28 May 2026 UK Expands Russia Sanctions Regime – Key Implications for Maritime, Energy and Trade The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 Introduction 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, timebound 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. Maritime Transportation of Russian LNG The Amended Regulations insert a new Chapter 4LA into the Russia (Sanctions) (EU Exit) Regulations 2019. This prohibits the supply or delivery by vessel of LNG (commodity code 2711 11 00) originating in or consigned from Russia, whether from Russia to a third country or between third countries. The prohibition applies to any person who directly or indirectly supplies or delivers such LNG by vessel, and extends to any person who owns, controls, charters, or operates a vessel on which the LNG is carried or from or to which it is transferred. Ship‑to‑ship transfer operations are expressly within scope of the prohibition. Separate prohibitions apply to the provision of financial services (including insurance), funds, and brokering services provided in connection with such arrangements. The Amended Regulations provide an exception for obligations arising under long‑term contracts concluded before 17 June 2025, where the contract duration exceeds one year (regulation 60L). This exception permits the continued provision of maritime transportation and related financial services until 1 January 2027, subject to the condition that the contract terms have not been materially amended after 17 June 2025, save for a defined set of permissible adjustments including reduced quantities, lower prices or fees, confidentiality amendments, operational procedure changes, address changes, intra‑group transfers, and amendments required by judic