New General Trade Licences Issued Under the UK Russia Sanctions Regime

On 19 May 2026, the Department for Business and Trade (DBT) issued two new general trade licences under the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations), both of which came into force on 20 May 2026. The licences sit alongside the latest amendments to the regime, which introduced new prohibitions on the import of processed oil products derived from Russian crude and on the maritime transportation of Russian liquefied natural gas (LNG) — measures that broadly mirror existing European Union (EU) restrictions.

General Trade Licence GBSAN0004 disapplies the prohibitions in regulations 46Z9F to 46Z9I of Chapter 4IB of the Russia Regulations for a narrow set of products: diesel falling within commodity codes 2710 19 42 and 2710 19 44, and jet fuel under 2710 19 21, in each case refined in a third country from Russian-origin crude. The licence is of indefinite duration but is subject to periodic review and may be varied, revoked or suspended at any time. It has been issued against a backdrop of tightening global middle-distillate supply following disruption to shipping through the Strait of Hormuz, and represents a calibrated relaxation rather than a wholesale carve-out — other CN 2710 products remain caught by the import ban.

The second licence authorises specified activities that would otherwise be prohibited under the new Chapter 4LA. It permits the maritime supply or delivery of LNG originating at the Sakhalin-2 or Yamal LNG terminals, either to a third country or between third countries, together with associated financial and brokering services. The authorisation is limited to contracts of one year or less in duration and expires on 1 January 2027, reflecting the time-limited nature of the carve-out for short-term LNG arrangements.

For compliance teams, several practical points warrant attention. Use of GBSAN0004 carries record-keeping obligations under regulation 76 of the Russia Regulations, and traders must notify DBT within 30 days of first relying on the licence by emailing importsanctions@businessandtrade.gov.uk. Customs declarations require document code 9L51 and the licence number. While documentary evidence of supply chain origin is not mandated for imports made under the licence, importers sourcing from countries that are net exporters of crude oil are advised to seek contractual assurances that the goods are not derived from Russian crude — and HMRC retains the ability to request evidence retrospectively. For the LNG licence, the activity must genuinely fulfil a qualifying short-term contract and the cargo must originate at one of the two named terminals.

Both licences should be read in full before any reliance is placed on them, as the authorisations are narrowly scoped and the conditions are exact. The Office of Trade Sanctions Implementation (OTSI) maintains the published texts and accompanying guidance on GOV.UK.