Contents

Summary 4

1 Background 7

2 Sanctions relating to the Ukraine conflict 8

2.1 Overview: What has changed in 2025? 8

Has there been a divergence between the US and its allies on Russian sanctions policy? 8

2.2 UK sanctions introduced since January 2025 12

New sanctions 13

Extending existing sanctions: Targeting Russia’s shadow fleet and restricting Russia’s energy revenues 17

New legislation to address sanctions evasion through third countries 22

2.3 EU sanctions since January 2025 23

Ending EU reliance on Russian oil and gas imports by 2027 26

Debate on the seizure of Russian state-owned assets 27

3 Annex 1: Broader Russian sanctions 30

3.1 UK sanctions frameworks targeting Russia 30

3.2 New EU sanctions frameworks 32

4 Annex 2: Suggested reading 33