The UK’s Russia sanctions regime continues to harden, and this month brings measures that will reshape shipping, insurance and trade workflows into 2026. For compliance leaders, the pace of change rewards those who move early: adjust screening rules now, align contract language, and secure audit-proof records before the next designation round lands.
This is your briefing on what changed, what still matters, and where to focus effort in the weeks ahead.
What changed this month
The headline is a UK ban on maritime services for Russian LNG exports announced on 12 November 2025. UK-linked shipping, insurance and related services will be off limits for all Russian LNG cargoes from 2026, extending the approach already used against Russian crude and products. Even though UK imports of Russian LNG were already banned, the new rule hits global logistics and finance that rely on UK service providers and insurers (see government release: gov.uk).
Compliance teams should also act on the Final Reminder to report frozen assets as at 30 September 2025, issued on 11 November. This annual review is not a box-tick. OFSI expects complete, accurate totals across accounts, securities and economic resources. Treat this as both an inventory exercise and a test of your sanctions data lineage.
There has been new licensing too. OFSI granted a time-limited General Licence on 14 November 2025 covering dealings with Lukoil Bulgaria entities under the Russia regime for three months, signalling a managed wind-down approach where sanctions intersect with essential supplies. Track the licence scope and end-date carefully, and lock it into your case management system so it triggers expiry alerts.
New designations continue to roll in. Joint allied actions this month target cyber and ransomware networks, with UK listings often following in short order. Expect additions across energy logistics and third-country facilitators as shadow fleet tactics attract more scrutiny.
This month at a glance
| Measure | Scope | Effective date | Who is impacted | Immediate actions |
|---|---|---|---|---|
| Maritime services ban for Russian LNG | Shipping, insurance, broking, certification for Russian LNG worldwide | 2026 (announced 12 Nov 2025) | Marine insurers, P&I clubs, brokers, charterers, traders, banks financing cargoes | Map LNG touchpoints, amend attestations and clauses, set 2026 stop-dates, update deal screening |
| Frozen Asset Review reminder | Annual report of frozen assets as at 30 Sep 2025 | Reminder issued 11 Nov 2025 | Banks, custodians, asset managers, corporates holding frozen assets | Reconcile holdings, evidence valuations, submit on time, retain audit trail |
| General Licence for Lukoil Bulgaria | Limited dealings authorised for wind-down | 14 Nov 2025 for 3 months | Energy traders, fuel distributors, banks serving affected clients | Validate counterparty scope, apply licence conditions, diarise expiry, pre-clear edge cases |
| Ongoing designations (energy, cyber, shipping) | Asset freezes and ancillary prohibitions | Rolling | All firms with Russia exposures or high-risk geographies | Refresh lists daily, rescreen active clients, re-paper contracts, assess sanctions clauses |
Core rules that still shape your decisions
The backbone remains the Russia (Sanctions) (EU Exit) Regulations 2019. Asset freezes prohibit dealing with funds or economic resources of designated persons, whether individuals or entities, and extend to making resources available to them. Financial prohibitions clamp down on capital market access, loans, correspondent banking, trust services and investment in Russian sovereign debt and equity. OFSI enforces, licenses and penalises, and the FCA expects regulated firms to have systems that actually block and report, not just policies on paper.
Trade and export controls are extensive. The UK operates a full arms embargo and bans exports of dual-use and advanced tech items listed across schedules, covering semiconductors, aerospace components, maritime navigation goods, quantum and AI-linked technologies. OTSI, the new trade sanctions regulator within the Department for Business and Trade, oversees civil enforcement for import/export breaches, complementing HMRC criminal powers. Expect more OTSI casework in 2026.
Energy remains a special case. UK imports of Russian oil and gas are prohibited, the G7 Oil Price Cap now sits at 47.60 dollars per barrel for crude, and shipping sanctions target vessels tied to evasion and unsafe practices. Transport sanctions add port and airspace bans. The Home Office keeps travel bans updated for sanctioned individuals, often aligned with financial listings.
Screening and controls that stand up to scrutiny
A risk-based screening architecture needs to run across counterparties, payments, cargoes and vessels. The FCA calls out that AML checks alone do not catch sanctions breaches, so sanctions filters must be explicit, tested and frequently updated. That means fuzzy matching tuned to reduce false positives without letting near matches slip through, plus a case management workflow that documents decisions and escalations.
Third-country routes deserve heightened attention. Government alerts describe patterns like opaque corporate structures in high-risk hubs, serial flag hopping, AIS dark activity and last-minute cargo re-documentation. Build those signals into rules and monitoring thresholds rather than treating them as afterthoughts.
After reviewing the current rule set, many teams find quick wins in permissions and attestations. Move price-cap attestations from soft representations to binding contractual warranties, and require underlying documentary proof rather than certificates alone for higher-risk trades.
- Screen everyone and everything: Customers, beneficial owners, directors, payees, vessels, suppliers and logistics intermediaries at onboarding and throughout the relationship.
