October 2025 has witnessed a significant wave of new restrictions and designations against Russia, introduced by the EU, the UK, and the US.

Further details are set out below, but we highlight several key common themes:

• Coordinated escalation targeting Russia’s energy sector, with particular focus on LNG and major oil companies
• Heightened scrutiny of shadow fleet operations and third-country intermediaries facilitating sanctions evasion
• Broadened export controls and tightened financial measures aimed at closing circumvention channels.

EU Sanctions – 19th Package

On 23 October 2025, the Council of the European Union introduced its 19th sanctions package, significantly expanding restrictions on Russia’s energy sector, financial infrastructure, and military-industrial complex by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. Key measures include:

• Energy Sector
  • Comprehensive ban on imports of Russian LNG into the EU:
    • Effective 25 April 2026 for short-term contracts
    • Effective 1 January 2027 for long-term contracts
  • Prohibition on transshipment of Russian LNG in EU ports
  • Ban on technical and financial assistance (including insurance) related to  LNG originating in or exported from Russia (applicable as of 25 April 2026 (unless the contract for supply of LNG exceeds one year in duration and was concluded before 17 June 2025 – in which case the prohibition applies as of 1 January 2027).
  • Tightened transaction ban on Rosneft and Gazprom Neft
• Third-Country Enablers
  • Sanctions on Chinese entities (two refineries and an oil trader) purchasing Russian crude
  • Listing of Litasco Middle East DMCC (Lukoil’s UAE-based company)
• Additional Measures
  • 69 individuals designated
  • 45  entities designated for supporting Russia’s military and industrial complex
  • 117  vessels designated, becoming subject to a port access ban and a ban on the provision of a broad range of services (including insurance) related to maritime transport (bringing the total number of designated vessels to 557)
  • Expanded export controls on electronic components, military-grade metals, and industrial goods
  • Import restrictions on additional metal, oxides and alloys used in the military systems and acyclic hydrocarbons
  • Sanctions on maritime registries providing false flags to shadow fleet vessels
  • Prior authorization requirement for any services provided to the Russian Government not already covered by Regulation (EU) 833/2014
  • Transaction ban expanded to five Russian banks (Istina Bank, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank). Four banks from Belarus and Kazakhstan are also put under a transaction ban, due to their connections to Russian financial messaging and payment systems.

UK Sanctions

On 15 October 2025, the UK designated Rosneft and Lukoil, as well as Nayara Energy Limited (the Indian refinery in which Rosneft is a 49% shareholder), and various other companies. The UK Government’s press release for these measures is available here.

Rosneft and Lukoil were added to the UK asset freeze list

• Additional 90 asset freeze targets, including:
  • Four Chinese oil terminals
  • Indian Nayara Energy Limited
  • 51 tankers and LNG carriers
  • Five Russian financial institutions
  • Defence sector entities
• General Licences
  • General Licence INT/2025/7539056 authorises wind-down of transactions involving Rosneft and Lukoil, and entities owned or controlled by these entities. This licence expires at 23:59 on 28 November 2025.
  • General Licence INT/2025/7538856 authorises wind-down of transactions involving certain energy entities, including Nayara Energy Limited. This licence  expires at 23:59 on 13 November 2025.
  • Additionally, on 22 October 2025, OFSI published a General License INT/2025/7598960 authorising business operations involving the Rosneft subsidiaries Rosneft Deutschland GmbH and RN Refining and Marketing GmbH. OFSI also updated FAQs (no. 169) confirming that UK sanctions are not intended to negatively affect the operations of these entities, who have been under trusteeship by the German government since 2022. 

US Sanctions

On 22 October 2025, the US imposed full blocking sanctions on Russia’s two largest oil majors:

• Rosneft and Lukoil designated on the SDN list, along with several subsidiaries
• All entities owned 50% or more by either company are blocked
• OFAC issued four general licences, including  Russia-related General License 126, “Authorizing the Wind Down of Transactions Involving Rosneft or Lukoil until 21 November 2025
  
  Impacts

The measures outlined above represent a further escalation of sanctions against Russia. Most notable are the measures taken against Rosneft and Lukoil, both of whom are substantial cargo suppliers and shippers of oil and other energy products from Russia. Subject to the wind down permitted under the UK’ and US’ respective General Licences, Members must ensure that they have terminated all commercial and contractual relationships – including charter parties – with these entities and discharged any cargoes where these entities may be the cargo owner by the expiry date of those General Licences.  In effect, that means by latest 21 November 2025. Failure to do so may expose Members to sanctions enforcement measures by the relevant sanctions authorities.

Members are reminded that cover is not available for any trade that breaches applicable sanctions. Members are advised that they should conduct thorough due diligence on the parties, cargoes, vessels, and other service providers that are or may be involved before they engage in any trade with a high sanctions risk. Finally, Members are reminded to keep records of their due diligence investigations and findings.

 All Clubs in the International Group have issued a similarly worded circular.