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ARTICLE · 16 DECEMBER 2025

EU And UK Sanctions On Russia And Iran

A&O Shearman
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The UK and EU continue to evolve their sanctions frameworks to further expand their reach and to cut down on sanctions circumvention.

GlobalInternational Law
Matthew Townsend
Matthew Townsend
Dr. Udo Herbert Olgemöller
Dr. Udo Herbert Olgemöller
James Freeman
James Freeman
Ming He Tan
Ming He Tan
Gauthier Jacqmin
Gauthier Jacqmin
Sarah Weber
Sarah Weber
Luke Adams
Luke Adams
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INTRODUCTION

The UK and EU continue to evolve their sanctions frameworks to further expand their reach and to cut down on sanctions circumvention. The UK recently sanctioned Rosneft and Lukoil, two of Russia's biggest oil producers, whilst the EU's latest 19th sanctions package also imposes further restrictions on the Russian energy sector.

In addition, the UK and EU have recently re-introduced sanctions on Iran following the "snap-back" of the Joint Comprehensive Plan of Action. Businesses engaging in business in Iran will therefore have to re-evaluate their positions.

THE UK SANCTIONS RUSSIA'S LARGEST OIL COMPANIES

On 15 October 2025, the UK imposed an asset freeze and related financial restrictions on PJSC Rosneft Oil Company (Rosneft) and PJSC Lukoil (Lukoil). The designations formed part of a wider package of 88 additional listings targeting Russia's energy revenues and associated logistics and financing networks.

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