Executive Summary
- What’s new: In October, the EU adopted its largest-ever set of designations relating to Russia, and the UK implemented new sanctions targeting Russian oil and gas producers, shadow fleet tankers, payment and crypto platforms, and third-country suppliers.
- Why it matters: The EU’s 1,646 new designations are the largest single set since Russia’s full-scale invasion of Ukraine and extend the asset-freeze perimeter deep into Russia’s industrial supply chain. Similarly, the UK’s latest designations capture more than 90% of Russia’s oil production capacity and reach financial and crypto intermediaries outside Russia.
- What to do next: Companies should consider screening counterparties, suppliers and payment chains, while mapping ownership and control exposure with heightened scrutiny, as the volume of sanctioned parties becomes increasingly challenging to manage. Companies may also want to watch for the European Commission’s 22nd package, which is expected to consist of sectoral sanctions, likely further targeting Russia’s oil revenue.
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European Union
On 12 October 2026, the EU imposed further sanctions on Russia, adding to the EU’s asset-freeze list 826 entities and 743 individuals — all part of Russia’s military-industrial complex — and 77 candidates involved in the illegal September 2026 elections to the Russian State Duma.1 The listed companies generate an annual turnover of at least €20 billion and employ more than 250,000 people, extending the asset-freeze perimeter deep into Russia’s industrial supply chain.
New Designations
These designations fall under two distinct thematic regimes. Under the regime targeting actions that undermine or threaten Ukraine’s territorial integrity, sovereignty and independence, Council Implementing Regulation (EU) 2026/2281 (Regulation 2281) added 826 entities and 743 individuals to Annex I of Council Regulation (EU) No 269/2014 (Regulation 269).2 Neither act changes the designation criteria or adds sectoral measures.
The new listings were based on Russia’s continued and escalating aggression against Ukraine, in particular its military campaign against civilian infrastructure, and in response to the European Council’s call of 18 and 19 June 2026 to step up pressure on Russia through further sanctions.3
The entities came from a list recently established by the Russian government that identifies them as belonging to the Russian military-industrial complex and therefore eligible for government subsidies.4
The targets are midlevel suppliers that the EU describes as the “core” of the Russian military industry, supplying key components for missiles, unmanned aerial vehicles and aircraft.5 The component categories are:
- Electronics, including semiconductors, microcircuits and computers.
- Communication equipment, including radars, antennas and transceivers.
- Aviation, satellite and missile systems.
- Explosives and ammunition.
- Optics and navigation systems.
The new designations reach beyond classic defence manufacturing into adjacent industries, including shipyards, chemical and reagent plants, instrument and machine-building works, textile producers and research institutes.
Under the same Ukraine regime, Council Implementing Regulation (EU) 2026/2292 (Regulation 2292) amended Regulation 269 by adding 77 individuals who stood as candidates in the “illegal so-called ‘elections’ for the Russian State Duma,” held in September 2026 in the temporarily occupied territories of Ukraine, to its Annex I.6
Under the separate regime concerning the Democratic People’s Republic of Korea, Council Implementing Regulation (EU) 2026/2278 added three individuals and four entities to Annexes XV and XVI of Council Regulation (EU) 2017/1509, in each case over DPRK-Russia military, shipping or labour cooperation.
Three of those entities are Russian companies and two of the individuals are the companies’ executives, listed for employing DPRK workers in Russia or forming joint ventures with the DPRK in breach of United Nations Security Council resolutions.7
Key Measures
Under all of the relevant regimes, designations trigger an asset freeze: EU operators must freeze all funds and economic resources belonging to, owned, held or controlled by the designated persons, and may not make funds or economic resources available, directly or indirectly, to them or for their benefit. Additionally, the individuals are targeted by travel bans.
United Kingdom
On 1 and 8 October 2026, the UK added 69 new entries to the UK Sanctions List, covering Russian gas and oil, shadow fleet vessels, banking, payment and cryptocurrency platforms, military supply chains and human rights abuses in occupied Ukraine.
These latest designations capture more than 90% of Russia’s oil production capacity, bring the number of sanctioned shadow fleet vessels to more than 600, and reach financial and crypto intermediaries outside Russia.
New Designations
On 1 October 2026, the UK added 31 entries to the UK Sanctions List: 22 individuals, one entity and eight ships.8 On 8 October 2026, it added an additional 38 entries.9
The packages differ in focus. The 1 October sanctions targeted Russia’s liquefied natural gas shadow fleet, Kremlin disinformation networks and the perpetrators of alleged civilian torture and child indoctrination. These included Novatek Gas and Power Asia Pte Limited, and Novatek and Gazprom-operated liquefied natural gas (LNG) tankers.
