Russia/Ukraine Sanctions Update - Month of April 2025

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

I. U.S. Sanctions 

• White House Reportedly Considering Lifting Sanctions on Russian Energy Assets: On April 23, Politico reported that the White House is debating lifting sanctions on Russia’s Nord Stream 2 natural gas pipeline and potentially other Russian assets in Europe as part of discussions on ending the war between Russia and Ukraine. Lifting the sanctions currently in place on these energy assets would be a sharp reversal of the U.S. policy put in place during President Donald Trump’s first term. Read more>>
• U.S. Sanctions Houthi Network Procuring Weapons and Commodities from Russia: On April 2, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned several individuals and entities determined to be part of a network of Houthi financial facilitators and procurement operatives that procured tens of millions of dollars’ worth of commodities from Russia, including weapons and sensitive goods, as well as stolen Ukrainian grain, for onward shipment to Houthi-controlled Yemen. OFAC also sanctioned eight digital asset wallets used by the Houthis to transfer funds associated with these activities. Read more>>
• Secretary of the Treasury Meets with Prime Minister and Minister of Finance of Ukraine: On April 23, Secretary of the Treasury, Scott K.H. Bessent, met with Prime Minister, Denys Shmyhal, and Minister of Finance, Sergii Marchenko, of Ukraine. During the meeting, the parties discussed U.S. support of Ukraine’s sovereignty and the benefits of the economic partnership between the people of the United States and Ukraine. Read more>>
• U.S. Warns It Will Pause Ukraine Peace Efforts if No Progress is Made Soon: On April 18, Reuters reported that the U.S. has promised to “walk away from efforts to broker a Russia-Ukraine peace deal unless there are clear signs of progress soon.” "We're not going to continue with this endeavor for weeks and months on end. So we need to determine very quickly now, and I'm talking about a matter of days, whether or not this is doable in the next few weeks," Secretary of State, Marco Rubio, said in Paris after meeting with European and Ukrainian leaders. Read more>>

• U.S. Secretary of State Call with Russian Foreign Minister: On April 17, U.S. Secretary of State, Marco Rubio, held a call with Russian Foreign Minister, Sergei Lavrov. Secretary Rubio emphasized to Foreign Minister Lavrov that “President Trump and the United States want this war to end, and have now presented to all parties the outlines of a durable and lasting peace.” Read more>>

II. EU Sanctions

• EU Imposes New Sanctions on Belarusian Individuals and Entities: On March 27, the EU imposed sanctions on an additional 25 individuals and 7 entities responsible of undermining democracy and the rule of law in Belarus, as well as contributing to the ongoing internal repression, human rights abuses as well as military cooperation with Russia in support of the war against Ukraine. Read more>> and Read more>>

• Additional Broadcasting Prohibition Enters into Force: On April 9, the EU began enforcing a broadcasting ban and related service restrictions on the following Russian entities: EADaily / Eurasia Daily, Fondsk, Lenta, NewsFront, RuBaltic, SouthFront, Strategic Culture Foundation, and Krasnaya Zvezda / Tvzvezda. Read more>> and Read more>>

• Statement by EU Sanctions Envoy on the Fifth Sanctions Coordinators Forum: On April 8, EU Sanctions Envoy David O'Sullivan convened the fifth Sanctions Coordinators Forum, bringing together representatives from all EU Member States, international partners, and Ukraine to discuss the ongoing impact and enforcement of sanctions against Russia. The forum reviewed the effectiveness of sanctions in disrupting Russia’s access to sensitive technology, weakening its industrial base, and increasing its economic difficulties, while also addressing the need to combat circumvention and maintain pressure on Russia’s revenue streams. EU Sanctions Envoy emphasized the coalition’s continued commitment to enforcing sanctions and disrupting Russia’s war efforts through coordinated international action. Read more>>

• Statement by Commissioner in Charge of Sanctions Implementation: On April 8, Commissioner Maria Luís Albuquerque chaired the seventh High-Level Expert Group meeting on EU sanctions, emphasizing the importance of effective implementation and enforcement of sanctions against Russia. The group discussed challenges, shared best practices, and looked into practical solutions, such as the EU sanctions helpdesk to assist businesses in compliance. Commissioner Albuquerque reaffirmed the EU’s commitment to strong international coordination and ongoing efforts to prevent sanctions evasion. Read more>>

