Expanded Russia-Related Sanctions 2025: Risk & Compliance for Energy and Infrastructure Firms

UK, US and EU expanded Russia-related sanctions raise compliance risk for energy and infrastructure firms. Learn key changes, impacts and mitigation steps.

In 2025 the sanctions landscape for the energy and infrastructure sectors shifted sharply. In August, Bracewell highlighted the evolving impact of UK and EU sanctions on corporations operating in these industries. That trajectory accelerated in October, when the UK, US and EU introduced a more expansive set of Russia-related sanctions designed to increase pressure on Russia to end the war in Ukraine.

A key moment came on October 15, 2025, when the UK Office of Financial Sanctions targeted two of Russia’s largest oil companies — part of coordinated measures that represent the strongest packages to date from each authority. These new measures broaden the scope of prohibitions and increase secondary risk for any counterparty with ties to the Russian energy sector.

What changed: the recent packages expand designation lists, tighten export controls, and strengthen financial restrictions. For energy and infrastructure firms this means greater scrutiny of counterparties, more limited financing options, and enhanced controls on tech and equipment transfers. Cross-jurisdictional alignment between the UK, US and EU also raises the operational risk of inadvertent non-compliance because a transaction lawful in one jurisdiction may now trigger restrictions under another.

Impacts and increased risk: transacting with players connected to the Russian energy sector now carries elevated reputational, legal and financial risk. Banks and insurers are likely to apply stricter sanctions screening and de-risking measures; supply chains can be disrupted; and contractual exposures may increase if counterparties are designated or indirectly affected by secondary sanctions or export control rules.

How to manage and mitigate risk: a proactive, layered compliance approach is essential. Key steps include enhanced due diligence and ongoing monitoring of counterparties; implementing robust sanctions screening that covers UK, US and EU lists; updating contractual clauses to include sanctions exit and indemnity provisions; and conducting scenario planning for sudden designations or payment disruptions. Engage external sanctions counsel when questions arise and coordinate with banks and insurers to confirm transactional permissibility.

Conclusion: the October escalation of Russia-related sanctions marks a significant change for energy and infrastructure sectors. While the risk is real and elevated, it is manageable with timely updates to sanctions compliance programs, rigorous risk assessments, and clear contractual protections. Firms that act now can reduce exposure and continue to operate confidently in a stricter regulatory environment.

Back