilpricecap.ofsi@hmtreasury.gov.uk. Full guidance on the Russian Oil Services ban can be found on the OFSI website.

2.4 Transport sanctions enforcement

A breach of the following transport sanctions relating to Russian ships and aircraft is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 7 years’ imprisonment or a fine, or both. This includes failing to comply with:

• the prohibitions on port entry  - the prohibitions on overflying or landing 
• a port barring direction 
• a port entry, or movement direction 
• a direction given in respect of an aircraft  

A breach of the transport sanctions licensing conditions is also triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both. 

The offence of failing to comply with a detention direction in relation to a ship is triable either way and carries a sentence or a fine. 

Disclosure of confidential information carries a maximum sentence of 6 months’ imprisonment on summary conviction or a fine, or both. 

A failure to comply with the reporting obligations is a criminal offence and carries a maximum sentence of 6 months’ imprisonment on summary conviction or a fine, or both. See Transport sanctions: reporting obligations.

DfT as the enforcement authority is supported by the Maritime and Coastguard Agency (MCA), harbour authorities, the Civil Aviation Authority (CAA), National Air Traffic Services (NATS) and airport operators.

DfT also has the power to impose civil monetary penalties for breaches of transport sanctions and to refer cases to law enforcement agencies for investigation and potential prosecution.

If you become aware that a breach of the transport sanctions has taken or will take place, you can report it by emailing transportsanctions@dft.gov.uk

For more information about how DfT assesses breaches of transport sanctions and the possible enforcement outcomes, see DfT’s enforcement guidance.

3. Exceptions and licences

Exceptions and licensing provisions are contained in Part 7 of the regulations.

3.1 Exceptions

An exception gives an automatic exemption to an activity that would otherwise be prohibited under sanctions. It means you can carry out that activity as long as certain defined circumstances, set out in the Regulations, apply to your activity.

An exception applies automatically so you do not require a licence to carry out the proposed activity, but some exceptions have notification obligations.

To check the full legal wording of an exception, go to the regulations listed in Part 7. If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

General exceptions

Exception for authorised conduct in a relevant country (regulation 62A)

This exception relates to prohibitions in regulations 11 to 15, 16, 17, 17A, 18, 18A, 18B, 18C and Chapters 2 to 6 and 6B of Part 5 (Trade).

The exception applies if:

• conduct is authorised by a licence or other authorisation that is issued under the law of the Channel Islands, Isle of Man or any British Overseas Territory for the purpose of disapplying a prohibition in that jurisdiction which corresponds to the relevant prohibition

Exception for acts done for purposes of national security or prevention of serious crime (regulation 63)

This exception can be used in relation to any prohibition or requirement imposed by the Regulations.

The exception applies if:

• a responsible officer has determined the relevant actions to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere

Financial sanctions exceptions

Exceptions for crediting a frozen account (regulation 58)

These exceptions relate to the prohibitions in regulations 11 to 13 about dealing with the funds or economic resources of designated persons and making funds available to them. The exceptions permit, in certain circumstances, frozen accounts to be credited by and transfers made to ’relevant institutions’ – those with permission to carry out regulated activities under the Financial Services and Markets Act 2000 part 4A.

See section 6 of OFSI’s general guidance for details about how to use these exceptions and the related reporting obligations for relevant institutions.

Exception for required payments (regulation 58A)

This exception relates to the prohibitions in regulations 11 and 13 about dealing with the funds or economic resources of designated persons and making funds available for their benefit.

The exception permits certain required payments to be made by, or on behalf of, designated persons to various specified UK public bodies.

See OFSI’s FAQs on required payments for details about how to use these exceptions and the related notification obligations.

OFSI has also issued guidance on exceptions specific to the Russia sanctions that allow certain activities in relation to: 

• loans and credit arrangements (regulation 59) 
• processing of payments (regulation 59A) 
• investments in non-government-controlled Ukrainian territory (regulation 60) 
• investments in Russia (regulation 60ZZA) 
• the provision of trust services (regulation 60ZZB)

Trade and transport sanctions exceptions

The regulations also set out exceptions relating to some of the trade and transport restrictions.

The exceptions are navigable and scannable in a guide that forms part of this statutory guidance: Look up exceptions to Russia trade and transport sanctions.