• Commission Comments on Poland’s Decision to De-List Omne Energia: The Commission was asked to comment on the decision taken by Poland to remove Omne Energia – a company linked to Gazprom – from the Polish sanctions list. The Commission responded that it cannot comment on the removal of Omne Energia from the Polish sanctions list, its original inclusion not being based on EU sanctions. The Commission recalled however that Omne Energia and Gazprom are not listed under EU sanctions. In addition, the import of Russian natural gas into the EU is not prohibited under EU sanctions. Restrictions on public procurement which prohibit the award of public contracts to Russian entities and those majority owned by them foresee an exemption for the purchase, import or transfer of natural gas. Read more>> and Read more>>

• EU's General Court Dismisses Action Against EU Sanctions Brought by Gennady Timchenko and Elena Timchenko: By its judgments delivered on April 2, the General Court dismissed the action brought by Gennady Nikolayevich Timchenko and Elena Petrovna Timchenko challenging their listing. Read more>> and Read more>> (both French language)

• EU General Court Annuls EU Sanctions Against Galina Pumpyanskaya, Alexander Pumpyanskiy, and Dmitry Pumpyanskiy: By its judgments delivered on April 2, the General Court annulled sanctions imposed on Russian businessman Dmitry Alexandrovich Pumpyanskiy and his spouse Galina Evgenyevna Pumpyanskaya. In both cases, the General Court determined that the Council made an ‘error of assessment’ when maintaining the couple’s names on the sanctions lists, which impose asset freezes and travel restrictions. Read more>> and Read more>>

III. UK Sanctions

• OFSI extends General Licence relating to insolvency payments for GTLK: On April 24, OFSI amended general licence INT/2023/3263556, which authorises payments and certain activities relating to the insolvency proceedings of certain GTLK companies. The amendment extends the General Licence by five years to 31 July 2030. Read more>>

• UK issues new sanctions FAQs to reflect Russian bank mergers: On April 23, OFSI published three new Russia sanctions FAQs following the merger of Rosbank PJSC with TBank and Bank Otkritie with BM-Bank. The FAQs indicate that any person holding an OFSI licence relating to a bank that no longer exists as a separate entity should immediately request an amendment to the licence from OFSI.  OFSI has already amended any live general licences affected by these mergers. Read more>>

• UK Government amends two entries on the UK sanctions list under the Russia regime: On April 14, the UK government amended the entries for Niels Oscar Troost and Paramount Energy & Commodities DMCC on the UK sanctions list under the Russia regime. Read more>>

• UK concludes first prosecution for breaches of Russia sanctions: On April 11, Dmitrii Ovsyannikov and Alexei Ovsyannikov were prosecuted for breaches of Russian linked financial sanctions for the first time ever in the United Kingdom.  Among other things, Alexei purchased a car for and paid private school fees on behalf of his brother, Dmitrii, a UK sanctions target, making funds available to Dmitrii in contravention of UK financial sanctions.  They were each found guilty of either counts or breaching financial sanctions and two counts of money laundering, and were sentences to 40- and 15-months imprisonment, suspended for 15 months, respectively. Read more>> and Read more>>

• UK court rejects application for disclosure of information relating to designation of former Everton FC director: On April 9, the UK High Court rejected an application by Sarvar Ismailov for the disclosure of unredacted material and other information from the Foreign, Commonwealth and Development Office relating to the process by which Ismailov was designated as a UK assets freeze target.  Ismailov was previously a board member of Everton FC. Read more>>

• Minister responds to written question relating to assets associated with Chelsea Football Club: On April 7, Stephen Doughty MP, Minister of State (FCDO), responded to a written question asking whether the UK Government plans to apply further sanctions to assets associated with the owners and affiliated entities of Chelsea Football Club and other Russian individuals/entities.  The Minister stated that the Government will not comment or speculate on further designations but noted that the Government is determined to see the proceeds from the sale of Chelsea FC reach humanitarian causes in Ukraine as soon as possible. Read more>>

