Sanctions on Russia
Updated
Summary
Sanctions on Russia are the legal restrictions Western governments use to cut Russia's income and access to money, technology and markets because of its war on Ukraine. The European Union has adopted 21 numbered packages since February 2022, the latest on 2026-07-23, and its economic sanctions now run to 2027-07-31. The United States runs a parallel program under Executive Order 14024, administered by Treasury's OFAC, and in September 2026 enacted the Lindsey O. Graham Sanctioning Russia and Iran Act, whose new tariffs and most new sanctions were waived on 2026-10-16. The United Kingdom has sanctioned over 3,500 individuals, entities and ships. The tools include asset freezes, bans on trade and finance, an oil price cap of $44.10 per barrel in the EU and UK, and about EUR 210 billion of Russian central bank assets immobilised in the EU.
Key numbers
EU numbered sanctions packages (latest): 21 (21st adopted 2026-07-23) (as of 2026-07-23). Source: consilium.europa.eu
EU listings under the Ukraine territorial-integrity regime: close to 4,600 (as of 2026-10-12). Source: consilium.europa.eu
EU/UK crude oil price cap: $44.10 per barrel (EU from 2026-02-01; EU adjustment suspended 2026-07-24 to 2027-07-14) (as of 2026-07-24). Source: finance.ec.europa.eu
EU economic sanctions expiry: 2027-07-31 (12-month renewal) (as of 2026-06-25). Source: consilium.europa.eu
EU shadow-fleet vessels under port-access ban: 632 after the 20th package; 41 more in the 21st (as of 2026-07-23). Source: consilium.europa.eu
Central Bank of Russia assets immobilised in the EU: about EUR 210 billion (as of 2026-08-12). Source: consilium.europa.eu
EU Ukraine Support Loan, disbursed / total: EUR 11.6 billion / EUR 90 billion (as of 2026-08-12). Source: consilium.europa.eu
UK Russia-regime designations: over 3,500 individuals, entities and ships (as of 2026-10-13). Source: gov.uk
Shadow-fleet vessels designated, UK vs US: over 600 (UK) vs 216 (US, per senators' letter) (as of 2026-10-08). Source: gov.uk
Graham Act duties (waived 2026-10-16): 500% on Russian goods; 100% on top-5 buyers and top-5 facilitators (as of 2026-10-16). Source: whitehouse.gov
OFAC GL 135 (Russian diesel) expiry: 12:01 a.m. EDT 2027-04-07 (as of 2026-10-09). Source: ofac.treasury.gov
Timeline
2026-10-16 — White House order waives all Graham Act duties (secs. 112-113) and sanctions in secs. 102(a),(d),(e), 103-111 and 117, with no expiry; existing EO-based sanctions untouched. (Source: whitehouse.gov)
2026-10-15 — 22 House members led by McCaul and Costa urge full implementation before 2026-10-18 and revocation of GL 135. (Source: mccaul.house.gov)
2026-10-13 — Eleven bipartisan senators ask the President to rescind GL 135 and use the Graham Act's authorities. (Source: blumenthal.senate.gov)
2026-10-12 — EU lists 1,569 military-industrial individuals and entities, its largest single listing round; regime total near 4,600. (Source: consilium.europa.eu)
2026-10-09 — OFAC issues GL 135 authorizing Russian-origin diesel transactions, including US imports, to 2027-04-07. (Source: ofac.treasury.gov)
2026-10-08 — UK makes 38 designations including 12 shadow-fleet tankers; UK total passes 600 vessels. (Source: gov.uk)
2026-10-06 — Senators Shaheen and Wicker urge State and Treasury to match EU/UK shadow-fleet listings (600+ vs 216 US). (Source: foreign.senate.gov)
2026-09-22 — EU extends individual territorial-integrity listings for three years, to 2029-09-22. (Source: consilium.europa.eu)
2026-09-18 — President signs H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. (Source: whitehouse.gov)
2026-09-14 — House Rules Committee rejects, 3-7, amendments to narrow the waiver, strike secondary tariffs and name non-exempt countries. (Source: rules.house.gov)
2026-07-23 — EU 21st package: 218 listings, 41 vessels, bank and crypto bans; price-cap adjustment paused to July 2027. (Source: consilium.europa.eu)
2026-06-25 — EU renews economic sanctions for twelve months, to 2027-07-31. (Source: consilium.europa.eu)
2026-04-23 — EU 20th package: 120 listings, 46 vessels (632 total), 20 banks, first anti-circumvention measure (Kyrgyzstan). (Source: consilium.europa.eu)
2026-03-24 — US continues the EO 14024 national emergency on Russia's harmful foreign activities for one year beyond 2026-04-15. (Source: federalregister.gov)
2026-01-15 — Commission applies the dynamic mechanism: EU crude cap set at $44.10 per barrel from 2026-02-01; UK matches. (Source: finance.ec.europa.eu)
2025-12-18 — European Council agrees a EUR 90 billion loan to Ukraine for 2026-2027, repayable only once reparations are received. (Source: consilium.europa.eu)
2025-12-12 — Council bans transfers of immobilised Central Bank of Russia assets back to Russia (Regulation 2025/2600). (Source: consilium.europa.eu)
2025-10-23 — EU 19th package: 117 more vessels and a ban on Russian LNG imports. (Source: consilium.europa.eu)
2025-10-22 — US Treasury designates Rosneft and Lukoil under EO 14024. (Source: home.treasury.gov)
2025-07-18 — EU 18th package lowers the crude cap from $60 to $47.6 and creates the dynamic cap mechanism. (Source: consilium.europa.eu)
Key actors and links
U.S. Treasury (actor:us-treasury): OFAC runs the EO 14024 program (31 CFR 587), designations such as Rosneft and Lukoil, and general licences such as GL 135 on Russian diesel.
