UK Sanctions Update: Russia and Belarus
Summary
The UK government has amended its sanctions list under the Russia regime, with one entity remaining subject to an asset freeze and another being removed. Additionally, new guidance on licences for Belarus trade sanctions has been published, and an overview of 2025 Russia sanctions highlights potential future legislation targeting sanctions evasion.
What changed
This update details recent amendments to the UK's sanctions regime concerning Russia. Specifically, OJSC Keremet Bank remains under an asset freeze, while John Ormerod has been removed from the sanctions list. The update also references a research briefing on 2025 Russia sanctions, which outlines potential future legislation including measures against sanctions evasion, a maritime services ban for Russian LNG, and an import ban on oil products refined in third countries from Russian crude.
Regulated entities, particularly those involved in international trade with Russia and Belarus, should review these updates. While the immediate changes involve specific entities, the mention of potential future legislation targeting sanctions evasion and maritime services indicates a tightening regulatory environment. Companies should ensure their compliance programs are robust and adaptable to evolving sanctions requirements. No specific compliance deadline is provided for these updates, but ongoing monitoring is crucial.
What to do next
- Review the updated UK sanctions list for Russia and Belarus.
- Assess impact of potential future legislation on sanctions evasion and maritime services.
- Ensure compliance programs are updated to reflect current and potential future sanctions.
Source document (simplified)
March 11, 2026
UK Weekly Sanctions Update - Week of March 2, 2026
Jason Hungerford, Kirsty Morris, Mihira Patten, Findley Penn-Hughes, Paul Whitfield-Jones Mayer Brown + Follow Contact LinkedIn Facebook X Send Embed
In this weekly update, we summarise the most notable updates in the UK sanctions world.
RUSSIA SANCTIONS
- UK Government amends one entry on the UK sanctions list under the Russia sanctions regime: On March 6, 2026, the FCDO amended the entry for OJSC Keremet Bank under the Russia sanctions regime. This entity is still subject to an asset freeze. (Sanctions Notice).
- UK Government removes one entry from the UK sanctions list under the Russia sanctions regime: On March 2, 2026, the FCDO removed John Ormerod from the UK sanctions list under the Russia regime. (https://assets.publishing.service.gov.uk/media/69a5a6e846e50eda5c46b59a/SanctionsNoticeRussia2March_2026.pdf).
- UK Government publishes overview of 2025 Russia sanctions: On February 27, 2026, the House of Commons Library published a research briefing providing an overview of UK and EU sanctions imposed on Russia since January 2025. The briefing noted that the UK government would introduce new legislation to target sanctions evasion and the export of goods to third countries which are then re-directed to Russia, a maritime services ban related to the export of Russian Liquefied Natural Gas (and possibly a full maritime services ban in relation to Russian crude oil and oil-related products), and an import ban on oil products refined in third countries made from Russian‑origin crude. (https://commonslibrary.parliament.uk/research-briefings/cbp-10342/).
BELARUS SANCTIONS
- UK Government publishes guidance on licences and exceptions to Belarus trade and transport sanctions: On March 5, 2026, the Department for Business and Trade published guidance on considerations for granting licences under trade sanctions against Belarus across a broad range of products. (https://www.gov.uk/guidance/look-up-considerations-for-trade-licences-under-the-belarus-sanctions).
- UK Court of Appeal rejects Dana Astra’s Belarus delisting appeal: On February 26, 2026, the UK Court of Appeal dismissed Dana Astra’s appeal in Dana Astra v Secretary of State for Foreign, Commonwealth and Development Affairs [2026] EWCA Civ 160 against the High Court’s decision to reject Dana Astra’s delisting application. (https://www.judiciary.uk/wp-content/uploads/2026/02/APPROVED-JUDGMENT-in-DANA-ASTRA-v-SS-for-FCDA-CA-2025-000603.pdf).
OTHER
- UK Government removes one entry under the ISIL (Da'esh) and Al-Qaida sanctions regime: On March 2, 2026, the FCDO removed AL-NUSRAH FRONT FOR THE PEOPLE OF THE LEVANT from the UK sanctions list under Isil (Da'esh) and Al-Qaeda (United Nations Sanctions) (EU Exit) Regulations 2019.
- UK Government publishes Notice to Importers NTI 2956 regarding equipment that may be used for torture: On March 2, 2026, the Import Controls Policy and Licensing team published Notice to Importers NTI 2956 outlining that certain are subject to a UK import ban or licensing requirement due to their potential use as “torture equipment” under Assimilated Regulation (EU) 2019/125. (https://www.gov.uk/government/publications/notice-to-importers-2956-import-of-equipment-that-could-be-used-for-torture/nti-2956-import-of-equipment-that-could-be-used-for-torture).
UK Government publishes blog post on how OFSI prioritises sanctions licence applications: On February 27, 2026, OFSI published a blog post on how it prioritises applications for sanctions licences. OFSI classifies applications as high, medium, or low priority based on seven licensing criteria. (https://ofsi.blog.gov.uk/2026/02/27/how-ofsi-prioritises-licence-applications/).
Roundup of evidence presented to Parliament on UK trade sanctions regime: On February 25, 2025, the UK Government’s Business and Trade Sub‑Committee on Economic Security, Arms and Export Controls (BTC) heard evidence on the UK’s trade sanctions regime. Witnesses included the Minister of State for Trade, the Deputy Director for the Office of Trade Sanctions Implementation and the Deputy Director for Russia and Belarus Sanctions at the FCDO. The transcript is now available. (https://committees.parliament.uk/oralevidence/17234/html/),
[View source.]
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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