The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 31 Oct 2025 (Russia - Countermeasures):
The Ministry of Foreign Affairs introduced additional countermeasures in response to the EU's 19th package of sanctions against Russia.
- 31 Oct 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") added one FAQ (FAQ 172) to the UK's Financial Sanctions FAQs to clarify whether a UK financial institution requires an OFSI license to deal with or receive (or use once received) funds allocated to it by an International Central Securities Depository ("ICSD"), where corresponding ICSD funds held by Russia's National Settlement Depository ("NSD") have been seized and dealt with by the NSD.
- 30 Oct 2025 (New Zealand):
Content provided in collaboration with Chapman Tripp.
The Russia Sanctions Amendment Regulations (No 5) 2025 came into force. An additional two individuals and seven entities were added to the Schedule of sanctioned persons, and 65 vessels were also designated.
- 29 Oct 2025 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Russia-related General License ("GL") GL 129, "Authorizing Transactions Involving Rosneft Deutschland GmbH and RN Refining & Marketing GmbH", which authorizes "all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations" (“RuHSR”) involving those entities through 12:01 a.m. eastern daylight time, April 29, 2026. These covered entities are subsidiaries of Rosneft, whose assets are evidently no longer controlled by Russia.
- 29 Oct 2025 (EU):
The European Commission (the "Commission") updated its Russia sanctions FAQs in respect of the prohibition applicable to oil imports, pursuant to Article 3m of Council Regulation (EU) No. 833/2014 ("Regulation 833").
- 29 Oct 2025 (EU):
The European Commission (the "Commission") updated its Russia sanctions FAQs in respect of the import ban on refined petroleum products obtained from Russian crude oil, pursuant to Article 3ma of Council Regulation (EU) No. 833/2014 ("Regulation 833").
- 29 Oct 2025 (Switzerland):
Switzerland adopted most of the remaining measures included in the EU's 18th sanctions package of July 18, 2025, including a prohibition on imports of refined oil products made from Russian crude, additional export controls, a catch-all provision for advanced technology items, and a transaction ban with certain Russian banks.
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