Key takeaways
UK sanctions target Russia’s shadow fleet
New measures increase pressure on vessels supporting energy exports.
Iran faces expanded trade and maritime restrictions
New rules strengthen controls across energy, finance and shipping.
Maritime sanctions demand continued compliance vigilance
Owners and operators should monitor evolving international restrictions.
Latest Russia sanctions package
On 1 October 2026, the UK Government announced a new package of sanctions against Russia.
The 31 new measures include the targeting of 23 individuals and entities, who will be subject to asset freezes and other sanctions measures, as well as sanctions against eight vessels. These vessels comprise three LNG shadow fleet tankers, two vessels providing the shadow fleet with bunkering services and three Russian-owned ice-class vessels. The vessels are subject to shipping and trade sanctions.
The UK Government has expressed concern that Russia is attempting to build a new shadow fleet to circumvent sanctions and sustain revenues from its gas exports. This latest package, therefore, targets several vessels that were acquired and entered into service recently. The UK has now sanctioned nearly 600 tankers said to form part of the shadow fleet.
However, existing licenses to cover LNG shipments to Japan and South Korea on a targeted and time limited basis have been extended to allow the two countries to ensure their continued energy security whilst they reduce their reliance on Russian energy.
In tandem with the new UK measures, on 2 October 2026, Japan introduced new sanctions against Russia that included the targeting of 35 vessels associated with the shadow fleet. The provision of designated services to these vessels will require authorisation. Authorisation will also be required for any financial transactions associated with these vessels’ purchase, sale, lease or charter.
The Russian shadow fleet
These latest measures have been introduced in response to Russia’s ongoing attempts to evade sanctions through the use of shadow fleet vessels.
It has been reported that nearly 100 shadow fleet tankers were reflagged to the Russian registry during 2025 and 2026. This is an attempt to prevent EU seizures and inspections that are aimed at targeting falsely flagged tankers. However, many of these vessels are old and poorly maintained, giving rise to casualty and pollution concerns.
Russia has also provided some of the shadow fleet vessels with naval escorts and/or protection teams on board.
The shadow fleet, therefore, continues to present numerous legal, political and practical challenges for the UK and other states.
Coordinated response
A number of states are cooperating and coordinating on a joint response to the threats posed by the shadow fleet but also by Russia generally.
On 2 October 2026, British forces teamed up with partner nations from the Joint Expeditionary Force (JEF) for joint military exercises across the North Atlantic, High North and Baltic Sea.
Royal Marines have also trained alongside Danish troops in the Faroe Islands. Some of the exercises are said to have featured training on potential future interceptions of shadow fleet vessels.
These latest training operations come after an August deployment by JEF members that rehearsed maritime escorting along the Baltic Sea.
These multinational operations are aimed at strengthening the defence of both infrastructure and maritime routes.
Iran sanctions
On 29 September 2026, the UK introduced new sanctions measures against Iran that encompassed financial and trade sanctions among others.
The new measures restrict trade in crude oil, petroleum products, natural gas, petrochemical products, gold, precious metals, diamonds, vessels, and energy-related equipment and technology.
The expanded financial sanctions include prohibitions or restrictions on Iran-related investments, the provision of certain loans and credit, as well as insurance and reinsurance services.
The new regulations also include maritime measures in the form of rules allowing the Secretary of State to specify ships for the purposes of shipping and trade sanctions.
The transport sanctions prohibit persons from chartering or operating the specified ships. They also prohibit specified ships or ships owned or controlled or chartered by designated persons from entering UK ports.
Such ships may be detained by the harbour authorities on the orders of the Secretary of State. The Secretary of State has the power to control the movement of these ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are.
A person to whom a direction is given in respect of ships owned, controlled, chartered or operated by a designated person or specified ships is required to comply with it.
A failure to comply with the sanctions relating to specified ships is a triable offence with a maximum sentence of seven years or a fine, or both. This includes failing to comply with:
prohibitions on port entry
the prohibitions related to operating or chartering a specified ship
a port barring direction
a port entry or movement direction
EU sanctions
The EU’s 22nd sanctions package against Russia, expected to be the biggest yet, is awaited and expected to be introduced sometime before the end of 2026.
Find out more about our Sanctions team or contact us today to discuss how we can help.
