Russia/Ukraine Sanctions Update - Month of March 2025

US Sanctions | EU Sanctions | UK Sanctions | Russia/Ukraine Sanctions | Other Notable Developments 

I.  US SANCTIONS

• U.S. Agrees to Help Lift International Sanctions on Certain Russian Exports: On March 25, Reuters reported that Washington has agreed “to push to lift some sanctions against Moscow.” This consideration follows Russia’s agreement to pause attacks at sea and against energy targets (discussed further below) and U.S. commitment “to help seek the lifting of international sanctions on Russian agriculture and fertilizer exports.” Russia has reported that this relief would include “restoring links between Russia’s agricultural bank and the SWIFT international payments system,” which requires agreement from the EU. Read more>> and Read more>>
• White House Releases Outcomes of the U.S., Ukraine, and Russia Expert Groups on the Black Sea: On March 25, the White House released the results of the U.S., Russia, and Ukraine expert groups on the Black Sea. Following the results, the U.S. and Russia and the U.S. and Ukraine agreed on several provisions, including the banning of strikes against energy facilities of Russia and Ukraine, ending the use of force in the Black Sea, and “working toward achieving a durable and lasting peace” between Russia and Ukraine. Read more>> and Read more>> 
• U.S. Secretary of State Reports on President Trump’s Call with President Zelenskyy: On March 19, U.S. Secretary of State, Marco Rubio, announced that President Trump held a call with President Zelenskyy of Ukraine. Secretary Rubio detailed the call as “fantastic” and noted the Presidents discussed javelin missiles, air defense systems, and “broadening the ceasefire to the Black Sea on the way to a full ceasefire.” Read more>>
• U.S. Secretary of State Call with Russian Foreign Minister: On March 15, U.S. Secretary of State, Marco Rubio, held a call with Russian Foreign Minister, Sergei Lavrov. Secretary Rubio “informed Russia of U.S. military deterrence operations against the Iran-backed Houthis and emphasized that continued Houthi attacks on U.S. military and commercial shipping vessels in the Red Sea will not be tolerated.” The parties also “agreed to continue working towards restoring communication between the United States and Russia.”  Read more>> 

II.  EU Sanctions

• EU Sanctions Against Russia Extended for a Further Six Months: On March 14, the EU prolonged and updated the list of individuals and entities subject to restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine until September 15, 2025. Read more>> and Read more >> 
• EU Sanctions in View of the Situation in Ukraine Extended for a Further Year: On March 3, the EU prolonged restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine until March 6, 2026. Read more>>
• European Commission Updates FAQs on EU Sanctions: The revised FAQs on sanctions against Russia, released in March 2025, address topics including oil imports, the ban on infrastructure transactions, and the transshipment of liquefied natural gas. Read more>>, Read more>> and Read more>>
• High Risk of Circumvention of EU Sanctions in Plywood Imports: On March 14, the European Commission issued a critical alert on sanctions evasion in plywood imports, and particularly birch plywood. Russian and Belarusian plywood producers are reported to be circumventing sanctions by using third-country companies to repackage and relabel their products, providing false documentation to hide the true origin. Enhanced due diligence on the origin of imported plywood is strongly recommended by the European Commission for all parties involved in the supply chain. Specific red flags include birch plywood from producers/exporters in China, Kazakhstan, Türkiye, or countries with trade links to Russia or Belarus, and/or with sudden growth in EU exports, as well as economically unjustified processing operations and illogical logistic routes. Read more>>
• EU Launches Sanctions Helpdesk: The EU Sanctions Helpdesk is an initiative by the EU designed to assist small and medium-sized enterprises (SMEs) and other organizations in complying with EU restrictive measures. Its primary aim is to answer questions regarding the applicability of these measures and to offer guidance on performing sanctions due diligence. Furthermore, the Helpdesk can conduct sanctions due diligence free of charge in cases where red flags are identified, or additional support is needed. Read more>>
• EU Sanctions on Russian Oil Imports and Monitoring of 'Dark Fleet' Vessels: In response to a question from a Member of the European Parliament, the European Commission clarified that under Regulation (EU) 833/2014, the import of Russian oil is prohibited, with limited exceptions for oil supplied by pipeline, and no Russian oil transported by 'dark fleet' vessels can be imported into the EU. In June 2024, the EU targeted 27 vessels for their role in Russia's warfare against Ukraine, and in December 2024, it listed 52 additional vessels, subjecting them to a port access ban and a ban on the provision of services. The EU continuously monitors developments related to Russia's shadow fleet to combat sanctions circumvention, and Member States are responsible for addressing significant pollution events under the Marine Strategy Framework Directive, with support from the EU Civil Protection Mechanism and the European Maritime Safety Agency. Read more>> and Read more>>
• EU's General Court Upholds Media Restrictions on Russia: By its judgment delivered on March 26, the General Court dismissed the action brought by three Dutch information society operators—A2B Connect BV, BIT BV, and Freedom Internet BV—and upheld the EU's restrictive measures prohibiting the broadcasting and advertising of products or services from certain Russian media outlets. Read more>>
• EU's General Court Dismisses Action Against EU Sanctions Brought by Dana Astra and AAT Byelorussian Steel Works: By its judgments delivered on March 19, the General Court dismissed action brought by Dana Astra, a Belarusian company active in the construction and property development sector, and AAT Byelorussian Steel Works, a Belarusian company active in the field of iron and steel products, challenging their listings. Read more>> and Read more>> 
• EU's General Court Dismisses Action Against EU Sanctions Brought by Mr. Alexander Ponomarenko: By its judgment delivered on March 5, the General Court dismissed action brought by Mr. Alexander Ponomarenko challenging his listing. Read more>>
• EU's Court of Justice Dismisses the Appeal Brought by Mr. Igor Shuvalov: By its judgment delivered on March 13, the Court of Justice dismissed the appeal brought by Mr. Igor Shuvalov, Deputy Prime Minister of the Russian Government and former president of Vnesheconombank (VEB.RF), challenging his listing. Consequently, the Court upheld the judgment of the General Court. The Court of Justice noted that the General Court did not err in law by determining that the Council could rely on positions held and public statements made by Mr. Shuvalov prior to the adoption of the acts imposing restrictive measures. Additionally, the General Court correctly held that these acts do not undermine the essence of Mr. Shuvalov's right to property and that the limitation imposed by the restrictive measures on that right does not appear to be manifestly inappropriate in relation to the objective they pursue. Read more>>
• German Court Initiates Criminal Case Against Former Siemens Executives: A German court has initiated a criminal case against two former Siemens executives for allegedly violating EU sanctions by exporting Siemens gas turbines to Russian-occupied Crimea. Charges against three other individuals were dropped due to insufficient evidence. However, the prosecutor's department has appealed the court's decision to dismiss the charges against these three individuals. The Siemens turbines, which are used to generate electricity, were delivered to two power plants in Crimea that are being constructed by Russia. Read more>>
• Russian businessman extradited to Estonia in sanctions investigation: On February 27, it was reported that Ivan Anchevsky, a Russian businessman with Estonian citizenship, had been arrested in Italy and extradited to Tallinn in January 2025 in connection with the alleged illegal transportation of strategic cargo to Russia in violation of EU sanctions. Read more>>