If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

3.2 Licensing for financial sanctions

A licence is a written permission from OFSI that allows an act that would otherwise be in breach of the financial sanctions prohibitions set out in Regulations:  

• 11 to 15 (asset-freeze etc) 
• 16 (transferable securities and money- market instruments) 
• 17 (loans and credit arrangements) 
• 17A (corresponding banking relationships and processing payments) 
• 18 (investments in relation to non-government controlled Ukrainian territory) 
• 18A (provision of financial services relating to foreign reserve and asset management services) 
• 18B (investments in relation to Russia) 
• 18C (trust services)
• 46Z9B to 46Z9D (maritime transportation of certain oil and oil products)

OFSI has issued general licences that may be used under this regime. For details see OFSI’s general licence page.

In circumstances where there are no applicable exceptions from the prohibitions or general licences, any person (including a designated person) may apply for a licence from OFSI enabling them to deal with the frozen funds or economic resources of the designated person, or to allow these to be made available to or for the benefit of a designated person.

You should not assume that a licence will be granted or engage in any activities prohibited by financial sanctions until your licence has been granted.

Licensing grounds for financial sanctions

OFSI can only issue individual licences where:

• there is a relevant licensing ground
• the conditions set out in that licensing ground have been met, and
• OFSI considers it appropriate to issue a licence for that purpose

The purposes and activities for which OFSI may grant an individual licence to a person, allowing them to deal with the frozen funds or economic resources of a designated person, or to allow for funds or economic resources to be made available to or for the benefit of a designated person, are set out in part 1 of Schedule 5 to the regulations.

OFSI has given a summary of these licensing grounds in their financial sanctions guidance for Russia including: 

• asset freeze etc. 
• divestments 
• insolvency 
• securities, loans and credit arrangements  
• correspondent banking relationships and payment processing  -processing payments 
• investment in non-government controlled Ukrainian territory 
• foreign exchange reserve and asset management 
• investment in relation to Russia 
• trust services 
• maritime transportation of certain oil and oil products

See section 6.6 of OFSI’s general guidance for the approach OFSI takes when deciding whether to grant a licence for each possible licensing ground. It also has details about licence applications in relation to divestment (whole and partial). 

See OFSI’s licensing page for licence application forms and guidance. 

OFSI’s guide Financial sanctions licensing: supplementary guidance gives the reasonable rates for covering certain licensed expenses for designated persons.

3.3 Licensing for director disqualification sanctions

The designated person, or their authorised representative, can make an application for a licence to the Insolvency Service. See more details about how to apply.  

The Insolvency Service will assess and grant or refuse licence applications on behalf of the Secretary of State. Companies House is responsible for updating the Companies Register when a licence is granted.  

You should not assume that a licence will be granted or act as the director of a company – or directly or indirectly take part in or be concerned in the promotion, formation or management of a company – until your licence has been granted.

3.4 Licensing for trade sanctions

Licences may also be issued for certain trade activities that would otherwise be prohibited by the regulations. DBT has overall responsibility for trade sanctions licensing. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out.  

If you are carrying out activity that falls under the remit of more than one licensing body, you will need to submit separate licence applications for each one.  

The Export Control Joint Unit (ECJU), part of DBT, is responsible for licensing the export of sanctioned goods, software and technology. See how to apply for an export licence. Information on the activities you wish to carry out and relevant documentation can be provided in a cover letter and attached to the application.

DBT’s Import Controls team is responsible for licensing the import of (otherwise sanctioned) goods, software and technology. See guidance on how to apply for an import licence. The Import Controls team will, to the extent possible, aim to inform the trader of the application outcome within 30 days. However, in some circumstances, for operational or legal reasons, DBT may need to take longer than the 30 day period. They will inform the applicant if this is the case. 

The Office of Trade Sanctions Implementation (OTSI) can issue licences for (otherwise sanctioned) interception and monitoring services, professional and business services, and energy-related services.

DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.

In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 5 of the regulations, the Secretary of State will consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.

Licences granted will not permit activity in respect of Northern Ireland that is not consistent with EU sanctions regulations as they apply via the Northern Ireland Protocol.

For some prohibitions there are some specific activities that DBT considers are likely to be consistent with the aims of the sanctions (‘licensing considerations’). If you think that your proposed activity falls within one of these specific descriptions you should make this clear and explain why you believe this to be the case in your application for a licence.

You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted.

The licensing considerations are navigable and scannable in a guide that forms part of this statutory guidance: Look up considerations for trade licences under the Russia sanctions.