U.S. Department of State (actor:us-department-of-state): Secretary of State can end the Graham Act waivers under the 2026-10-16 order; co-addressee of congressional letters on implementation.
U.S. Senate (actor:us-senate): Passed the Graham Act; senators of both parties (Shaheen, Wicker, Tillis, McConnell and others) are pressing for implementation and against GL 135.
European Union (actor:european-union): Largest sanctions builder: 21 packages, close to 4,600 listings, the dynamic price cap, LNG import ban and about EUR 210 billion of immobilised central bank assets.
United Kingdom (country:united-kingdom): Over 3,500 Russia designations and over 600 shadow-fleet vessels; matched the $44.10 cap; joined the EUR 90 billion Ukraine Support Loan.
Russia (country:russia): The target: state banks, energy firms, the central bank's reserves, shadow-fleet tankers and military suppliers.
Ukraine (country:ukraine): Beneficiary of the frozen-asset structures (ERA loans, EUR 90 billion loan repayable from reparations); the Graham Act ties termination to a peace deal Ukraine accepts.
Crude oil (commodity:crude-oil): Main revenue channel targeted: EU import ban, price cap, shadow-fleet listings and the waived US secondary tariff on top buyers.
Refined products (commodity:diesel): GL 135 carves Russian diesel out of US sanctions to 2027-04-07, a US-only relaxation.
LNG (commodity:lng): EU bans Russian LNG imports, with long-term contracts covered from 2027-01-01.
India (country:india): Named by House members as one of Russia's largest crude buyers, so exposed to the now-waived section 113 tariff.
China (country:china): Named by House members as Russia's largest crude buyer and by senators as a main enabler; EU lists Chinese suppliers of dual-use goods.
Sanctions/enforcement (indicator:energy-sanctions-enforcement): Tracks OFAC energy enforcement for Russia and Iran; this node supplies the legal regime that enforcement applies.
Russia–Ukraine armistice / frozen conflict (theme:russia-ukraine-armistice): Sanctions relief is a bargaining chip; the Graham Act's section 117 links termination to a signed peace agreement, though that section is waived.
Russia–Ukraine war (theme:russia-ukraine-war): The war is the legal predicate for the EU, UK and US programs since 2022.
Why it matters now
The regime is diverging across the Atlantic. Europe keeps tightening: the 20th and 21st packages added 338 listings (120 plus 218) and banned 87 more shadow-fleet vessels (46 plus 41), and on 2026-10-12 the EU listed 1,569 more people and companies at once. Brussels also renewed its economic sanctions for twelve months instead of the usual six, which removes a January veto point for a single member state. Washington is moving the other way at the margin. Congress passed the Graham Act to force secondary tariffs of up to 100 percent on the biggest buyers of Russian oil and gas. The President signed it, then waived those tariffs and most new sanctions two days before they bit, and OFAC licensed Russian diesel imports through 2027-04-07. Two senators say the EU and UK have listed over 600 shadow-fleet vessels against 216 for the US.
The causal mechanism runs through oil revenue. A price cap only works if Western shipping, insurance and finance are needed to move the oil; a shadow fleet avoids them, so listing tankers is how the cap gets teeth. Secondary tariffs aimed to raise the cost for buyers such as China and India instead. With that tool held off, pressure on buyers now depends mainly on EU and UK listings and on existing US designations like Rosneft and Lukoil. The Hormuz disruption matters too: the EU froze its cap at $44.10 rather than let the formula raise it, citing the risk that Russia would profit from the strait's closure. Inference (AA): the frozen assets are now Europe's main lever, because the EUR 90 billion loan is repayable from reparations and the assets stay immobilised until Russia pays.
