Published 28 May 2026
On 20 May 2026, the UK Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (“Amended Regulations”) along with an Explanatory Memorandum came into force. This circular summarises the provisions of the Amended Regulations.
The Amended Regulations introduce a prohibition on the maritime transportation of Russian liquefied natural gas (LNG), strengthens the UK’s ship specification regime by introducing comprehensive service prohibitions for specified vessels, creates a new import prohibition on refined oil products processed from Russian crude oil, expands the lists of goods prohibited for export to and import from Russia, and introduces a prohibition on the provision of construction services to persons connected with Russia.
Key takeaways for Members:
Ban on maritime transport of Russian LNG, including third-country trades, with limited, time-bound exceptions and licensing arrangements.
Expanded ship sanctions regime introducing wide-ranging prohibitions on services (e.g. technical, chartering, insurance) for specified vessels; scope now includes LNG and coal shipments.
New UK import ban on refined oil products derived from Russian crude processed in third countries, with exemptions for diesel and jet fuel.
Further trade restrictions introduced across industrial goods, chemicals, metals, and advanced technologies (including AI, quantum and semiconductors), with wind-down to 20 November 2026.
Prohibition on construction services to persons connected with Russia, extending existing professional services restrictions.
New restriction on transport assets, prohibiting acquisition linked to detained assets, designated persons, or Russia-connected parties.
New prohibition on the import, acquisition and cross‑trade supply of Russian uranium and related services, subject to narrow exceptions.
All Clubs in the International Group have issued a similarly worded circular.
If you have any questions about this please contact Ingvild Høgenes Nilsen, EVP - Corporate Legal, Chief Legal Officer.
Yours faithfully,
GARD AS
Rolf Thore Roppestad
Chief Executive Officer
Gard is a member of
