Regulatory & International Trade | RIT
Helping businesses clear legal regulatory hurdles in Europe
Regulatory & International Trade | RIT
Regulatory & International Trade | RIT
Helping businesses clear legal regulatory hurdles in Europe
Russia Sanctions
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Quarterly Sanctions Update | Q3 2025

The third quarter of 2025 marks greater coordination between the European Union and United Kingdom on sanctions, specifically with respect to lowering the price cap on Russian oil, broadening the range of targeted individuals and entities, and introducing new measures against sanctions circumvention via third countries.

Key developments also include new sectoral restrictions, expanded export control powers, targeted guidance for high-risk industries and jurisdictions, and increased enforcement focus.

Beyond Russia, both the European Union and United Kingdom maintained pressure on Belarus, Iran, and Libya, with the UK also proscribing Palestine Action as a terrorist group.

In this update, our global team provides an in-depth look at key developments introduced between June and August 2025, highlighting what these changes mean for businesses across affected sectors.

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Quarterly Sanctions Update | Q3 2024

Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week, however, a new package of sanctions aimed at tackling hybrid operations by the Russian government has been agreed upon, and is expected to be published in the coming weeks. In the same period, the Court of Justice of the European Union (CJEU) issued a number of landmark judgments clarifying certain aspects of the EU sanctions regime and has, in one instance, openly disagreed with the interpretation of the regime by the European Commission.

Furthermore, in line with the overarching goal of EU sanctions against Russia, which is to support Ukraine, for the first time, the European Union has transferred profits from frozen assets of the Russian Central Bank to the European Peace Facility and the Ukraine Facility, which will used the monies in support of Ukraine’s military and reconstruction needs.

Finally, acknowledging the current geopolitical situation in the Middle East, the European Union and United Kingdom continued to issue new sanctions against Hamas and Iran. The United Kingdom has also revoked certain licences allowing the sale of [...]

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