Regulatory Blog

On 23 October 2025, the European Union has adopted its 19th package of sanctions against Russia, marking a significant escalation in its efforts to counter Russia's ongoing aggression in Ukraine. These measures target critical sectors of the Russian economy, including energy, finance, and military industries, while also addressing circumvention tactics and third-party enablers.

On 23 October 2025, the Cyprus Bar Association issued Circular 18/2025 regarding the 19th package of sanctions imposed by the European Commission against Russia, informing its members on the sanctions targeting actions undermining Ukraine's territorial integrity, sovereignty and independence.

European Union has issued significant and far-reaching sanctions and restrictive measures on Russia and the Russian Economy. View a table of all the sanctions here.

On 23 September 2025, the Cyprus Securities and Exchange Commission issued Circular C728, drawing attention to the recent amendments to Article 5h of Regulation (EU) 833/2014. These changes significantly expand the scope of restrictive measures against Russia in response to its military aggression against Ukraine.

The EU Advocate General's Opinion in Case C-483/23 sheds light on the application of the EU’s core sanctions regime under Regulation 269/2014 as regards assets placed in trusts by sanctioned individuals.

Following the triggering of the snapback mechanism in August 2025 by the UK, Germany and France under the 2015 Joint Comprehensive Plan of Action, the UN Security Council has now reimposed sanctions on Iran. The EU and the UK have also reimposed their own autonomous measures, which are super-equivalent to the sanctions imposed by the UNSC.

On 25 September 2025, the UK and Bermuda issued a joint statement reinforcing their commitment to sanctions enforcement. During a meeting in Hamilton, UK Minister for Overseas Territories Stephen Doughty and Bermuda Premier David Burt highlighted Bermuda’s leadership in freezing over $200M in sanctioned assets and ensuring robust compliance with UK sanctions.

The English High Court recently delivered a significant judgment in Thomas, Carter, Nilson v. PJSC National Bank Trust [2025] EWHC 75 (Ch), addressing whether UK sanctions laws would be breached by distributing bankruptcy funds to PJSC National Bank Trust, a Russian bank. This case provides critical guidance for trustees in bankruptcy navigating the complexities of sanctions compliance.

The English High Court's judgment in LLC EuroChem North-West-2 and Eurochem Group AG v Societe Generale S.A. and others [2025] EWHC 1938 (Comm) provides crucial guidance on the interpretation of "ownership" and "control" under EU sanctions regulations, particularly in complex corporate structures involving discretionary trusts.

The National Sanctions Implementation Unit is now established under the Ministry of Finance in Cyprus, and has been set up on 25 July 2025 following the passing of the Establishment of the National Sanctions Implementation Unit and the Implementation of Restrictive Measures and National Sanctions in the Republic Law of 2025.

France, Germany and the UK (the E3) have triggered the "snapback" mechanism under UN Security Council Resolution 2231, escalating diplomatic pressure on Iran regarding its nuclear programme. This decision, announced on 28 August 2025, follows years of escalating Iranian non-compliance with the Joint Comprehensive Plan of Action.

The UK Overseas Territories and Crown Dependencies have updated their sanctions lists to align with the latest UK measures against Russia.