Risks and open questions
Bull case: The regime is getting stronger, at least in Europe. The EU adopted two packages in 2026, listed 1,569 targets in a single day, and extended economic sanctions to 2027-07-31, so no renewal vote is due in January. It also banned transfers of central bank assets back to Russia without an end date and built a EUR 90 billion loan that Ukraine repays only from reparations, which ties the assets to the war's outcome. The UK matches on price cap and shadow fleet. In Washington the Graham Act exists as law: a waiver can be withdrawn by the President or the Secretary of State at any time, and bipartisan pressure from both chambers is visible. OFAC's 2025 designation of Rosneft and Lukoil still stands, and its licences around Lukoil's foreign assets show that designation is forcing divestment.
Bear case: The US is easing at the margin. The order waives every new tariff and most new sanctions of the Graham Act, with no end date, and the administration has not published its reasons. OFAC licensed Russian diesel, including imports into the United States, for six months. The order also waives section 117, the clause that tied lifting the codified sanctions to a peace deal and a congressional review. Inference (AA): that weakens Congress's lock on future relief. The shadow-fleet gap with Europe (216 US designations against over 600) suggests weaker US enforcement of oil restrictions. The price cap depends on Western services that a shadow fleet avoids. Europe is not fully united either: the Czech Republic, Hungary and Slovakia were shielded from the costs of the EUR 90 billion loan, and the reparations loan that would use the assets directly is still unfinished.
Falsifiers: - The President or Secretary of State ends the Graham Act waivers, or Congress passes a law overriding them. - OFAC makes large new Russia designations, especially of shadow-fleet tankers, narrowing the gap with EU/UK listings. - OFAC revokes or lets GL 135 lapse on 2027-04-07 without renewal (weakens the bear case). - The EU fails to adopt a 22nd package or lets economic sanctions lapse at 2027-07-31. - The EU uses the immobilised central bank assets directly (a reparations loan) or, conversely, releases them in a peace settlement. - A Council review after 2027-01-15 raises the price cap, or the maritime services ban is adopted.
What to watch
Publication of the Section 115 certification and report on the Graham Act waivers, or a congressional move against them. (no scheduled date); speculative, no scheduled source
USTR monitoring of Russian crude and gas purchases under section 3 of the 2026-10-16 order; any decision to end the waivers. (no scheduled date); Source: whitehouse.gov
Commission calculates the average Russian crude price for the Council's price-cap review. (by 2027-01-15); Source: eur-lex.europa.eu
EU ban on Russian LNG imports under long-term contracts takes effect. (2027-01-01); Source: commission.europa.eu
OFAC GL 135 on Russian diesel expires unless renewed. (2027-04-07); Source: ofac.treasury.gov
EU automatic price-cap adjustment resumes. (2027-07-15); Source: eur-lex.europa.eu
EU economic sanctions expire unless the Council renews them. (2027-07-31); Source: consilium.europa.eu
A 22nd EU package, possibly including the maritime services ban prepared in the 20th. (no scheduled date); speculative, no scheduled source
AA inference
Inference (AA): This node is the graph's legal layer between the war and Russian oil, diesel and LNG flows. The US waiver turns the Graham Act into a held switch: it can be flipped back on without Congress, so it adds tail risk for large buyers of Russian crude without changing flows today. Europe's twelve-month renewal and the open-ended asset immobilisation make EU sanctions stickier than US ones, which means a peace deal would likely see US relief come first and EU relief later. The view weakens if the EU fails to adopt further measures or if OFAC resumes major Russia designations.