- Tighten transaction filters: Apply list screening to wires, letters of credit, bills of lading, charterparties and insurance binders, not just names in the CRM.
- Refresh daily, test quarterly: Subscribe to OFSI and gov.uk alerts, push automated updates to tools, and prove control effectiveness with documented testing.
LNG and oil shipping: operational watchpoints
The LNG maritime services ban will demand changes across the pre-trade, trade and post-trade cycle. Insurers will need exclusionary language for Russian LNG, brokers will require data-backed attestations from clients, and banks will want enhanced due diligence where counterparties have any LNG exposure.
The price cap regime for oil continues to bite. Service providers must obtain and retain attestation chains that evidence compliant pricing. Compliance leaders should pressure test their evidence packs: would they withstand a regulator asking for full voyage documentation, not just a single attestation?
These are the practical controls many teams are putting in place now:
- Contract clauses hardened for sanctions and price cap breach
- Voyage-by-voyage attestations with source data
- Vessel screening tied to port state control and flag changes
- Counterparty risk ratings that weight shadow fleet indicators
Contracts, licences and reporting
Contract hygiene is a recurring weakness. Sanctions clauses copied from pre-2022 templates will not handle the LNG ban, price-cap attestations or fast-moving designations. Renegotiate with clear termination rights, information rights, and obligations to provide underlying trade documents on demand. Time your re-papering to coincide with renewals and rollovers to reduce friction.
Licensing needs discipline. OFSI’s General Licences are precise on scope and timings, and individual licence applications benefit from complete, well-structured submissions with evidence of diligence already taken. Keep a register of licences, conditions and expiry dates. Tie those to trade controls so a shipment cannot proceed if a licence lapses mid-voyage.
Frozen asset reporting should be treated as a data-quality project. Align client static data, account-level assets, securities positions and any non-cash economic resources. Record valuation methods, FX rates and the dates applied, then store the pack in a way that allows a regulator to re-perform your numbers.
- Who reports: Firms that know or suspect they hold frozen assets for designated persons.
- What to include: Balances, securities, economic resources, valuation basis, identifiers.
- How to evidence: System extracts, reconciliation notes, screenshots, and decision logs that show why assets are in scope.
Where UK rules diverge from EU and US
Divergence is real, particularly for service bans and sector scopes. A UK-only list addition or a UK General Licence can create mismatches against EU or US frameworks. Multinationals should avoid “lowest common denominator” policies and instead apply the strictest applicable rule to each transaction based on parties, goods, currency, and service footprint.
The UK has also published guidance for non-UK businesses with UK touchpoints. Entities operating through third countries but using UK finance, insurance, or personnel can fall within scope. High-risk diversion routes in parts of the Caucasus and Central Asia require detailed end-use checks and contractual undertakings on no re-export to Russia, backed by audit rights. Testing those rights once in a while sends a powerful message.
Sector spotlights
Energy and commodities face structural change. Traders and shippers must maintain robust attestation chains, risk-rank counterparties involved in Russian-origin cargoes to third countries, and adapt to the LNG services ban before it activates. Insurers should update policy wordings, underwriting guidelines and referral criteria for any voyage with a Russian nexus. Banks should strengthen checks on trade finance deals tied to oil or gas flows that could breach sanctions or the cap.
Finance and banking need precision in data. Field-level static data for designations has to be synchronised across core banking, payments, securities and custody platforms. Screen at the customer, account and transaction level. With more ransomware and cyber facilitators entering lists, payments to technology vendors or exchanges in higher-risk jurisdictions deserve extra review, especially where crypto is involved.
Technology and defence exporters are living with tight controls. If your product sits anywhere near the Common High Priority list, license checks should be mandatory. Kill switches in contracts that activate on designation help prevent over-compliance without losing control. For suppliers to aerospace, electronics or heavy machinery, map your upstream vendors to ensure none have been listed in the recent UK actions against China-based facilitators.
How RusCrime can help your horizon scanning
We are not a law firm or a regulator, so you will not find a sanctions checklist or a screening engine on our site. What you will find is reporting that traces people, companies and networks across Russia’s criminal and industrial landscape. That context matters when a name appears in your screening queue and you need to understand potential affiliations, past deals, and the stories that sit behind a shell company.
Use official sources for rules and licences, then pair them with open-source intelligence to build a richer picture of counterparties and patterns. Our newsroom tracks corruption probes, shipping manoeuvres and supply-chain workarounds that often foreshadow designation waves. If your risk team watches these signals, policies can be tightened ahead of the lists.
The compliance advantage goes to teams that translate policy shifts into system rules, contract terms and habits on the ground. The UK regime is tightening, but with the right controls you can keep trade moving, protect your firm and support enforcement goals.
Useful links for immediate action: UK Russia financial sanctions guidance (gov.uk), the sanctions collection with Oil Price Cap industry guidance (gov.uk), FCA sanctions expectations for firms (fca.org.uk), and OTSI information on trade sanctions enforcement (gov.uk).
