New UK trade sanctions on Russia restrict transfers of software and technology and expand lists of sanctioned products

On 24 April 2025, the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 (the Amendment Regulations) came into force, amending the Russia (Sanctions) (EU Exit) Regulations 2019 (Russia Regulations) to implement further trade sanctions targeting Russia.

Among other changes, the Amendment Regulations further restrict the transfer of technology and software into Russia, make dozens of additions to the lists of items restricted for trade with Russia and expand sanctions aimed at curtailing trade in Russian synthetic diamonds.

Included in the measures are so termed “sectoral software” restrictions on the provision – including via SaaS – of business enterprise software and technology (including ERP software) and industrial design software and technology to a person connected with Russia or for use in Russia. These business enterprise and industrial design software and technology measures broadly mirror EU sanctions restrictions that have been in force since December 2023.  

The new technology transfer and software sanctions, in particular, have the potential to affect a wide range of businesses. Companies and firms in the energy and industrial sectors may wish to review the new sanctions particularly closely, including if they are continuing to transfer IP or trade secrets into Russia, provide SaaS into Russia or host information, software and technology on cloud servers that is accessible from Russia. 

At the same time, the energy and industrial sectors are not the only sectors potentially affected by the new measures. The measures restricting the provision of business enterprise software have the potential to affect any group that continues to have an operational subsidiary in Russia. New additions to lists of products subject to export and related product restrictions target a range of chemicals, electronics, machinery, plastics, and metals. New additions to import and related product restrictions target helium as well as synthetic diamonds.

The Department for Business and Trade has issued a Notice to Exporters on the new sanctions, and updated its Notice to Importers on Russia import sanctions to reflect the measures. The UK government’s Russia sanctions guidance has also been updated and an Explanatory Memorandum published.

Key measures in the Amendment Regulations are summarised below.

If you would like to further discuss trade sanctions risk and compliance and how the new measures may affect your organisation, please contact Chloe Barker, Katie Palms, Daniel Jones, Calum Ablett, Lydia Rogers, Gaurav Kapoor, Aleks Owczarska or Svens Krumins in our UK Trade and Government Affairs team.

 

New sectoral software prohibitions

The Amendment Regulations introduce new prohibitions on the transfer or making available of “sectoral software and technology” to a person connected with Russia or for use in Russia (see new Chapter 4N of the Russia Regulations).  

The new category of sectoral software and technology broadly comprises:

• business enterprise software and technology, including (but not limited to) enterprise resource planning software;
• industrial design software and technology, including (but not limited to) building information modelling software; and
• oil and gas related software and technology, including (but not limited to) oil and gas exploration and oil and gas production software.

The Amendment Regulations also introduce related prohibitions on the provision of technical assistance, financial services and funds, and brokering services.

Excluded from these prohibitions is any software or technology which is in the public domain or basic scientific research.

As noted above, these restrictions are similar to sanctions previously introduced by the EU in December 2023 – a point reflected in the Explanatory Memorandum accompanying the Amendment Regulations, which states that the new measures align with measures taken by allies. The Explanatory Memorandum also states that the new sanctions aim to reduce the efficiency and productivity of key sectors in the Russian economy, including the oil and gas sector, and will deny Russia’s military industrial complex access to this software.

New compliance guidance accompanying the new sectoral software prohibitions gives examples of transfers considered to be prohibited by the new sanctions (downloading software from the internet, providing the software by means of ‘Software as a Service’ (SaaS) or accessing the software via an app).

The guidance also suggests specific measures to consider to achieve compliance with the sectoral software and technology sanctions, including:

1. contractual clauses requiring controls over restricted software and technology;
2. “No-Russia clauses” in contracts concerning sanctioned sectoral software and technology;
3. collecting and monitoring data on the end users of sectoral software and technology; and
4. proactive assessments of compliance in current business practice.

 

New technology transfer prohibitions

Building on existing sanctions restricting the transfer of physical goods, the Amendment Regulations introduce new prohibitions on the transfer and making available of certain categories of technology to a place in Russia, for use in Russia, or to a person connected with Russia. These categories comprise:

• technology relevant to Russia’s revenue-generating oil and gas industry (ie “energy-related technology” in Schedule 3 of the Russia Regulations); and
• a broad range of industrial technology, including technology on the Common High Priority Items List of items Russia is using in its weapons systems (ie “G7 dependency and further technology” in Schedule 3E of the Russia Regulations and “Russia’s vulnerable technology” in Schedule 3I of the Russia Regulations).

The Amendment Regulations also introduce related prohibitions on the provision of technical assistance, financial services and funds, and brokering services.

The technology captured by these new restrictions generally includes all technology required for the “development”, “production” or “use” of the previously restricted goods falling within the same category.

As above, excluded from these prohibitions is any technology which is in the public domain or basic scientific research.

The Explanatory Memorandum accompanying the new technology prohibitions states that they aim to restrict technology related to goods of strategic importance to Russia’s military-industrial and economic development and restrict Russia’s access to UK expertise in key supply chains.

The new technology prohibitions are accompanied by new compliance guidance. The guidance gives examples of types of information – including, in many cases, intellectual property and trade secrets – that may constitute “technology” prohibited for transfer, as well as examples of the types of activity that may constitute “transfer” of this technology, including phone calls and the use of cloud storage.

 

Additions to lists of restricted goods and technology

The Amendment Regulations make dozens of additions to the lists of items restricted for trade with Russia. These target the export of chemicals, electronics, machinery, plastics, and metals, with the stated aim to weaken the military and industrial capabilities of Russia.

The Explanatory Memorandum states that these categories of newly restricted goods have been chosen to align with measures taken by allies and to target new products identified as important to critical industries supporting the Russian war economy, such as the oil, gas and chemical sectors.

Products newly restricted for export or making available to Russia, and subject to related services restrictions, include:

• Three additional product categories in Schedule 2A (critical industry goods and critical industry technology), included to align with the EU, and found to be used by Russia in its military sector.
• Nine additional chemicals in Schedule 3C (defence and security), which the U.S. has sanctioned for their uses as riot control agents, and which have been found to be used by Russian forces.
• An additional 81 product categories in Schedule 3E (G7 dependency and further goods), to align the UK with EU and some U.S. sanctions.
• 67 new product categories in Schedule 3I (Russia’s vulnerable goods), which have been identified for use in Russia’s critical industries.

 

Import prohibitions on processed synthetic diamonds

The Amendment Regulations introduce a prohibition on the import into the UK of “relevant processed synthetic diamonds”, ie synthetic diamonds classified under commodity codes 7104 21 or 7104 91 which:

• are equal to, or larger than, 0.5 carats;
• were manufactured in Russia; and
• have been processed in a third country.

Related prohibitions on the provision of technical assistance, financial services and funds, and brokering services have also been introduced.

The new restrictions supplement existing prohibitions on: (i) the import, acquisition, etc of diamonds and diamond jewellery that is Russian-origin or located in Russia; and (ii) the import of Russian-origin diamonds that have been processed in a third country.

The Department for Business and Trade has published accompanying guidance on these measures which states that traders should be prepared to provide documentation to demonstrate evidence of an item’s supply chain, and provides examples of evidence that traders could request.

A related General Trade Licence for sanctioned Russian synthetic diamonds processed in third countries was published on 24 April 2025. The licence permits otherwise prohibited activities in relation to synthetic diamonds that have not been located in Russia at any time beginning with 24 April 2025.