Key takeaways
Maritime services ban on Russian LNG
The UK will phase this in over 2026 in conjunction with other European countries.
EU phase out of Russian gas imports
An EU regulation will introduce a legally binding, stepwise prohibition on both LNG and pipeline gas imports from Russia with a full ban from the end of 2026 and autumn 2027 respectively.
Reparations loan
The EU is considering using Russian assets frozen in Europe as a loan to Ukraine to help fund its military and economy.
Maritime services ban
On 12 November 2025, the UK Government announced its intention to introduce a maritime services ban on Russian LNG.
The UK had already banned the import of Russian LNG in January 2023, but this latest action is intended to significantly reduce Russian exports of LNG by directly cutting off access to the UK’s maritime transport and related services, including insurance, for Russian LNG exports to third countries. Consequently, UK-linked ships and services will not be permitted to help move Russian LNG globally.
The UK Government indicated that the ban would be phased in over 2026 in conjunction with other European countries.
Furthermore, on 5 December 2025, it was reported that the G7 countries and the EU are in talks to replace the price cap on Russian oil exports with a full maritime services ban in an attempt to reduce Russia’s oil revenues. It is estimated that one third of Russian oil is exported on Western tankers and using Western shipping services. Such a ban would, therefore, prevent Russia trading its oil through the fleets of EU and G7 countries.
It has been speculated that if this ban is implemented, it might well form part of the next EU sanctions package (the 20th), which is expected to be announced in early 2026. One consideration, however, is whether the introduction of a maritime services ban will result in the expansion of the shadow fleet.
EU phase out of Russian gas imports
On 3 December 2025, the European Council and the European Parliament reached a provisional agreement on a regulation to phase out imports of Russian natural gas. The regulation introduces a legally binding, stepwise prohibition on both LNG and pipeline gas imports from Russia, with a full ban from the end of 2026 and autumn 2027 respectively.
The EU aims to end its dependence on Russian gas and ban it in the EU permanently. However, it also wishes to preserve the security of supply. The main elements of the agreement include:
Imports of Russian pipeline gas and LNG will be prohibited from six weeks after the regulation enters into force.
There will be a transitional phase for existing supply contracts.
Gas imports to the EU will be subject to a prior authorisation regime.
Breach of the regulation can lead to penalties for both companies and private individuals.
There will be a suspension clause allowing the application of the regulation to be temporarily suspended in case of sudden developments threatening the security of the energy supply of one or more states.
The implementation of the regulation would be reviewed within two years after it enters into force.
Reparations loan
It has been reported that Russia has about Euros 210 billion in sovereign assets in Europe, primarily in Belgium where they are held by central securities depository, Euroclear. Russia’s assets in Europe were frozen after it invaded Ukraine. The EU is now considering using that money as a loan to Ukraine to help it fund its military and economy.
As a first step, on 12 December 2025, the EU agreed to immobilise those funds indefinitely. Up to this point, there had to be a unanimous vote every six months to preserve the freeze. A decision is expected to be made at an EU summit on 18 December 2025 to discuss how to fund Ukraine’s war efforts for the next two years and perhaps beyond.
Belgium and Euroclear are objecting to the use of those frozen assets as proposed. There is a clear risk of retaliatory legal and other action by Russia. There are also liquidity concerns for Euroclear. Belgium is seeking independent guarantees from the EU if it is to agree to the reparations loan. Belgium is also seeking protection from liability for Euroclear.
Indeed, on 12 December 2025, the Central Bank of Russia announced that it will be filing suit against Euroclear in the Moscow Arbitrazh Court for its losses sustained as a result of its inability to dispose of its assets. This Court is increasingly being used by Russian entities who believe they are being unfairly treated and cannot get justice in foreign courts and tribunals due to sanctions. Euroclear has Euros 17 billion of assets in Russia, which are at risk of being frozen or seized. If that happens, it may potentially have the option of offsetting its losses against Russian assets held within the EU.
OTSI: one year on
On 4 December 2025, the UK Office of Trade Sanctions Implementation (OTSI) published a report that provided an overview of OTSI’s activities during its first year of operation (it was established in October 2024).
Among other things, OTSI reports that it has developed a rigorous licensing process. It received 60 licensing applications up to 9 October 2025. As at the time the report was published, 12 had been granted, 3 refused, 7 withdrawn, and 5 proved to have been submitted in error. OTSI estimates that there is a turnaround time of around 82 days for a licence application to be dealt with and achieve an outcome.
Looking forward, OTSI is expanding its licensing remit. In early 2026, OTSI will take on responsibility for all export sanctions licensing, with the exception of activities which involve goods and technology subject to strategic export controls – these will remain with Export Control Joint Unit (EJCU).
