Key takeaways

• Ban on the import of CN 2710 products derived from Russian crude and refined in third countries – subject to diesel and jet fuel exceptions.

• Prohibition on the maritime transportation of Russian LNG – subject to carve-outs for: (i) pre-existing long-term LNG contracts until 1 January 2027; and (ii) Sakhalin and Yamal 2 projects.

• Expansion of specified “shadow-fleet” vessel restrictions, with wide-ranging measures prohibiting provision of all principal services to specified ships. These will not automatically apply to pre-existing specified ships.

• The LNG and refined product restrictions follow announcements in late 2025 by the UK government of an intention to introduce such measures. These largely align with existing EU measures under Council Regulation (EU) 833/2014.

Overview

On 19 May 2026, the UK government laid before Parliament the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (the “Amendment Regulations”), which come into force on 20 May 2026 and amend The Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). The Amendment Regulations introduce a wide-ranging package of measures, the most notable being:

• a ban on the import of CN 2710 products refined in third countries derived from Russian crude (closing the so-called “refinement loophole”);

• a prohibition on maritime transportation of Russian LNG;

• broader restrictions on ‘specified ships’ sanctioned by the UK; and

• an import and transport ban on Russian uranium.

Concurrently, two General Trade Licences have been issued to mitigate the immediate impact of certain aspects of the CN 2710 refined product and LNG measures.

The CN 2710 and LNG measures largely mirror existing EU measures under Article 3ma and Article 3ra of Regulation (EU) 833/2014 (the “EU Regulation”) and follow UK government announcements made in late 2025. The broadening of ship specification measures also more closely aligns the UK with equivalent EU Article 3s measures, albeit these measures appear to be in addition to, rather than in replacement of, existing UK specification measures.

A. Russian oil refined in third countries – a new import ban

The new Regulation 46Z9F prohibits the direct or indirect import into the UK of “relevant processed oil products” (CN 2710) that have been processed in a third country from Russian-origin crude oil (CN 2709). A “third country” means any country that is not the United Kingdom, the Isle of Man or Russia.

The import ban is accompanied by restrictions on ancillary services including technical assistance (Regulation 46Z9G), financial services or funds (Regulation 46Z9H), and brokering services (Regulation 46Z9I).

The Amendment Regulations do not prescribe the standard of due diligence required of importers to ascertain whether of “relevant processed oil products” derive from Russian origin crude. We expect guidance to follow on this point – with a key question being whether this will mirror equivalent EU standards.

The General Trade Licence

In parallel, General Trade Licence (GBSAN0004), coming into force on 20 May 2026, has been issued to carve out critical fuels from the new import prohibitions:

• Excepted cargos: CN 2710 19 42, CN 2710 19 44 (diesel) and CN 2710 19 21 (jet fuel).

• Duration: the licence is of indefinite duration but may be revoked at any time, with the Secretary of State endeavouring to provide four months’ notice if it is revoked.

This exclusion seems likely to be a recognition of diesel and jet fuel supply challenges arising from the current Strait of Hormuz blockade. Relevant importers are therefore advised to monitor developments and potential revocation of this licence in the future.

For further details on this General Trade Licence see our further alert.

B. Maritime transportation ban on Russian LNG

Under the new Regulation 46Z29B, it is prohibited to, directly or indirectly, supply or deliver LNG (CN 2711 11) that originates in or is consigned from Russia by ship from (i) a place in Russia to a third country, or (ii) one third country to another third country. Under Regulations 46Z29C and 46Z29D, the provision of funds and financial services and brokering services in connection with such arrangements is also prohibited.

This follows existing UK prohibitions on the import and acquisition of Russian LNG in the Russia Regulations and closely mirrors the EU’s LNG maritime transportation restrictions in Article 3ra of the EU Regulation.

Exceptions

1.Long-term pre-existing contracts: the new Regulation 60L provides an exception to the Regulation 46Z29B – 46Z29D restrictions, permitting activity done in connection with an obligation arising under a contract for the supply of LNG, concluded before 17 June 2025, provided that:

1. the duration of the contract exceeds one year;
2. the terms of the contract are not amended after 17 June 2025 (subject to certain narrow exceptions); and
3. the relevant activity is carried out before the end of 1 January 2027

This broadly mirrors a similar exception under Article 3ra of the EU Regulation.

