Russia Sanctions: Statutory Guidance
Summary
The UK's Foreign, Commonwealth & Development Office has updated its statutory guidance for the Russia (Sanctions) (EU Exit) Regulations 2019. The latest updates, as of March 12, 2026, incorporate significant changes to trade sanctions measures and licensing conditions, alongside technical amendments to improve intelligence gathering and enforcement powers.
What changed
The UK government, through the Foreign, Commonwealth & Development Office and other related agencies, has issued updated statutory guidance for the Russia (Sanctions) (EU Exit) Regulations 2019. The document details prohibitions and requirements, with recent updates (as of March 12, 2026) incorporating significant changes to trade sanctions measures effective April 24, 2025, and technical amendments aimed at enhancing intelligence gathering, strengthening enforcement powers, and clarifying legislation. These updates also reflect changes in licensing conditions and the introduction of new services for applying for sanctions licenses for the provision of services by the Office of Trade Sanctions Implementation (OTSI).
Regulated entities, particularly those involved in trade with or related to Russia, must review the updated guidance to ensure compliance with the latest prohibitions and licensing requirements. Key areas of change include trade sanctions measures, legal services prohibitions, and licensing for third-country processed Russian diamonds. Companies should pay close attention to the effective dates of new measures and ensure their internal compliance programs are updated accordingly. While specific compliance deadlines for these updates are not explicitly stated, adherence to the regulations is mandatory, and non-compliance can lead to enforcement actions.
What to do next
- Review updated Russia (Sanctions) (EU Exit) Regulations 2019 guidance
- Ensure compliance with new trade sanctions measures and licensing requirements
- Update internal compliance programs to reflect changes in prohibitions and enforcement powers
Source document (simplified)
Statutory guidance
Russia sanctions: guidance
Guidance on the Russia (Sanctions) (EU Exit) Regulations 2019
From: Foreign, Commonwealth & Development Office, Export Control Joint Unit, Office of Financial Sanctions Implementation and Office of Trade Sanctions Implementation Published 9 May 2019 Last updated 12 March 2026
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Russia sanctions: statutory guidance
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Details
The Russia (Sanctions) (EU Exit) Regulations 2019 came fully into force on 31 December 2020.
This guidance assists people in implementing and complying with the regulations. It covers the prohibitions and requirements imposed, and provides guidance on best practice for:
- complying with the prohibitions and requirements
- enforcing them
- circumstances where they do not apply This guidance should be read alongside more detailed sanctions guidance published by departments including the Department for Business and Trade (DBT), Department for Transport (DfT), Home Office and HM Treasury, through the Office of Financial Sanctions Implementation (OFSI).
Updates to this page
Published 9 May 2019 Last updated 12 March 2026 show all updates
1.
12 March 2026
Page has been updated for better clarity and usability. No material changes to text.
2.
28 November 2025
Added link to guide to trade licensing considerations, 'Look up considerations for trade licences under the Russia sanctions'.
3.
25 September 2025
Added 'Look up exceptions to the Russia trade and transport sanctions' and 'Look up amendments to the Russia sanctions regulations'.
4.
22 July 2025
latest amendments cover new licencing Regs 46Z34 - 46Z
5.
25 April 2025
Significant additions to Russia trade sanctions measures that come into force on 24.04.2025 and have been incorporated into this updated version on the stat guidance.
6.
14 March 2025
Page navigation has been updated for better usability. No material changes to text.
7.
5 December 2024
These changes reflect the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 and taken together make a range of technical changes with the purpose of improving OFSI’s ability to gather intelligence on industry’s compliance with financial sanctions, strengthen OFSI’s enforcement powers, enable OFSI to conduct its licensing responsibilities more efficiently, and clarify financial sanctions legislation where there is existing uncertainty.
8.
31 October 2024
Lines removed to reflect the change in licensing conditions in russia sanctions regulations.
9.
10 October 2024
Added the Office of Trade Sanctions Implementation (OTSI) as a supporting organisation, who took over civil enforcement for sanctions in October 2024. As part of these new powers, OTSI has introduced a new service to apply for sanctions licences for the provision of services, which replaces the previous process of applying via SPIRE. Applications for goods-related exports sanctions licences remain via SPIRE.
10.
6 September 2024
Changes made to align with amendments to regulation 54D.
11.
5 September 2024
Changes made to reflect amendments to legal services prohibition as a result of SI laid by FCDO
12.
1 September 2024
Prohibition 46Z16R has been amended to update licencing information of third country processed Russian diamonds, including new links to guidance.
13.
12 June 2024
Amended to incorporate latest legislation guidance on director disqualification and ship specification in sanctions.
14.
16 April 2024
Information on the prohibition of metals updated to reflect amendments to the Trade Licence on the acquisition of metals.
15.
1 March 2024
New Chapter 4JC bans the import of diamonds processed in a third country that originate from Russia and builds on Chapter 4JB that banned the direct import of all diamonds from Russia.
16.
26 February 2024
Amended the date in Regulation 46IB from April 2023 to June 2023
17.
30 January 2024
Guidance updated to include licencing grounds relating to Schedule 3DA revenue generating goods.
18.
15 December 2023
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023 and the Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2023.
19.
29 September 2023
Guidance updated to add additional licencing grounds for the purpose of divestment from Russia
20.
11 August 2023
Guidance updated to add a licensing ground for the restrictions on legal advisory services (Regulation 54D).
21.
3 July 2023
This amendment introduces guidance on the addition of the prohibition of Legal advisory services to the Russia (Sanctions) (EU Exit) Regulations 2019
22.
21 June 2023
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.2) Regulations 2023.
23.
17 May 2023
Minor changes to lines on provision of food services.
24.
24 April 2023
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023.
25.
20 March 2023
Guidance updated to add a licencing ground for professional and business services for critical energy supply.
26.
5 January 2023
Guidance updated to clarify the application of prohibitions on the provision of technical assistance relating to, and making available or transferral of, aviation and space goods and technology or critical-industry goods and technology.
27.
20 December 2022
A new licensing ground related to medical goods has been added to the licensing grounds for the export of Russia's vulnerable goods.
28.
16 December 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022
29.
1 December 2022
Guidance updated to clarify the application of the prohibition on provision of technical assistance, financial services or funds related to G7 dependency and further goods.
30.
9 November 2022
Guidance updated to clarify the application of the prohibition on providing financial services and funds relating to restricted goods and G7 dependency and further goods.
31.
4 November 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022
32.
28 October 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022
33.
21 July 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022.
34.
18 July 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022.
35.
15 July 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022.
36.
4 July 2022
Guidance updated to clarify the application of the prohibition on providing insurance and reinsurance services in relation to aviation and space goods and technology.
37.
24 June 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022.
38.
21 June 2022
Guidance updated to clarify the application of the prohibition on providing insurance and reinsurance services in relation to aviation and space goods and technology.
39.
29 April 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022.
40.
14 April 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022.
41.
31 March 2022
Updated to add Annex A and Annex B
42.
30 March 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022.
43.
25 March 2022
Guidance updated to clarify that the prohibition on providing financial services for the purposes of foreign exchange reserve and asset management also applies to transactions involving gold.
44.
8 March 2022
Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022.
45.
1 March 2022
Guidance amended to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2022.
46.
1 March 2022
Guidance amended to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.2) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2022.
47.
14 February 2022
Updated to link to the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022.
48.
9 May 2019
First published.
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