Regulatory Blog

On 16 February 2026, the UK Government, through the Office of Financial Sanctions Implementation, initiated a call for evidence on the implementation of the "Ownership and Control" test within UK financial sanctions regulations. This initiative requests to gather insights from businesses, legal professionals and other stakeholders to evaluate the clarity, effectiveness, and proportionality of the current framework.

On 26 January 2026, the Council of the EU announced the publication of the draft Regulation to phase out Russian pipeline gas and LNG imports. The Regulation operates as an amendment to Regulation (EU) 2017/1938 which contains measures safeguarding the security of gas supply in the EU. The ban will begin six weeks after the Regulation's entry into force, with a full ban on LNG by early 2027 and pipeline gas by autumn 2027. It is expected that the Regulation will be published in the Official Gazette imminently.

On 12 December 2025, the EU adopted Council Regulation (EU) 2025/2600, prohibiting the transfer of immobilised assets of the Central Bank of Russia, or entities acting on its behalf, back to Russia. This temporary measure is a direct response to the ongoing war of aggression against Ukraine and aims to mitigate the severe economic and security challenges posed by Russia's actions.

The recent enactment of the National Sanctions Implementation Unit Law 2025 and establishment of the National Sanctions Implementation Unit in Cyprus marks a significant milestone in the island’s sanctions enforcement regime.

On 16 October 2025, the European Securities and Markets Authority released its second consolidated report on sanctions and measures imposed in Member States for 2024. Here are the highlights:

The European Union has intensified its sanctions against Russia's "shadow fleet" in response to its ongoing aggression against Ukraine. Two recent measures highlight the EU's commitment to curbing Russia's revenue streams and addressing its violations of international law.

The Sanctions Order 2025 was published on 12 December 2025 and came into force on 11 December 2025. This updates the sanctions framework that applies across UK Overseas Territories, including the British Virgin Islands, Cayman Islands. The changes are also relevant to, by local extension, to Bermuda.

On 3 December 2025, the European Commission officially added Russia to its list of high-risk jurisdictions with strategic deficiencies in anti-money laundering and counter-terrorist financing frameworks. This decision follows the adoption of Delegated Regulation (EU) 2025/1393, which aims to amend and assess the EU AML list based on a review of third countries not listed by the Financial Action Task Force but whose membership is suspended.

On 3 December 2025, the European Commission put forward a comprehensive package of legal proposals designed to address Ukraine's ongoing budgetary and defence requirements for the years 2026 and 2027. These measures are presented as a strategic investment in European security and a mechanism to facilitate a fair and sustainable peace.

Jersey has implemented the Sanctions and Asset-Freezing Amendment Order 2025 (the Amendment Order), which came into effect on 5 December 2025.

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.

Following the invasion of Ukraine by Russia, the UK Government, alongside the member states of the European Union, the United States of America and other global stakeholders issued significant new sanctions. View a table of all the sanctions here.