III.  UK Sanctions

• UK Government amends two entries on UK sanctions list under the Russia regime: On March 27, the UK Government amended the entries for two entities (2Rivers DMCC and 2Rivers PTE LTD) on the UK sanctions list under the Russia regime. Read more>>
• OFSI amends General Licence for payments involving Russian Railways and Lithuanian Railways: On March 27, the Office of Financial Sanctions Implementation (“OFSI”) amended general licence INT/2023/2883496, which inter alia authorises certain payments involving Russian Railways and Lithuanian Railways relating to the transit of persons between the Kaliningrad Region and other parts of Russia via the passenger rail service operated by Lithuanian Railways, subject to certain terms and conditions. The expiry date of the General Licence was extended by two years to April 13, 2027. Read more>>
• OFSI amends General Licence relating to presidential supervision and protection of the integrity of the UK financial system: On March 27, OFSI amended General Licence INT/20221280976, which authorises a UK regulatory authority involved in the regulation of financial services to engage in certain activities in respect of a UK sanctions target, including activities that relate to prudential supervision or protecting, maintaining or enhancing the stability of the UK financial system.  The General Licence has been extended indefinitely and to apply to all persons designated under the UK’s autonomous sanctions regimes listed in Annex 1 of the General Licence. Read more>>
• OFSI amends General Licence for humanitarian activity: On March 24, OFSI amended General Licence INT/2022/1947936, which authorises the performance of certain activities relating to the delivery of humanitarian assistance and the support of basic human needs in relation to the conflict in Ukraine and non-government controlled Ukrainian territory, subject to certain terms and conditions.  In particular, Rosbank PJSC and Tinkoff Bank were removed from, and TBank was added to, Annex I of the general licence. Read more>>
• OFSI amends General Licence for Mongolia energy payments: On March 24, OFSI amended General Licence INT/2022/2085212, which authorises certain payments to be made to certain sanctioned banks for the purpose of making energy available for use in Mongolia, subject to certain terms and conditions. In particular, Rosbank PJSC, which has merged with T-Bank, has been removed and replaced by TBank under the definition of “Sanctioned Bank” under the licence.  The General Licence expires on 14 August 2025. Read more>>
• UK Government amends one entry on UK sanctions list under the Russia regime: On March 24, the UK Government amended the entry for Tigran Oganesovich on the UK sanctions list under the Russia regime. Read more>>
• UK Government amends one entry on UK sanctions list under the Russia regime: On March 20, the UK Government amended the entry for Red Box Energy Services Pte Ltd on the UK sanctions list under the Russia regime. Read more>>
• OFSI imposes £465,000 fine against law firm for breach of UK financial sanctions: On March 20, OFSI issued a £465,000 fine against Herbert Smith Freehills CIS LLP Moscow (“HSF”) for making funds available to certain UK assets freeze targets in May 2022 in breach of UK sanctions. In particular, HSF made six payments worth almost £4 million to Alfa-Bank, Sberbank and a subsidiary of Sovcombank between 25 and 31 May 2022.  According to OFSI’s penalty notice, root causes of the breach included inadequate due diligence and sanctions screening and errors causes by the hasty closure of HSF’s Russian offices. Read more>>
• UK Government removes one entry from and corrected two entries under the UK sanctions list under the Russia regime: On March 19, the UK Government removed Farkhad Akhmedov from the UK sanctions list under the Russia regime. The UK Government also corrected two entries on the UK sanctions list for MCR Global Elektronik Sanayi Ve Ticaret Ltd Sirketi and Poly Technologies, Inc. Read more>>
• Trial begins for former Crimea governor charged with breaching UK sanctions: On March 18, the trial of Dmitrii Ovsiannikov, former governor of Sevastopol, began in Southwark Crown Court.  Among other things, Ovsiannikov is charged with trying to circumvent sanctions between February 2023 and January 2024.  His wife and brother are also facing charges of circumventing sanctions for their apparent roles in supporting Ovsiannikov. Read more>>
