The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 were made on 18 May 2026, laid before Parliament on 19 May and came into force on 20 May 2026. The instrument, signed by Foreign, Commonwealth and Development Office Minister of State Stephen Doughty, extends across the United Kingdom and was made under the Sanctions and Anti-Money Laundering Act 2018, using the made affirmative procedure that requires approval by both Houses within the statutory 28-day period. The publication note on legislation.gov.uk states that the instrument is being issued free of charge to known recipients of S.I. 2025/504 in order to correct errors in that earlier instrument. Alongside that correction note, the published text makes a wide set of amendments to the Russia (Sanctions) (EU Exit) Regulations 2019, widening the UK regime across trade controls, shipping restrictions, licensing and enforcement.
The published amendments create a new regime for specified ships. According to the Regulations, a person must not provide technical assistance, crew services, operating services, chartering services, brokering services, financial services or funds in relation to a specified ship, and must not provide services linked to that ship's acquisition, sale, transfer or supply. A separate prohibition covers the procurement of services relating to a specified ship, including services involving the use of that ship. Part 6 of the 2019 Regulations is widened at the same time. A person must not charter or operate a specified ship if they know, or have reasonable cause to suspect, that it is specified, and the Registrar must refuse UK registration for such a vessel. The text also creates limited exceptions where conduct is necessary for ship safety or the protection of life, and a further carve-out for non-UK persons exercising rights of innocent passage or transit passage. For shipowners, charterers, operators, financiers and brokers, the immediate effect is that sanctions checks now have to cover the status of the vessel itself, not only the identity of the counterparty.
The amendments also move further into energy trade. New regulations 46Z9F to 46Z9I prohibit the import of relevant processed oil products where third-country processed products falling within commodity code 2710 are made from Russian crude falling within commodity code 2709. The ban is paired with restrictions on technical assistance, finance and brokering, which matters because the policy is aimed at indirect routing as well as direct Russian imports. For liquefied natural gas, the Regulations prohibit maritime supply or delivery by ship of Russian-origin or Russian-consigned LNG from Russia to a third country and between third countries. The Explanatory Note says associated financial services and brokering are also prohibited, and the text treats ship-to-ship transfers as part of the same activity. The ship specification rules are expanded as well, so vessels involved in Russian-origin LNG and coal movements can be specified for sanctions purposes. There is, however, a continuity exception for certain LNG supply contracts concluded before 17 June 2025, where the contract runs for more than a year, is not materially amended beyond tightly defined changes, and the activity is completed before the end of 1 January 2027.
A separate block of amendments introduces uranium controls. The instrument prohibits the import of uranium consigned from Russia or originating in Russia, the acquisition of uranium originating in or located in Russia, and the supply or delivery of uranium from Russia to a third country. Technical assistance, financial services, funds and brokering tied to those activities are also brought within scope. The text includes targeted exceptions. According to regulation 60K, otherwise prohibited activity may continue where it is necessary for the continued operation of a nuclear installation in a third country that was already operational on 20 May 2026. A further exception applies to Russian-exported uranium that left Russia before 20 May 2026 and is stored in a third country. That is a narrow continuity measure rather than a general exemption, so operators will still need documentary evidence on export date, storage location and end use.
The instrument also creates a new prohibition on the acquisition of detained transport assets. A person must not acquire, or purport to acquire, a detained transport asset from, or for the benefit of, a designated person or a person connected with Russia. The Regulation goes further than a standard trade ban: such a transaction is treated as void and ineffective for all purposes, including under contract and property law, regardless of the law governing the agreement. For this purpose, a detained transport asset means a ship or aircraft already subject to a detention direction under the existing Russia sanctions framework. Construction services are added to the list of restricted professional and business services. The Schedule 3J definition is broad, covering site investigation, demolition, civil engineering, installation work, finishing work and equipment rental with operator. The Regulations create a wind-down until the end of 20 August 2026 for contracts concluded before 20 May 2026, subject to notification to the Secretary of State, and they also allow work that is necessary for essential maintenance where justification is supplied within five working days of the work beginning.
Beyond the headline trade bans, the measure updates several goods schedules that sit behind the wider sanctions regime. Engineering biology ancillary goods are added to the defence and security goods framework, and the Explanatory Note says new items are also added to the critical-industry, quantum computing and G7 dependency schedules. The published schedules include advanced chip-production chemicals, quantum and cryogenic components, AI accelerators, sensor-fusion modules and a new set of engineering biology items such as cell cultures, enzymes, culture media, gene-editing tools and microfluidic bioreactors. There are transition provisions for some of those goods. Regulation 60J allows pre-existing contracts concluded before 20 May 2026 to be performed until 20 November 2026 for advanced chip-production chemicals, quantum goods and engineering biology ancillary goods, provided the Secretary of State is notified. The emergency exception in regulation 61 is also widened so that the new goods controls, the specified ship prohibitions, the uranium measures and the LNG shipping rules all sit within the existing emergency carve-out.
Licensing is expanded in parallel. The Regulations create a detained transport asset licence and a ships licence, and make clear that the new prohibitions can be disapplied where the Secretary of State has issued the relevant authorisation. The same instrument creates new offences for knowingly or recklessly providing false information in order to obtain those licences, and makes a licence void from the moment of issue if such an offence has occurred. A person who purports to act under a licence but fails to comply with its conditions also commits an offence. Enforcement powers are updated across the regime. Penalty provisions, jurisdiction rules, trade enforcement and maritime enforcement are all amended so that the new offences can be investigated and prosecuted. The Explanatory Note says the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 are also amended so that detained transport asset offences are carved out of the usual CEMA route and certain detained transport asset and ship licensing offences fall within the investigatory powers in the Serious Organised Crime and Police Act 2005.
For compliance teams, the immediate issue is that the instrument is not confined to one commodity or one sector. It changes vessel-based screening, goods classification, contract review, notification procedures and licence governance in a single legislative step. Firms involved in shipping, insurance, commodities, nuclear fuel, construction, advanced manufacturing and trade finance will need to recheck whether their controls currently capture specified ships, Russian-origin inputs processed in third countries and the revised commodity codes in the schedules. The published text also matters because several protections are date-specific. Key cut-offs include 20 August 2026 for construction services wind-down, 20 November 2026 for certain goods contracts and 1 January 2027 for qualifying LNG contract activity. The policy position is therefore more exacting than a simple sanctions expansion: organisations now have to distinguish between activity that is prohibited outright, activity that can continue only under a temporary exception, and activity that requires a formal licence before any step is taken.