2. Sakhalin-2 and Yamal LNG (short-term contracts): A General Trade Licence, effective from 20 May 2026 and expiring on 1 January 2027, authorises certain contracts relating to the Sakhalin-2 and Yamal LNG projects.

Specifically, it permits maritime transportation (and related brokering and funds / financial services) under contracts of a duration of one year or less for:

1. LNG from the Sakhalin-2 LNG terminal or Yamal LNG terminal to a third country; and
2. LNG originating at the Sakhalin-2 terminal or Yamal LNG terminal, from one third country to another third country.

C. Specified ships – expansion of restrictions targeting the “shadow fleet”

New restrictions on specified ships have been introduced in two tranches:

1. Trade sanctions: Under the new Regulation 46AA it is prohibited to, directly or indirectly, provide to a specified ship any technical assistance, crew services, operating services, chartering services, brokering services, or financial services or funds. Services relating to the acquisition, sale, transfer or supply of a specified ship are also prohibited. Regulation 46AB goes on to prohibit, directly or indirectly, procuring services relating to a specified ship.
2. Shipping sanctions: The existing specified ship restrictions within the Russia Regulations have been expanded under the new Regulation 57ZA, to include a prohibition on the chartering and operation of a specified ship.

Changes made to Regulation 57F of the Russia Regulations make clear that the Secretary of State can choose to specify ships under the new restrictions at Regulation 46AA/46AB and/or the Regulation 57 measures – effectively providing a menu of options.

The Explanatory Memorandum to the Amendment Regulations also confirms that:

“These new sanctions in relation to specified ships will not automatically apply to ships already specified and listed on the UK Sanctions List. The UK may review existing specifications to consider whether these measures should be imposed…”

Other amendments include:

• an expansion of the grounds for specification, to now allow the targeting of ships carrying Russian-origin LNG and coal products; and

• the introduction of exceptions under Regulation 61ZC which: (i) protect UNCLOS rights of innocent passage for specified ships operated by non-UK persons proceeding through UK territorial waters; and (ii) provide an emergency exception allowing conduct necessary to protect or avoid endangering the safety of any ship or the life of any person.

Taken in their totality, these changes seem likely to signal an intention for expanded use of specification measures in the future.

D. Comprehensive prohibition on Russian uranium

Chapter 4KA introduces wide-ranging prohibitions on uranium products (as specified in the new Schedule 3HA). These are as follows:

• Import (Regulation 46Z23B): the import into the UK of uranium originating in or consigned from Russia, is prohibited.

• Acquisition (Regulation 46Z23C): the direct or indirect acquisition of uranium that originates in, or is located in, Russia is also prohibited.

• Supply and delivery (Regulation 46Z23D): the supply or delivery of uranium from a place in Russia to a third country is prohibited.

• Ancillary services (Regulations 46Z23E to 46Z23G): financial services and funds, technical assistance and brokering services in connection with the activities above are prohibited.

Limited exceptions are provided in Regulation 60K, specifically: (i) activity necessary for the continued operation of a nuclear installation in a third country that was operational on 20 May 2026; and (ii) activity in relation to uranium exported from Russia before 20 May 2026 and stored in a third country

E. Other

Expansion of chemical export restrictions

The goods subject to export restrictions to Russia has been expanded to include additional goods relating to inter alia engineering biology, chemicals used in advanced chip production and quantum computing. Wind-down restrictions are provided for in Regulation 60J. The list of Schedule 3E ‘G7 dependency and further goods and G7 dependency and further technology’ has also been expanded.

Detained transport assets

Chapter 4O introduces new measures in relation to “detained transport assets”, comprising: (i) ships subject to a direction under Regulation 57D(1); and (ii) aircraft subject to a direction under Regulation 57J(6)(b) of the Russia Regulations. Such measures prohibit their acquisition and provide that any purported acquisition shall be void and ineffective as a matter of contract and property law (regardless of the governing law).

Construction services

“Construction services” have been added to the existing prohibition on providing “Professional and business services” to persons connected with Russia – subject to: (i) wind-down provisions expiring on 20 August 2026; and (ii) an essential maintenance exception.