The sanctions on 8 October targeted individuals and entities, including those:
- Involved in Russian oil production and transport.
- Involved in the production or trade of items used to support Russia’s military capabilities, including a Dutch national, Chinese entities and a Turkish metals trader.
- Allegedly assisting Russia in evading sanctions, including financial services and crypto platforms.
The designation of an EU national for his alleged association with a third-country entity exporting tools to Russia is particularly notable and reiterates the focus of UK authorities in seeking to tackle and deter circumvention of UK sanctions.
The newly listed individuals and entities are subject to asset freezes, trust services sanctions and director disqualification sanctions; the individuals also face travel bans.
The sanctioned vessels are specified under Regulation 57F, which was amended on 20 May 2026 to significantly expand the UK sanctions restrictions applicable to specified vessels, bringing it closer to the EU position.10 The newly sanctioned vessels are subject to the full range of shipping and trade sanctions, including those implemented on 20 May 2026 (e.g., no chartering or operating, no UK port entry, port barring, movement and detention directions, termination of UK registration, and a prohibition on directly or indirectly providing or procuring technical, crew, operating, chartering, brokering, insurance or financial services in relation to the vessel).
General Licences
On 1 October 2026, the UK’s Office of Trade Sanctions Implementation issued two general trade licences related to shipments of LNG to Japan and South Korea (the General Licences).11 This follows the UK’s new trade sanctions, introduced on 20 May 2026, that prohibit UK person involvement in the maritime transport of Russian LNG and certain associated services. From 1 January 2027, those sanctions will extend to trade under long-term contracts concluded before 17 June 2025.
The General Licences provide that, between 1 January 2027 and 31 March 2028, UK persons may be involved in the supply or delivery of LNG by ship from Russia or from a third country to either Japan or South Korea, together with related financial, brokering and legal advisory services, in certain limited circumstances.12
The General Licence will apply where:
- the activity arises under a contract for the supply of LNG concluded before 17 June 2025, and
- the LNG originates from the Sakhalin-2 project.
The General Licences are narrow and do not cover the full range of potential activity prohibited by UK sanctions in this context (e.g., the payment of funds to a designated person in connection with the shipment). Any person utilising the General Licences must inform the UK Department for Business, Innovation, Science and Trade within 30 calendar days of the activity commencing.
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1 This client alert is for informational purposes only and does not constitute legal advice. Complex assessments often have to be made regarding which sanctions regime applies in any given instance, given the multinational touchpoints of many entities and individuals. In that regard, given the complex and dynamic nature of these sanctions regimes, there may be developments not captured in this summary. Additionally, while the summary was accurate when written, it may become inaccurate over time given developments. For all of these reasons, you should consult with a qualified attorney before making any judgments relating to sanctions, as there are potentially severe consequences for failing to adhere fully to sanctions restrictions.
2 Council Implementing Regulation (EU) 2026/2281 of 12 October 2026 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (OJ L, 2026/2281, 12.10.2026); Council Decision (CFSP) 2026/2279 of 12 October 2026 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (OJ L, 2026/2279, 12.10.2026).
3 Recitals 2 and 3 of Council Decision (CFSP) 2026/2279.
4 Recital 5 of Council Decision (CFSP) 2026/2279.
5 Council of the European Union, press release of 12 October 2026, “Russia’s War of Aggression Against Ukraine: EU Agrees Largest-Ever Package of Listings Targeting Almost 1600 Individuals and Entities in Russia’s Military-Industrial Complex.”
6 Council Implementing Regulation (EU) 2026/2292 of 12 October 2026 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (OJ L 2026/2292, 12.10.2026).
7 Council Implementing Regulation (EU) 2026/2278 of 12 October 2026 implementing Regulation (EU) 2017/1509 concerning restrictive measures against the DPRK (OJ L 2026/2278, 12.10.2026), Recital 10 and Annex.
8 Foreign, Commonwealth & Development Office, Sanctions Notice: Russia Sanctions Regime (1 October 2026).
9 Foreign, Commonwealth & Development Office, Sanctions Notice: Russia Sanctions Regime (8 October 2026).
10 The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026, SI 2026/543, reg 15.
11 Department for Business and Trade and Office of Trade Sanctions Implementation, General Trade Licence: Maritime Transportation of Liquefied Natural Gas (LNG) – South Korea (1 October 2026).
12 Department for Business and Trade and Office of Trade Sanctions Implementation, General Trade Licence: Maritime Transportation of Liquefied Natural Gas (LNG) – Japan (1 October 2026).
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