Sources
On 2026-10-16 the White House issued an order implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. It describes a 500 percent ad valorem duty increase on Russian goods, a 100 percent increase on the five largest importers of Russian crude oil and natural gas that knowingly make new purchases on or after 2026-10-18, and a 100 percent increase on the top five facilitators of Russian oil sanctions evasion. (Source: whitehouse.gov, accessed 2026-10-17)
Section 4 of the 2026-10-16 order waives all duties under sections 112 and 113 of the Act, and the Act's sanctions in sections 102(a), 102(d), 102(e), 103 through 111 and 117. The waivers last until the President or the Secretary of State decides further action is appropriate; no expiry date is set. The order says the Section 115 certification and report were submitted to Congress. (Source: whitehouse.gov, accessed 2026-10-17)
The 2026-10-16 order says nothing in it affects sanctions under executive orders addressing the national emergency concerning harmful activities of the Russian government, which the President continued on 2026-03-24 (91 FR 15515). Section 3 tells the Trade Representative to monitor countries' purchases of Russian crude oil and natural gas and report to the President. (Source: whitehouse.gov, accessed 2026-10-17)
The White House says the President signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, on 2026-09-18. (Source: whitehouse.gov, accessed 2026-10-17)
In the Senate-passed text of H.R. 5334, Title I covers sanctions on persons supporting the Russian government (sec. 102), state-linked banks including the Central Bank of Russia (103), transfers of funds (105), US exchange listings (106), new US investment in Russia (107), energy investment and exports (108), Russian sovereign debt (109), financial messaging (110) and uranium (111); section 112 sets duties of up to 500 percent on Russian goods and section 113 duties of up to 100 percent on the top five buyers of Russian crude or gas or facilitators of evasion. (Source: govinfo.gov, accessed 2026-10-17)
In the Senate-passed text, section 115 lets the President waive any Title I sanction, restriction or duty after certifying to Congress that it serves US national interests; section 117 lets sanctions on Russia be terminated only after certifying a peace agreement accepted by Ukraine's government, followed by a 30-day (or 60-day) congressional review in which Congress may pass a joint resolution of disapproval. Division A, except the Iran Sanctions Act extension, terminates 5 years after enactment. (Source: govinfo.gov, accessed 2026-10-17)
On 2026-09-14 the House Rules Committee rejected, 3 to 7 (record vote 413), an amendment to allow waivers only if 'vital to the national security of the United States'; it also rejected, 3 to 7, amendments to strike the secondary-tariff section and to list non-exempt countries. The House adopted the rule on 2026-09-15 by 214 to 211. (Source: rules.house.gov, accessed 2026-10-17)
In an 2026-10-06 letter to Secretaries Rubio and Bessent, Senators Shaheen and Wicker said the EU and UK had designated over 600 shadow-fleet vessels against 216 for the United States, mostly in early 2025, and that 'the majority of the Act's provisions go into effect on October 18th.' (Source: foreign.senate.gov, accessed 2026-10-17)
On 2026-10-13, eleven senators, including Republicans Tillis, Collins, Murkowski and McConnell, asked the President to rescind OFAC General License 135 and to use the Graham Act's authorities; they claim the licence gives Moscow more revenue with negligible effect on US fuel prices. (Source: blumenthal.senate.gov, accessed 2026-10-17)
On 2026-10-15, Representatives McCaul and Costa and 20 colleagues urged full implementation of the Act before the 2026-10-18 deadline, revocation of GL 135, and any waiver kept narrow and time-limited. (Source: mccaul.house.gov, accessed 2026-10-17)
On 2026-03-24 the President continued for one year, beyond 2026-04-15, the national emergency declared in EO 14024 (2021-04-15) concerning specified harmful foreign activities of the Russian government; it was published at 91 FR 15515 on 2026-03-27. (Source: federalregister.gov, accessed 2026-10-17)
OFAC administers the Russian Harmful Foreign Activities Sanctions under EOs 14024, 14039, 14066, 14068, 14071 and 14114 and 31 CFR part 587; Russia-related general licences issued or amended in 2026 include GL 129A (2026-03-05), GL 131J (2026-09-18), GL 13S (2026-10-08), GL 135 (2026-10-09), and GL 128D and GL 130B (2026-10-15). (Source: ofac.treasury.gov, accessed 2026-10-17)
OFAC General License 135, dated 2026-10-09, authorizes transactions for the sale, delivery, offloading and importation, including into the United States, of Russian-origin diesel fuel otherwise prohibited under 31 CFR parts 587 and 589, through 12:01 a.m. EDT on 2027-04-07. It does not authorize debits to US accounts of Russia's central bank, National Wealth Fund or Ministry of Finance. (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2026-10-15 OFAC issued GL 128D (Lukoil retail service stations outside Russia) and GL 130B (certain Lukoil entities in Bulgaria). (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2025-10-22 Treasury designated Rosneft and Lukoil under EO 14024, with 34 Russia-based subsidiaries (28 Rosneft, 6 Lukoil); Secretary Bessent called for an immediate ceasefire. (Source: home.treasury.gov, accessed 2026-10-17)
