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Paul Henty reports on rule changes to tackle shadow fleets, proxies & other sanctions evasion routes
- New ‘end-user controls’ across the UK’s sanctions regimes allow the government to notify an exporter that an apparently innocent counterparty is a proxy for a sanctioned state, making it an offence to supply without a licence.
- The Russia Amendments target the shadow fleet, ‘oil laundering’ through third-country refineries, and add construction services to the banned professional services list, subject to a wind-down to 20 August 2026.
- Enforcement is tightening: maximum fines are set to double to £2m or the full value of the breach once legislation allows.
May 2026 brought a substantial package of amendments to the UK’s sanctions framework: the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (SI 2026/443), in force from 13 May, followed a week later by the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) (the Russia Amendments), in force from 20 May 2026. The package demands the attention of businesses across
