Notice to exporters 2025/11: further sanctions against Russia introduced in April 2025

30 April 2025

 

Introduction

A tranche of new trade sanctions on Russia entered into force on 24 April 2025.

The legislation for the new measures is the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, found here:

https://www.legislation.gov.uk/uksi/2025/504/contents/made

The legislation amends sanctions legislation originally introduced in 2014. The latest version of the legislation is the Russia (Sanctions) (EU Exit) Regulations 2019 (the “2019 Regulations”), found here:

https://www.legislation.gov.uk/uksi/2019/855/contents

New measures

The new measures prohibit the export, supply and delivery, and making available to, or for use in Russia, of newly sanctioned items as well as the provision of related ancillary services. This includes chemicals, electronics, machinery, plastics, and metals added to existing schedules in the 2019 Regulations, namely:

  • 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)

Additionally, there are new prohibitions on the transfer, making available and ancillary services related to certain technology and software. This includes energy related, advanced and industrial manufacturing technology, and business enterprise, industrial design, and oil and gas related software and technology. They are detailed by amendments and additions to the 2019 Regulations in:

  • Chapter 4 (energy-related goods, energy-related technology and related activities)
  • Chapter 4H (G7 dependency and further goods and G7 dependency and further technology)
  • Chapter 4M (Russia’s vulnerable goods and Russia’s vulnerable technology)
  • Chapter 4N (sectoral software and technology)

Finally, import bans now apply to synthetic diamonds processed in third countries and helium. They are found in:

  • Chapter 4JC (certain diamonds processed in a third country)
  • Chapter 4JD (certain synthetic diamonds processed in a third country)
  • Schedule 3DA (revenue generating goods)

Exceptions

There are some exceptions to the prohibitions, which are set out in detail in the 2019 Regulations, and licences can be granted in very limited circumstances.

Kindly supplied by GOV.UK

 

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