• OFSI issues General Licence for petrol station payments involving Gazprom Neft and its subsidiaries in Kyrgyzstan and Tajikistan: On March 14, the Office of Financial Sanctions Implementation (“OFSI”) granted a general licence which authorises UK nationals to purchase petrol at any petrol station in Kyrgyzstan or Tajikistan that is owned or controlled by Gazprom Neft or one of its subsidiaries, provided that the petrol is for the UK national’s personal vehicle, subject to certain terms and conditions. The General Licence expires on March 15, 2027. Read more>>
• UK Minister states that no oil was exported from the UK to Russia in 2023 or 2024: On March 7, Douglas Alexander MP, Secretary of State for Business and Trade, stated in a response to a written question that, according to HMRC data, the UK did not export oil to Russia in 2023 or 2024.Read more>>
• UK Government amends one entry on and removes two entries from the UK sanctions list under the Russia sanctions regime: On March 7, OFSI removed Rosbank PJSC, a Russian financial services firm, and Active Denizcilik Ve Gemi Isletmeciligi Anonim Sirket, a Russian energy company, from the UK sanctions list under the Russia sanctions regime.  OFSI also amended the entry for Tinkoff Bank, updating its name to TBank. Read more>>
• UK Government corrects one entry on the UK sanctions list under the Russia regime: On February 28, OFSI corrected the address for OJSC Keremet Bank on the UK sanctions list under the Russia sanctions regime. Read more>>
• UK Government publishes factsheet on UK Support to Ukraine: On February 28, the UK Government published a factsheet which details the UK's support to Ukraine.  Among other things, the factsheet notes that, since Russia's full-scale invasion of Ukraine in 2022, the UK Government has designated over 2,000 individuals and entities, including members of Putin's inner circle and two of the Russia's largest oil companies and more than 140 vessels. Read more>>
• General Licence on Russian Oil Majors Wind Down expires:On February 27, General Licence INT/2025/5635701 expired.  The General Licence authorised the wind down or divestment from any transactions involving Gazprom Neft and PJSC Surgutneftegas or any entity owned or controlled by either of them following their designation as a UK sanctions target on January 10, 2025. Read more>>
• UK Government corrects five entries on the UK sanctions list under the Russia regime: On February 27, OFSI corrected the entries for two individuals (Vasily Abramov and Natalya Tyurina) and three entities (JSC Siberia Airlines, Monolink Group and OJSC Keremet Bank) on the UK sanctions list under the Russia sanctions regime. Read more>>

 IV.  Russia/Ukraine Sanctions 

• Russia and Zimbabwe sign agreement to counter Western Sanctions: On March 6, it was reported that Zimbabwe and Russia had signed an agreement in Moscow to strengthen both countries’ cooperation in response to Western sanctions and to further deepen their economic and political ties. The agreement covers collaboration in key sectors such as geological exploration, mineral resource extraction, energy, agriculture, and defence. Read more>>
• Russia demands lifting of sanctions before maritime ceasefire can begin: On March 26, it was reported that Russia has said that some Western sanctions must be lifted before it begins a maritime ceasefire with Ukraine. In particular, the Kremlin has said that a ceasefire would only take place once a number of sanctions, including sanctions targeting the state agricultural bank Rosselkhozbank and the access of Russian banks to the Swift international banking system, are lifted. Read more>>
• Zelenskyy urges more US sanctions on Russia after drone strikes: On March 26, Ukrainian President Zelenskyy urged the United States to impose more sanctions on Moscow after the Ukrainian military reported Ukraine to have been subject to 117 drone attacks overnight. Read more>>

V.  Other Notable Developments

• Canada Further Sanctions Russia: On March 1, Canada further amended its Special Economic Measures (Russia) Regulations to add ten individuals and twenty-one entities determined to be linked to “Russia’s illegal annexation of Crimea, and to the continuing violation of Ukraine’s sovereignty and territorial integrity.”  Read more>>