When you export or import goods, you may need to submit a declaration: guidance is available on:

• how to make an export declaration. 
• how to make an import declaration

By exception within trade sanctions, OFSI is responsible for issuing licences relating to the supply or delivery by ship of oil and oil products under the commodity codes 2709 and 2710 from Russia to and between third countries and services associated with that supply or delivery (such as financial services and brokering). OFSI can be contacted by emailing oilpricecap.ofsi@hmtreasury.gov.uk. Full guidance on the Russian Oil Services ban can be found on the OFSI website.

Overlap with strategic export licensing

Military goods and military technology

Please note the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence which is valid under that legislation. This means that all licence applications relating to military goods and military technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.

The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the regulations and the Export Control Order 2008 as an application for a licence under both pieces of legislation. This means that only a single licence application is required.

The application will be considered against the relevant licensing criteria. If a licence is granted it will be valid under both the Export Control Order 2008 and the regulations.

Dual-use goods and technology

Please note that the export of and trade in dual-use goods and technology are also controlled under the Dual-Use Regulation. Authorisations under that regulation are granted by the Secretary of State for Business and Trade under licensing powers in the Export Control Order 2008.

This means that all licence applications relating to items which are controlled dual-use goods and technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the regulations is unlikely to be granted if an authorisation is refused for the same activity under the Dual-Use Regulation.

As explained above in relation to military goods and technology, only a single licence application will be required in relation to dual-use goods and technology which falls within the scope of both the regulations and the Dual-Use Regulation. If the application is compatible with both criteria, a licence will be granted which will be valid under the Dual-Use Regulation and the Export Control Order 2008 as well as the regulations.

Overlap between items falling under Schedule 2C (aviation and space goods and technology) which are also military goods and technology or dual-use goods and technology

Where an item falls within the definition of ‘aviation and space goods’ or ‘aviation and space technology’ list and also within the definitions of either military goods, military technology, dual-use goods or dual-use technology, it is subject to prohibitions under all relevant regulations. If you wish to rely on an exception, there must be a relevant exception available for all relevant prohibitions that it engages.

Similarly, if you wish to apply for a licence, your activity must be compatible with licensing grounds for all relevant prohibitions that it engages. The ECJU will assess your application against all relevant prohibitions and licensing grounds.

Overlap between trade sanctions and financial sanctions

You may need a licence from OFSI as well as from ECJU, OTSI or the Import Controls Team. See the guidance on licensing for more details.

Transit control

Certain goods transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception meaning that in many situations a licence is not required. This exception does not apply to goods destined for Russia, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to Russia.

3.5 Licensing for transport sanctions

Licences may also be issued for certain transport activities that would otherwise be prohibited by the regulations. DfT has overall responsibility for transport sanctions licensing. The Secretary of State for Transport is ultimately responsible for decisions to grant or refuse a transport sanctions licence in any individual case.

For some prohibitions there are some specific activities that DfT considers are likely to be consistent with the aims of the sanctions.

These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions you should make this clear and explain why you believe this to be the case in your application for a licence.

Prohibition description	Prohibition reference	Considerations for licensing
Prohibition on the movement of Russian aircraft	Regulation 57J	A licence may be granted for the overflight of UK airspace, or for the landing in the UK of a Russian aircraft where it is necessary either: - for the delivery of humanitarian assistance, or - for the official purposes of a diplomatic mission or consular post in Russia or the UK, or of an international organisation enjoying immunities in the UK in accordance with international law, or - for testing the aircraft for the purposes of providing technical assistance

You should not assume that a licence will be granted or engage in any activities prohibited by the sanctions until your licence has been granted.

See how to apply for a transport sanctions licence.

3.6 Directions in respect of immigration sanctions

If you are subject to immigration sanctions the Home Office may direct, on a case by case basis, that the sanction does not apply in particular circumstances, such as for travel to, or through, the UK for a UN sponsored meeting. You can check how to apply for a UK visa, and find further information about travelling to the UK on GOV.UK.

4. Further information

The UK sanctions hub page is a central point for all sanctions content, including links to introductory guidance, sector-specific guidance, reporting obligations, blogs, and email alert services.

You can report a suspected breach of sanctions if you think you, or someone else, may have breached sanctions, or be attempting to circumvent sanctions.

For specific queries about this sanctions regime, email: fcdo.correspondence@fcdo.gov.uk

For other contact details, see Government departments and agencies responsible for sanctions.