Sanctions against Russia: UK introduces new Russian sanctions with key carve outs in respect of Russian oil refined in third countries and the maritime transport of LNG

On 19th May, 2026, the UK government introduced new trade and transport Russian sanctions, as well as two general trade licences providing for certain exemptions to the new measures.

The licences came into force on 20th May, 2026 and cover:

1. sanctioned processed oil products from third countries, namely diesel and jet fuel; and
2. the maritime transportation of LNG.

Sanctioned processed oil products from third countries

At the same time as introducing a UK prohibition on the import of oil products processed in a third country using Russian crude oil (similar to the EU’s ban in January, 2026), the UK introduced a general trade licence, which permits the import into the UK of the following otherwise prohibited goods processed in third countries from Russian crude oil:

• diesel (under commodity code HS 2710 19 42 or HS 2710 19 44); and
• jet fuel (HS 2710 19 21).

The licence also permits the provision of certain services related to their import, namely technical assistance, financial services such as insurance, funds and brokering services. The licence has a record-keeping requirement.

The licence took effect on 20th May, 2026 and is of indefinite duration. It can be varied or revoked by the Secretary of State at any time on 4 months’ notice.

The UK has also issued further guidance on this ban, available here: Guidance on third country processed oil product measures - GOV.UK

Maritime transportation of liquefied natural gas

The new UK measures ban the supply or delivery of Russian LNG by ship, including between third countries, as well as related financial and brokering services, broadly aligning with the EU’s similar LNG related measures. Like the EU, the measures include a transitional exemption which permits activity until 1st January, 2027 for contracts with a duration exceeding 1 year and which were concluded before 17th June, 2025.

However, under the UK licence issued at the same time, subject to certain conditions explored further below, a UK person may:

1. supply or deliver, by ship, LNG from the Sakhalin-2 LNG terminal or Yamal LNG terminal to a third country;
2. supply or deliver, by ship, LNG originating at the Sakhalin-2 terminal or Yamal LNG terminal, from one third country to another third country; and
3. provide financial services and funds for the activity described in a and b.

The conditions are:

1. The activity taking place is a contract with a duration of one year or less;
2. The LNG originates at the Sakhalin-2 LNG terminal or Yamal LNG terminal.

In addition, any person undertaking the permitted activity under this licence must inform the Department for Business and Trade within 30 calendar days of the activity beginning.

The licence took effect on 20th May, 2026, and will expire on 1st January, 2027. It can be varied, revoked or suspended by the Secretary of State at any time.

Additional UK shipping measures

The UK has also expanded its sanctions regime targeting specified ships, bringing it closer to the EU’s prohibitions on designated ships. The new UK measures prohibit the provision and procurement of a broad range of services in relation to designated ships, including technical, crewing, operational, chartering, brokering and financial services, as well as services relating to their acquisition or transfer. Separate shipping sanctions further prohibit the operation or chartering of specified ships. Previously, the main consequence of being a designated / specified ship was a UK port access ban

The criteria for designation have been widened to also include ships carrying Russian LNG and coal. Existing designations are not automatically subject to the new restrictions and may be reviewed on a case-by-case basis.

The approach to relaxing Russian sanctions

The US OFAC issued a waiver on 12th March, 2026, which permitted the delivery and sale of Russian crude oil and petroleum products loaded on ships before 17th April, 2026. That waiver was extended for a further 30 days on 18th May, 2026.

There is no present indication that the EU will follow the UK and US in relaxing certain Russian sanctions. As such, the EU’s import ban into the EU of petroleum products obtained in third countries that are derived from Russian origin crude oil remains in force, as detailed in our January, 2026 article, available here: Sanctions against Russia: Entry into Force of the EU Ban on Petroleum Products Derived from Russian Origin Crude Oil - UK Defence Club, as well as the EU’s ban on the transfer of Russian LNG by EU operators to third countries, as detailed here: Sanctions against Russia: UK, US and EU introduce further sanctions targeting the Russian energy sector - UK Defence Club

If Members have any questions in relation to the above issues they are invited to contact the Club for further information.