The EU Council lists 21 numbered sanctions packages since February 2022: the 18th on 2025-07-18, the 19th on 2025-10-23, the 20th on 2026-04-23 and the 21st on 2026-07-23. The 18th lowered the crude price cap from $60 to $47.6 per barrel; the 19th banned imports of Russian LNG into the EU. (Source: consilium.europa.eu, accessed 2026-10-17)
The 21st package (2026-07-23) added 218 listings (48 individuals, 170 entities), a port-access ban on 41 more shadow-fleet vessels, asset freezes on 94 banks and major financial institutions, a transaction ban on 33 more Russian institutions, and a transaction ban on 14 crypto platforms in third countries. It paused the price cap's automatic adjustment until 2027-07-15. (Source: consilium.europa.eu, accessed 2026-10-17)
The Commission said the 21st package suspends the price-cap adjustment so Russia does not benefit from the closure of the Strait of Hormuz, and that more than 100 Russian banks are now under transaction bans. (Source: ec.europa.eu, accessed 2026-10-17)
The 20th package (2026-04-23) added 120 listings, banned 46 more shadow-fleet vessels for a total of 632, imposed transaction bans on 20 Russian banks, banned Russian crypto-transfer providers and the RUBx token, first activated the anti-circumvention tool against exports of CNC machines and radios to Kyrgyzstan, and laid the basis for a future maritime services ban on Russian oil. (Source: consilium.europa.eu, accessed 2026-10-17)
On 2026-06-25 the Council extended EU economic sanctions on Russia for twelve months, until 2027-07-31, after the European Council of 18-19 June 2026 agreed a twelve-month extension; the measures cover trade, finance, energy and dual-use technology. (Source: consilium.europa.eu, accessed 2026-10-17)
On 2026-10-12 the EU listed 1,569 individuals and entities in Russia's military-industrial complex (826 companies and 743 chief executives), which the Council called the largest set of listings ever; listings under the regime are now close to 4,600. (Source: consilium.europa.eu, accessed 2026-10-17)
On 2026-09-22 the Council extended individual listings under the territorial-integrity regime for three years, until 2029-09-22. (Source: consilium.europa.eu, accessed 2026-10-17)
Under the EU's dynamic mechanism the crude price cap is set 15% below the average Urals price over the previous 22 weeks and reviewed every six months; on 2026-01-15 the Commission set it at $44.10 per barrel effective 2026-02-01. (Source: finance.ec.europa.eu, accessed 2026-10-17)
Council Regulation (EU) 2026/1848 suspends the cap-amendment procedure from 2026-07-24 to 2027-07-14; the Commission calculates the average Russian crude price by 2027-01-15 for a Council review, and absent a Council decision the applicable cap remains in place. (Source: eur-lex.europa.eu, accessed 2026-10-17)
The Commission says the EU bans Russian LNG imports from 2027-01-01 for long-term contracts; product caps are $100 per barrel for premium-to-crude products and $45 for discount products. (Source: commission.europa.eu, accessed 2026-10-17)
On 2025-12-12 the Council adopted Regulation (EU) 2025/2600, temporarily prohibiting transfers of immobilised Central Bank of Russia assets back to Russia, for as long as Russia's resources pose serious economic difficulties for the EU. (Source: consilium.europa.eu, accessed 2026-10-17)
On 2025-12-18 the European Council agreed a EUR 90 billion loan to Ukraine for 2026-2027 funded by EU borrowing, repaid by Ukraine 'only once reparations are received'; the immobilised assets stay immobilised and the EU 'reserves its right' to use them to repay the loan. Work on a separate Reparations Loan continues. (Source: consilium.europa.eu, accessed 2026-10-17)
About EUR 210 billion of Central Bank of Russia assets are immobilised in the EU. As of 2026-08-12, EUR 11.6 billion of the EUR 90 billion Ukraine Support Loan had been disbursed (EUR 3.2 billion macro-financial, EUR 8.4 billion defence). (Source: consilium.europa.eu, accessed 2026-10-17)
The Commission proposed the Ukraine Support Loan on 2026-01-14 as a limited-recourse loan: about EUR 60 billion for military and EUR 30 billion for budget support. The reparation loan proposed on 2025-12-03 was not withdrawn. (Source: enlargement.ec.europa.eu, accessed 2026-10-17)
The UK says it has sanctioned over 3,500 individuals, entities and ships under its Russia regime, over 3,300 since the full-scale invasion (page updated 2026-10-13), and that it joined the EUR 90 billion Ukraine Support Loan on 2026-07-13. (Source: gov.uk, accessed 2026-10-17)
On 2026-10-08 the UK made 38 designations, including 12 shadow-fleet tankers, bringing the UK total of sanctioned shadow-fleet vessels to over 600. (Source: gov.uk, accessed 2026-10-17)
The UK lowered its Russian crude price cap from $47.60 to $44.10 effective 23:01 on 2026-01-31; its 2026-10-01 licence amendment extended the Sakhalin-2 exemption to 2026-12-31. (Source: assets.publishing.service.gov.uk, accessed 2026-10-17)