New measures 

New measures have been applied in the following schedules to the legislation: 

• Schedule 2A (critical-industry goods and critical-industry technology) 
• Schedule 3 (energy-related goods and energy-related technology) 
• Schedule 3C (defence and security goods and defence and security technology) 
• Schedule 3E (G7 dependency goods and G7 dependency technology) 
• Schedule 3I (Russia’s vulnerable goods and Russia’s vulnerable technology) 

Additional new sanctions include the export, supply, and delivery of chemicals, electronics, machinery, plastics, and metals. Further restricted actions include making captured items available to or for use in Russia. Ancillary services related to the goods will also be subject to the change in regulation. 

If goods for export are captured within the above schedules, ensuring compliance with the legislation will be essential before attempting to export goods. 

Technology and software 

The new sanctions measures also capture software and technology relating to the following industries: 

• Energy 
• Advanced industrial manufacturing 
• Business enterprise 
• Industrial design 
• Oil and gas 

Prohibited actions include both the transfer and making available to Russia of captured technology and software.  Ancillary services related to the technology and software captured in the legislation are also prohibited. 

The detailed amendments and additions to the 2019 Regulations can be found in: 

• Chapter 4 (energy-related goods, energy-related technology, and related activities) 
• Chapter 4H (G7 dependency and further goods and G7 dependency and further technology) 
• Chapter 4M (Russia’s vulnerable goods and Russia’s vulnerable technology) 
• Chapter 4N (sectoral software and technology) 

Additional Restrictions on Imports 

Import bans are now in place for synthetic diamonds processed in third countries and on the import of helium. Affected imports can be found in the following chapters: 

• Chapter 4JC (certain diamonds mined in Russia processed in a third country) 
• Chapter 4JD (certain Russian-manufactured synthetic diamonds processed in a third country) 
• Schedule 3DA (revenue-generating goods - Helium) 

Exceptions 

Some exceptions to the prohibitions are set out in detail within the chapters in the 2019 Regulations.  Where an exception may be noted as possible within the chapter, licences can be granted in minimal circumstances, and applications should be made through the ECJU. 

Link to the NTE:  NTE 2025/11: further sanctions against Russia introduced in April 2025 - GOV.UK 

Further guidance and support 

The guidance pages for Russian sanctions are in the process of being updated.  Updates will be found at the link below: 

 Russia sanctions: guidance page. 

Technology and Software: 

Guidance on the transfer of technology and software sanctions can be found at the links below: 

 Complying with technology transfer sanctions  

Complying with sectoral software sanctions. 

Standalone services 

Businesses offering standalone services can find further information on licensing, compliance, and enforcement for trade sanctions by completing the online form at the link below, to be submitted to the Office of Trade Sanctions Implementation. 

Contact the Office of Trade Sanctions Implementation (OTSI) - Contact OTSI – GOV.UK 

Export Controls 

Enquiries related to Export Controls and trade sanctions that could affect the provision of ancillary services should be directed towards the Export Control Joint Unit.  The landing page for the ECJU can be found at the link below: 

 Contact the Export Controls Joint Unit (ECJU). 

Contact with the ECJU can be made directly as follows: 

General queries about strategic export licensing 

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY 

Email exportcontrol.help@businessandtrade.gov.uk 

Telephone 020 7215 4594 

Importing: 

For further information on import-related sanctions, the DBT’s landing page can be found here: 

Import controls - GOV.UK 

Details on Import Controls and Trade Sanctions can be found at the link below: 

Trade Sanctions - GOV.UK 

If your goods are not subject to export licences and your business is considering trade with Russia or Ukraine, the Export Support Service is a suggested source of information. 

A link to the ESS landing page is below: 

Export support for UK businesses 

The legislation for the new measures is the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, found here: 

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 

The latest version of the original 2014 sanctions regulation can be found in the Russia (Sanctions) (EU Exit) Regulations 2019 (the “2019 Regulations”), found here: 

https://www.legislation.gov.uk/uksi/2019/855/contents 

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP: