Circular 20/25: EU, UK and US Sanctions Updates OIL PRICE CAP – UPDATE 15 th JANUARY 2026 Please note that the EU and UK have confirmed that effective 23:01 GMT 31 January 2026 (UK) / 1 February 2026 (EU) the price cap for Russian crude is US$44.10 per barrel. Under the UK price cap , for any trades with an effective date of contract before 23:01 GMT 31 January and compliant with the existing price cap of US$47.60, there is a wind down period ending at 22.59 BST on 16 April 2026.  Under the EU price cap scheme, contracts concluded under the previous price cap can be executed for 90 days from 15 January 2026.   This circular provides an overview of new EU, UK, and US sanctions against Russia introduced in October 2025, focusing on energy sector restrictions, expanded export controls, and increased measures against sanctions evasion. Key impacts and compliance guidance for Members are outlined below.   October and November 2025 have witnessed a significant wave of new restrictions and designations against Russia, introduced by the EU, the UK, and the US. Further details are set out below, but we highlight several key common themes: Coordinated escalation targeting Russia’s energy sector, with particular focus on LNG (including insurance of the carriage of LNG) and major oil companies. Heightened scrutiny of shadow fleet operations and third-country intermediaries facilitating sanctions evasion. Broadened export controls and tightened financial measures aimed at closing circumvention channels. EU Sanctions – 19th Package On 23 October 2025, the Council of the European Union introduced its 19th sanctions package , significantly expanding restrictions on Russia’s energy sector, financial infrastructure, and military-industrial complex by amending  Regulation (EU) 833/2014  and  Regulation (EU) 269/2014 . Key measures include: Energy Sector Comprehensive ban on imports of  LNG originating in or exported from Russia into the EU: Effective