• OFSI publishes blog post on lessons for industry from recent enforcement action: On April 4, the Office of Financial Sanctions Implementation (“OFSI”) outlined key lessons for industry following the imposition of a £465,000 monetary penalty against Herbert Smith Freehills CIS LLP. In particular, the blog post encourages market participants to (i) understand their exposure to sanctions risks; (ii) adhere properly to any sanctions policies and processes they have in place, and (iii) fully consider ownership and control in any sanctions assessment. Read more>>

• OFSI issues General Licence for arbitration costs: On March 28, the Office of Financial Sanctions Implementation (“OFSI”) issued general licence INT/2025/5787748, which authorises certain payments to be made to an Arbitrator or an Arbitration Association in relation to arbitration proceedings, subject to certain terms and conditions, under both the Russia and Belarus regimes. The General Licence takes effect from March 28, 2025, for an indefinite term. Read more>> and Read more>>

• OFSI amends General Licence relating to bond amendments and restructurings: On March 28, OFSI amended general licence INT/2023/2824812, which authorises issuers which may have designated bondholders to effect the terms of a restricting or amendments agreed between itself and its bondholders provided no funds or economic resources are made available to a designated person, subject to certain terms and conditions. The General Licence was extended by one year to March 27, 2026. Read more>> and Read more>>

• OFSI amends General Licence for payments relating to the provision of professional legal services: On March 28, OFSI amended general licence INT/2024/5334756, which authorises certain payments relating to the provision of professional legal fees, subject to certain terms and conditions, under both the Russia and Belarus regimes. The amendments expand the definition of designated person under the general licence to include corporates and clarify that “legal services” includes representation in dispute resolution matters. The General Licence expires on 28 April 2025. Read more>>

IV. Russia/Ukraine Sanctions

• Russia imposes sanctions on 21 UK Politicians: On April 23, Russia imposed sanctions on 15 UK MPs, and six members of the House of lords, banning them from entering Russia. The Russian foreign affairs ministry published a statement which accused the UK of fabricating anti-Russian narratives. Read more>>

• Ukraine sanctions 39 individuals and 60 legal entities: On April 18, under Decree No. 247/2025, Ukraine imposed sanctions on 39 individuals and 60 entities. The sanctions target, among others, three Chinese companies following a missile strike where Iskander missiles had struck a city in Northern Ukraine, namely Beijing Aviation and Aerospace Xianghui Technology Co. Ltd, Rui Jin Machinery Co. Ltd, Zhongfu Shenying Carbon Fiber Xining Co. Ltd, and various Russian individuals and entities. Read more>> (Ukrainian language)

• Ukraine sanctions 20 individuals: On April 18, 2025, under Decree No. 246/2025, Ukraine imposed sanctions on 20 individuals. Read more>> (Ukrainian language)

• Zelensky announces new sanctions package: On April 11, 2025, Zelensky announced a new sanctions package which targets Russia’s ‘shadow fleet’ including ‘the shadow tanker fleet that Moscow uses to finance the war; war propagandists – those who are trying to undermine our defense and help Russia; and also certain officials – these are names well known to all Ukrainians – who used to have influence’. Read more>>

V. Other Notable Developments

• Switzerland Adopts EU Sanctions Targeting Russian Media: On April 23, Switzerland adopted further Russia sanctions imposed by the European Union, which include widening an advertising ban on media organizations, according to Switzerland’s State Secretariat for Economic Affairs. Switzerland also amended the listings of 158 persons and organizations under financial sanctions. Read more>>

• New Zealand Extends Military Support to Ukraine through 2026: On April 22, New Zealand announced an extension of its military assistance to Ukraine, committing support through December 2026. Prime Minister, Christopher Luxon, announced this decision includes the continued deployment of up to 100 New Zealand Defence Force personnel to train Ukrainian soldiers in the UK and Europe. The force will also provide intelligence, liaison, and logistics support to Ukraine. Read more>>