On 19 May 2026, the Department for Business and Trade (DBT) issued General Trade Licence GBSAN0004 (the Licence), authorising the import into the United Kingdom of certain processed oil products derived from Russian crude oil. The Licence, which comes into force on 20 May 2026, marks a notable relaxation of the UK’s otherwise comprehensive sanctions regime targeting Russian energy products. This article summarises the scope, conditions, and practical implications of the Licence for general counsel, compliance teams, and commercial clients engaged in the oil and refined products trade.

Background

The UK’s Russia sanctions regime – established under the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations) – includes a broad prohibition on the import and acquisition of Russian oil and oil products, as well as related services. Chapter 4IB of the Russia Regulations specifically addresses “relevant processed oil products”, prohibiting the import of oil products that have been processed in a third country from Russian-origin crude oil. Regulations 46Z9F, 46Z9G, 46Z9H, and 46Z9I impose prohibitions on the import, acquisition, supply, and delivery of such products, as well as on related financial and ancillary services.

The Licence was issued against a backdrop of intensifying pressure on global fuel markets. It followed the United States’ decision on 18 May 2026 to extend its own sanctions waiver on Russian oil, reportedly driven by the need to stabilise fuel costs amid the U.S.–Israeli conflict with Iran. The UK government stated that it remains “committed to strengthening our sanctions on Russia to degrade its ability to wage war in Ukraine, whilst protecting critical supply chains and maintaining market stability”.

Scope of the Licence

The Licence is granted by the Secretary of State under regulation 65 of the Russia Regulations and disapplies the prohibitions in regulations 46Z9F to 46Z9I in respect of qualifying products. Its scope is, however, deliberately narrow: it applies only to products classified under commodity code 2710 that have been processed in a “third country” from crude oil originating in Russia (commodity code 2709). A “third country” is defined as any country other than the United Kingdom, the Isle of Man, or Russia.

The products authorised under the Licence are limited to the following:

• Diesel, falling within commodity codes 2710 19 42 or 2710 19 44; and
• Jet fuel, falling within commodity code 2710 19 21.

No other refined or processed oil products are covered. Alongside the import of these goods, the Licence permits the provision of certain services and actions related to their importation. Importantly, the Licence does not authorise any act that the person carrying it out knows, or has reasonable grounds for suspecting, will result in a breach of any other part of the Russia Regulations.

Duration, revocation, and record-keeping

The Licence comes into force on 20 May 2026 and is of indefinite duration, subject to periodic review by the Secretary of State. It may be varied, revoked, or suspended at any time, although DBT has stated it will endeavour to provide four months’ notice of any decision to revoke. This notice period is a welcome feature for market participants seeking supply chain certainty, although it falls short of a binding commitment.

The provisions of regulation 76 of the Russia Regulations – which impose record-keeping obligations in connection with general trade licences – apply to any act carried out under the authority of the Licence. Entities relying on the Licence should therefore ensure that adequate records are maintained documenting their reliance on it, the products imported, and the relevant commodity codes.

Windsor Framework considerations

The Licence is expressly subject to any obligations arising under the Windsor Framework, as applied through section 7A of the European Union (Withdrawal) Act 2018, in respect of Northern Ireland. This is a significant caveat. Where products are destined for or transiting through Northern Ireland, businesses should assess whether EU sanctions restrictions – which may differ from those applicable in Great Britain – impose additional or overriding requirements.

Wider context

The issuance of the Licence forms part of a broader pattern of calibrated sanctions adjustments by the UK government. In addition to the Licence, on 19 May 2026, the UK issued a separate general licence permitting the maritime transport of Russian liquefied natural gas (LNG) from the Sakhalin-2 and Yamal LNG terminals, valid until 1 January 2027.

No doubt, political positions are being put aside as the wider impact of the U.S.–Israel conflict with Iran, and the resulting disruption to the Strait of Hormuz and movement of oil and gas, starts to bite on the UK economy.

Practical recommendations

For general counsel and compliance officers, the following steps are recommended. First, businesses engaged in the import of diesel or jet fuel should review their supply chains to determine whether any products may qualify as “relevant processed oil products” under the Licence and, if so, confirm that the applicable commodity codes are met. Second, entities relying on the Licence should implement robust record-keeping procedures compliant with Regulation 76 of the Russia Regulations. Third, given the indefinite but revocable nature of the Licence, businesses should monitor the government’s periodic reviews closely and maintain contingency plans for the possibility of revocation on four months’ notice. Fourth, any supply chains involving Northern Ireland must be assessed against the additional requirements that may apply under the Windsor Framework. Finally, enquiries regarding the Licence should be directed to the Import Controls and Trade Sanctions team at DBT.

Divergence and compliance complexity

The Licence represents a further divergence between the U.S., EU, and UK sanctions regimes on Russian oil and related services, which were implemented on a coordinated basis in 2022 and 2023. This increasing divergence adds complexity for compliance teams operating across these markets, who will now need to maintain a detailed understanding of, and ensure adherence to, three distinct and evolving sanctions frameworks – each with its own scope, exceptions, and licensing requirements.

How we can help

The Reed Smith team remains on hand to assist clients in navigating the evolving sanctions landscape, including advising on the application of the Licence, supply chain compliance, and the interplay between UK, EU, and U.S. restrictions. Please do not hesitate to reach out to any member of the team if you have any queries.