Editor’s Note
This article outlines the UK’s latest sanctions package targeting Russia’s military-industrial complex, which came into force on 24 April 2025. The new regulations expand the existing trade embargo by prohibiting the export of approximately 150 additional items, including key chemicals, electronics, and machinery.
On 24 April 2025, the UK’s Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 (the 2025 Regulations) came into force. The 2025 Regulations contain around 150 further trade sanctions against Russia.
The new measures prohibit the export of a number of items to Russia or a person connected with Russia, including certain chemicals, electronics, machinery, plastics and metals, which builds on the existing trade restrictions under the Russia (Sanctions) (EU Exit) Regulations 2019 (the 2019 Regulations). These new trade restrictions are extensive and include items that Russia has, according to the UK government, used for military purposes, including video game consoles and controllers.
The 2025 Regulations also introduced additional restrictions targeting the direct or indirect transfer or making available of software and technology used in the defense and energy sectors, such as software used to search for new oil and gas wells. This includes restrictions on making such technology available from third countries to Russia, or persons connected with Russia.
Additional restrictions have also been imposed related to the provision of services (e.g., technical, financial, brokering) in connection with such software and technology. This includes, for example, a ban on providing brokering services whose object or effect is to (directly or indirectly) provide, in a non-UK country, technical assistance or certain financial services to a person connected with Russia or for use in Russia.
These amendments appear designed to further target sanctions-circumvention-related activity in countries which have been identified by Western governments as potentially involved in such circumvention.
The package also builds on the restrictions in the 2019 Regulations which target the Russian diamond industry. The 2025 Regulations extend the diamond-related restrictions by imposing an import ban on synthetic diamonds that were manufactured in Russia and have been processed in third countries. The 2025 Regulations also prohibit a person from, directly or indirectly, providing certain services (e.g., technical, financial, brokering) in connection with such synthetic diamonds.
These measures represent an expansion of the scope of the existing measures rather than a radical overhaul of the regime and reflect the UK government’s intention to align UK sanctions with international partners such as the European Union. On 24 February 2025, in its 16th sanctions package against Russia, the European Union included similar measures to those contained in the 2025 Regulations, including expanding the scope of trade restrictions against Russia and strengthening the EU’s anti-circumvention measures.
Businesses involved in exporting these prohibited items should ensure that adequate measures are in place to reduce the risk of restricted items being transferred to Russia (including via third countries). For example, these businesses should consider including standard terms and conditions that prevent any re-export of controlled goods or technology to Russia as part of their risk mitigation efforts.
On 11 April 2025, for the first time in the UK, two individuals were sentenced for breaches of Russian-linked financial sanctions, receiving 40 months’ imprisonment and 15 months’ imprisonment, respectively. The defendants were found guilty of eight counts of breaching financial sanctions and two counts of money laundering. Both defendants are Russian nationals.
The first defendant is a designated person subject to UK financial sanctions as a result of senior positions that he held in the Russian Federation. His activities in breach of the sanctions regime included attempting to purchase a car at the cost of £54,000, receiving a transfer of £75,000 from his wife and making funds available to pay private school fees for around £17,000. The second defendant was found guilty of two counts of intentionally participating in activities that knowingly would breach Russian sanctions.
Julius Capon of the Crown Prosecution Service (CPS) said.
Also on 24 April 2025, the UK lifted sanctions on 12 Syrian entities, including the Syrian Ministry of Defense, Ministry of Interior and media companies.
The UK Office of Financial Sanctions Implementation (OFSI) announced that the entities removed from the list will no longer be subject to an asset freeze and have stated that amending Syria sanctions “will help the people of Syria rebuild their country and economy following the fall of Assad.”