In a move to strengthen its sanctions regime against Russia, the UK introduced additional sanctions through the publication of The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. The new sanctions came into force on April 24, 2025.
Key Points of Note:
- Software Sanctions: The UK has introduced a new prohibition on the transfer and making available of ‘sectoral software and technology’ to a person connected with Russia or for use in Russia. These restrictions capture business enterprise software and technology (such as ERP, CRM and supply chain management software), industrial design software and technology, and oil and gas related software and technology. The restrictions do not apply to software in the public domain or used for basic scientific research. In the accompanying explanatory memorandum, the UK Government confirmed that these restrictions capture the supply of in-scope software and technology in an intangible form, e.g., by download, via the cloud or otherwise provided as Software as a Service (“SaaS”). The new software restrictions largely align with existing EU and U.S. restrictions on enterprise management software.
- New Export Restrictions: The UK added goods to existing Russia export and supply restrictions, including various chemicals, plastics, metals, machinery and electronics which have military and industrial uses. These changes are to align the UK with measures taken by its allies, as well as to include other products the UK Government has identified as being important to the Russian war economy (such as the oil, gas, and chemical sectors).
- Technology Transfer Sanctions: The UK already restricted the transfer of technology in relation to certain military-related goods. The UK has extended the scope of these controls to a wider set of technology, including energy-related goods, G7 dependency and further goods, and Russia’s vulnerable goods. Such information can take many forms, including IP, industrial know-how, trade secrets, and information contained in blueprints and designs.
- Synthetic Diamonds Import Restrictions: Finally, the UK has extended an existing import ban to cover Russian synthetic diamonds (weighing 0.5 carats and above) processed in third countries. This new restriction aligns with an existing prohibition on natural diamonds and is intended to prevent potential circumvention since synthetic diamonds cannot be easily differentiated from natural diamonds.
In parallel, the UK Government has published new guidance on complying with the new sectoral software sanctions (here) and the technology transfer provisions (here), along with a notice to exporters on the additional trade sanctions (here).