UK’s New Trade Sanctions Against Russia

The new measures, contained in Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 (the “2025 Amendments”) amend the Russia (Sanctions) (EU Exit) Regulations 2019 (the “2019 Regulations”).

The latest sanctions package shows that restrictive measures against Russia are here to stay. They also bring the UK sanctions programme more in line with EU prohibitions, including by imposing restrictions on certain sectoral software and technology.

Summary of the new sanctions measures

1. Software and Technology Prohibitions

The UK has introduced new prohibitions on the transfer and making available (directly or indirectly) to a person connected with Russia, or for use in Russia, of certain ‘sectoral software and technology’. The prohibition covers the following types of software and technology.

• Business Enterprise software and technology, defined as:

• enterprise resource planning software;
• customer relationship management software;
• business intelligence software;
• supply chain management software;
• enterprise data warehouse software;
• computerised maintenance management systems;
• project management software;
• product lifecycle management software;
• any component of the software described above, including human resource, accounting or fleet management components;
• any other information comprised in the software described above; and
• technology required for the development, production or use of the software described above.

• Industrial Design software and technology, defined as:

• building information modelling software;
• computer aided design software;
• computer aided manufacture software;
• engineer to order software;
• any component of the software described above;
• any other information comprised in the software described above; and
• technology required for the development, production or use of the software described above.

• Oil and gas related software and technology, defined as:

• oil and gas exploration and oil and gas production software;
• reservoir simulation software;
• drilling and completion software;
• software for oil and gas production management;
• hydraulic fracturing design and analysis software;
• any component of the software described above;
• any other information comprised in, or for use in, the software described above, including seismic analysis data or hydraulic fracturing data; and
• technology required for the development, production or use of the software described above.

As usual, the prohibition also covers the provision of related technical assistance as well as brokering, financial services and funds.

Furthermore, new technology transfer prohibitions have been added to the existing product restrictions, targeting the provision of technology related to military, dual-use, and other advanced manufactured and industrial products with value to Russia’s military-industrial and economic development. The new technology sanctions apply to information that is required for the development, production or use of sanctioned goods and software, which may include intellectual property and trade secrets.

The UK Government issued guidance on the new sectoral software sanctions and technology transfer sanctions. The guidance on sectoral software sanctions provides some clarification to businesses of the scope of application of these measures. In particular, it confirms that providing the restricted software by means of ‘Software as a Service’ (Saas), or accessing the software via an app, would fall within the scope of the prohibition. Interestingly, the guidance also suggests that businesses implement measures to ensure compliance, including – although these are not prescribed, the Government’s suggestions include:

• introducing clauses in contracts requiring additional controls to be implemented to ensure compliance with the restrictions on software and technology;
• introducing a ‘no-Russia clause’ into contracts to ensure sanctioned sectoral software and technology is not made available to a person connected with Russia, to a place in Russia, or for use in Russia
• increasing data collection on the end users of sectoral software and technology to assess whether the provision of sectoral software and technology is subject to prohibition;
• assessing compliance in existing business practice – for example, the provision of relevant sectoral software and technology to subsidiaries in Russia.

2. Export bans

Certain chemicals, certain lithium and polyethylene products, all-terrain vehicles, certain electronics, machinery, plastics, and metals have also been added to the list of sanctioned items contained in the 2019 Regulations schedules (amended by the 2025 Amendments) as listed below:

• Schedule 2A (critical-industry goods and critical-industry technology)
• Schedule 3 (energy-related goods and energy-related technology)
• Schedule 3C (defence and security goods and defence and security technology)
• Schedule 3E (G7 dependency goods and G7 dependency technology)
• Schedule 3I (Russia’s vulnerable goods and Russia’s vulnerable technology)

The supply and delivery, making available to, or for use in, Russia of these newly sanctioned items, and provision of related ancillary services are now prohibited.

3. Import bans

Additional prohibitions have been introduced on the importation of Russian-origin synthetic diamonds processed in third countries, as well as Russian helium.

The UK Government has issued a General Trade Licence relating to the importation of Russian synthetic diamonds processed in third countries. The licence authorises the importation of synthetic diamonds where they have not been located in Russia at any time beginning with 24 April 2025. The UK’s newly-published guidance on third country processed Russian synthetic diamonds restrictions sets out different scenarios in which the import ban would apply and suggests measures which businesses can take to demonstrate compliance (focused on documenting supply chain history).

Commentary

The new measures are a significant enhancement of the pre-existing measures against Russia and a strong indication that UK restrictions against Russia are here to stay, with the UK Government continuing to lead the way in relation to imposing innovative and targeted restrictions (such as the wide-reaching prohibitions on software and technology).

It is also helpful to see Government guidance published alongside the new legislation, which sets out examples of concrete steps that businesses can take to ensure compliance with the complex restrictions.