Files / United Kingdom

Sanctions Update: EU and UK Strengthen Restrictions on Russian Oil and Software Provision to Russia.

Based on the EU's sanctions from [start month and year] to [end month and year] (rounds [start round] to [end round]) and relevant UK legislation, analyze the evolution of the Western sanctions system against Russia, key provisions, and the expansion of "best efforts" obligations.

Detail

Published

22/12/2025

Key Chapter Title List

  1. EU 15th Sanctions Package – Key Updates
  2. EU 16th Sanctions Package – Key Updates
  3. EU 17th Sanctions Package – Key Updates
  4. EU 18th Sanctions Package – Key Updates in the New Round of Measures
  5. UK's Key Sanctions Against Russia in 2025
  6. Contact

Document Introduction

This report is based on a client alert issued by Latham & Watkins on August 18, 2025. It systematically outlines a series of the latest sanctions measures implemented by the European Union and the United Kingdom against Russia and related parties from December 2024 to July 2025. The report focuses on the continuous evolution of the sanctions regime, particularly how successive "sanctions packages" have consistently filled loopholes, expanded scope, and strengthened enforcement mechanisms. This reflects the Western alliance's refined and long-term strategy of exerting economic pressure on Russia.

The main body of the report provides a detailed chronological analysis of the core content of the EU's sanctions packages from the 15th to the 18th. Key developments include: a significant expansion of the targets from entities within Russia to include third countries and individuals, such as those in China, Turkey, and India, demonstrating the trend towards "secondary" and "extraterritorial" application of sanctions; regarding Russian oil exports, measures have evolved from the initial price cap mechanism to attempts to block the "backdoor" of refined products entering the EU market via third countries, alongside the introduction of strict crude oil origin certification requirements; in terms of trade restrictions, the embargo list has been continuously expanded to cover a variety of goods, from specific industrial software (e.g., for oil and gas exploration, banking software), electronic products (e.g., video game controllers), to primary aluminum.

The report pays special attention to the strengthening of sanctions enforcement mechanisms. In its 16th package, the EU extended the "best efforts" obligation from the original trade sanctions regulations to other areas of sanctions against Russia, such as asset freezes. This requires EU natural and legal persons to exert influence over non-EU companies under their control to ensure these companies do not engage in activities that undermine EU sanctions. Furthermore, the sanctions measures include expanding transaction bans on Russian banks (including "de-SWIFTing" and targeting banks using the Russian financial messaging system), restrictions on specific ports and infrastructure, and countermeasures against legal tools related to so-called "investor-state disputes."

In addition to EU actions, the report also analyzes the progress of UK sanctions against Russia in 2025. The UK, in coordination with the US, lowered the price cap for seaborne Russian crude oil. It followed the EU in prohibiting the provision of specific types of "industry software" to Russia or persons associated with Russia, while also providing limited transitional period licenses for the exit of multinational companies' operations. These measures by the EU and the UK maintain coordination in core areas, collectively forming a complex network of economic pressure on Russia.

The content of this report is strictly based on published official regulations and legal analysis. It aims to provide researchers, policy analysts, and businesses affected by sanctions with an authoritative overview and summary of key recent developments in Western sanctions against Russia. This report does not constitute legal advice. However, it reveals a clear trend of increasing complexity, expansion, and stricter enforcement within the current sanctions system, holding significant reference value for understanding the "lawfare" and "rule-shaping" aspects of major power economic competition.