4 February 2026 EU RUSSIAN LNG IMPORT BAN – UPDATE On 26 January 2026, the 27 EU Member states formally adopted the ban on the import of LNG into the EU, as previously detailed in the 19th EU sanctions package and in our below Circular dated 17 November 2025. Further, the FAQs published on 21 November 2025 confirmed that the prohibition includes not only the import of Russian LNG into the EU but also the transport of Russian LNG to third countries. It is also prohibited to provide technical or financial assistance, including insurance, related to these prohibitions. Members are reminded of the applicable wind-down periods as set out in the Circular. 17 November 2025 EU, UK and US Sanctions Updates October and November 2025 have witnessed a significant wave of new restrictions and designations against Russia, introduced by the EU, the UK, and the US. Further details are set out below, but we highlight several key common themes: • Coordinated escalation targeting Russia’s energy sector, with particular focus on LNG (including insurance of the carriage of LNG) and major oil companies. • Heightened scrutiny of shadow fleet operations and third-country intermediaries facilitating sanctions evasion. • Broadened export controls and tightened financial measures aimed at closing circumvention channels. EU Sanctions – 19th Package On 23 October 2025, the Council of the European Union introduced its 19th sanctions package, significantly expanding restrictions on Russia’s energy sector, financial infrastructure, and military-industrial complex by amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. Key measures include: • Energy Sector • Comprehensive ban on imports of LNG originating in or exported from Russia into the EU: ▪ Effective 25 April 2026 for short-term contracts ▪ Effective 1 January 2027 for long-term contracts (exceeding one year in duration and concluded before 17 June 2025) • Prohibition on technical and financial assistance (including insurance) related to the above prohibitions on the import of LNG. • Prohibition on transshipment of Russian LNG in EU ports • Tightened transaction ban on Rosneft and Gazprom Nef • Third-Country Enablers • Sanctions on Chinese entities (two refineries and an oil trader) purchasing Russian crude • Listing of Litasco Middle East DMCC (Lukoil’s UAE-based company) • Additional Measures • 69 individuals designated • 45 entities designated for supporting Russia’s military and industrial complex • 117 vessels designated, becoming subject to a port access ban and a ban on the provision of a broad range of services (including insurance) related to maritime transport (bringing the total number of designated vessels to 557) • Prohibition on providing certain forms of (re)insurance to vessels formerly operated by Russian interests during the five years following the sale or any form of lease arrangement to third country buyers or lessees. • Expanded export controls on electronic components, military-grade metals, and industrial goods • Import restrictions on additional metal, oxides and alloys used in the military systems and acyclic hydrocarbons • Sanctions on maritime registries providing false flags to shadow fleet vessels • Prior authorization requirement for any services provided to the Russian Government not already covered by Regulation (EU) 833/2014 • Transaction ban expanded to five Russian banks (Istina Bank, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank). Four banks fro