On April 23, 2025, the UK Government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 (the “Amending Regulations”), which took effect on April 24, 2025. The Amending Regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019 by adding further trade restrictions. These measures follow the latest round of UK sanctions on the third anniversary of Russia’s invasion, as discussed in a previous Insight available here.
New measures include:
- Restrictions related to sectoral software and other technology involving controlled goods;
- Export bans on new items including chemicals, electronics, machinery, plastics, and metals; and
- Import bans targeting helium and synthetic diamonds of 0.5 carats or more produced in third countries and mined in Russia.
Many of the measures bring the UK rules into alignment with those of the European Union to ensure a united front between international partners.
Sectoral Software and Other Technology Restrictions
The Amending Regulations introduce a new software restriction on making available and transferring “sectoral software and technology” to persons connected with Russia or for use in Russia, as set out in the newly added Schedule 3IA which includes:
- Business enterprise software and technology (e.g., enterprise resource planning software and customer relationship management software);
- Industrial design software and technology (e.g., building information modelling software and computer aided design or manufacture software); and
- Oil and gas related software and technology (e.g., oil and gas exploration and production software and reservoir simulation software).
The prohibition on “ancillary services” catches any financial services or technical assistance provided in connection with the software.
Further, the Amending Regulations introduce additional restrictions on transferring technology “required” for the “development,” “production,” or “use” of a broad range of controlled goods, including those listed as G7 dependency and further goods, Russia’s vulnerable goods, and energy-related goods.
Export Bans
The Amending Regulations include prohibitions on the export, supply, and delivery, and making available to, or for use in Russia, of chemicals, electronics, machinery, plastics, and metals, as well as the provision of any ancillary services. This is mainly targeted at any goods which have the potential to have military or industrial use, including video game console controllers to Russia, following reports that these have been repurposed to pilot drones in Ukraine.
Exporters should check their products against the updated lists to ascertain if any additional controls are needed to ensure compliance with the updated regime.
Import Bans
Another measure introduced in the sanctions update is a ban on the import of helium and synthetic diamonds of 0.5 carats or more produced in third countries and mined in Russia, targeting a revenue stream that the Russian government may use to fund the war in Ukraine.
Although some exceptions apply, businesses should be aware that these are limited and partaking in any of the above activities significantly increases the risk of enforcement action.
