How Are Ownership and Control Rules Being Applied Under the UK’s Russia Sanctions Regime?

There was a rapid expansion of UK, EU, and U.S. sanctions on Russia and Belarus in recent weeks that were effective in both months of January & February ’26, with more in the regulatory pipeline.

UK

1. On Thursday, 26 February ’26, the UK Court of Appeal handed down judgment in Dana Astra 1000 vs. Secretary of State for Foreign Commonwealth and Development Affairs (2026) EWCA Civ 160.

Dana Astra, a real estate development company, had appealed the High Court’s decision to sustain its designation under the UK-Belarus sanctions regime. This was due to the designation being a rational and proportionate interference with A1P1 rights. The Court of Appeal agreed with the High Court and dismissed Dana Astra’s appeal.

2. On Wednesday, 25 February ’26, the UK office of Financial Sanctions (OFSI) extended the Lukoil International Entities General Licence (INT/2025/8031092) until 25 August ’26. This permits the British people and entities to transact with Lukoil International GmbH (and its subsidiaries). This move is despite UK sanctions on its parent company, PJSC Lukoil, where funds are paid into a frozen account.
3. On Tuesday, 24 February ’26, the UK Government designated 240 entities, 7 individuals, and 50 ships under the Russia (Sanctions) (EU Exit) Regulations 2019. The designations focus on Russian energy revenues and suppliers of military equipment. The designations target:

PJSC Transneft, which is responsible for transporting over 80% of Russia’s oil exports.

The designations target 175 companies within the 2Rivers oil network. This is based on the fact that it is one of the largest shadow fleet operators globally and a major Russian crude oil trader.

shadow fleet operators globally and a major Russian crude oil trader.

49 individuals and entities providing goods. This is besides components and technology for Russian drones and other weapons.

3 civil nuclear energy organizations and 2 individuals involved in attempting to secure contracts for new Russian nuclear energy installations overseas.

6 ships, traders, and terminals (Portovaya and Vysotsk) responsible for exporting Russian Liquefied Natural Gas (LNG).

9 Russian banks that process cross-border payments and enable Russian access to international markets.

OFSI issued 2 new General Licenses, the Maritime Mutual Re-Insurance Wind Down (INT/2026/8893924) and the PJSC Transneft Wind Down General License (INT/2026/8889196), and amended one General License. Also, the Russian Oil Exempt Projects General License (INT/2025/5635700), which is in relation to the new designations.

4. OFSI imposed a USD 214,400 (£160,000) fine on the Bank of Scotland for permitting a sanctioned person to open a UK bank account. This fine was imposed because the sanctioned person used a passport that contained a variation of their name when opening the account and processing their transactions. OFSI’s blog noted four compliance takeaways:

Firms should optimize sanctions controls related to risk. Also, consider whether screening systems could cope with name variants.

Internal policies should be clear on how and when there’s a need to escalate sanctions concerns.

Training content must be regularly reviewed.

Voluntary disclosures should be made as soon as practicable. This is even if it means a partial initial disclosure with a follow-up disclosure.

5. On Thursday, 19 February ’26, the UK Court of Appeal found that Mr. Mikhail Fridman, an individual sanctioned under the UK’s Russia sanctions regime, is subject to a travel ban. He could not be served with proceedings in the UK.

The Court believed that it would be legally incoherent for the state, on the one hand, to claim jurisdiction over Mr. Fridman on the ground of his presence in England and Wales. On the other hand, the state could not deny him the right to be present there.

6. On Monday, 16 February ’26, OSI launched a call for evidence, closing on 13 April ’26, to seek industry’s views on how UK financial sanctions regulations on ownership and control are applied in practice and where industry is facing challenges. Firms and other interested stakeholders are being asked to share evidence and practical examples.