Eleanor VaughanDonald Trump signed an order on 16–17 October 2026 waiving key parts of a new US sanctions package against Russia, and by 18 October a UK minister had said Britain takes a "different view". Yvette Cooper said the UK will keep increasing pressure on Moscow, even though Washington has halted the measures that were due to take effect on Sunday 18 October. For British businesses with US partners, that gap is now a legal problem as well as a political one.
What happened and why the UK is out of step
According to CNBC, the Treasury Department issued a general licence on Friday easing sanctions on Russian diesel, running into April 2027. This followed Trump's statement on 9 October, reported by NPR, that Vladimir Putin had agreed to supply more than four million tonnes of diesel to global markets. The White House framed the move as a way to calm fuel prices before the US midterms. The same weekend, Trump waived tariffs linked to Russian energy exports that had been due to start.
Bloomberg reported on 18 October that the UK government is keeping its own Russia sanctions in place. Bloomberg also noted that the episode has pushed foreign policy to the top of Prime Minister Andy Burnham's agenda, three months into the job. Volodymyr Zelenskyy has condemned the waiver as "wrong", according to CNBC.
The practical point for readers is simple. A US licence does not change UK law. Britain and America now treat some Russia-linked energy dealings differently, and a business that sits between the two can find that something permitted on one side of the Atlantic is a criminal or civil exposure on the other.
Why this matters to companies, not only governments
UK sanctions are enforced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury. Its guidance, published on gov.uk, explains that civil liability for breaching financial sanctions is strict. That means a firm can be penalised even if it did not know a transaction breached the rules. Since the Economic Crime Act 2022, the maximum civil penalty is the greater of £1 million or 50% of the value of the breach.
That strict-liability test is what makes a US waiver dangerous for UK firms. A US counterparty may honestly tell you a deal is cleared under its new licence. Under UK law, that assurance is worth nothing.
We covered the wider compliance picture earlier this year in Russia Economy 2026: 85 New UK Sanctions. The October waiver adds a new twist: the sanctions regimes are no longer moving in step.
What a sanctions lawyer looks at first
Sanctions specialists generally begin with four questions when a client reports a "cleared" US deal.
First, jurisdictional hook. Does the transaction involve a UK person, UK-incorporated entity, UK bank or UK-routed payment? If yes, UK rules apply regardless of the US licence.
Second, ownership and control. UK rules can capture entities owned or controlled by a designated person even when the designated person is not named on the contract. Supply chains for fuel, shipping and trading are full of such structures.
Third, ancillary services. Insurance, freight, brokerage and finance can each be restricted separately from the goods themselves.
Fourth, documentation. If OFSI ever asks questions, a firm that can show it checked, escalated and recorded its decision is in a far better position than one that relied on a partner's email.
The key insight from solicitors in this field is that the question to ask is never "is this allowed in America?" It is "what does UK law say about this particular payment, party and route?"
A worked example: a £250,000 fuel-additive contract
Consider a hypothetical Midlands logistics firm with a US parent company. In late October 2026 the parent tells the UK subsidiary that a supplier of diesel-related additives is now "cleared" because the supplier's goods are linked to Russian diesel covered by the new US general licence. The contract is worth £250,000, payable in three instalments through a UK bank.
If the UK subsidiary pays and any link in the chain involves a UK-sanctioned party, the position is stark. The potential OFSI penalty would be the greater of £1 million or 50% of £250,000, which is £125,000. The £1 million figure therefore applies, four times the value of the contract. And because liability is strict, "our American parent told us it was fine" is not a defence, although it may be relevant to how OFSI weighs the penalty.
If, instead, the firm pauses before the first instalment and instructs a sanctions solicitor, the picture changes. The lawyer maps the ownership chain, checks the UK designations list, and advises whether a UK licence is needed. Suppose the check shows no UK designated party and no restricted service. The firm then pays with a written record of its analysis. The cost is a few hours of specialist time, set against a seven-figure exposure.
The rule of thumb is this: if the contract involves a UK entity, UK money or UK services, then a US waiver changes nothing until UK law says it does.
Practical implications for the next 30 days
Reports say the US waiver is a time-limited measure, and Zelenskyy has already argued it benefits only Russia, so further reversals are possible. Companies should expect volatility. Sensible steps include:
- Pause new Russia-linked energy or commodity deals that rely solely on a US licence until UK counsel has reviewed them.
- Update internal screening so that UK designations, not US ones, are the baseline test for UK entities.
- Brief finance teams that payments connected to Russian energy may trigger bank queries or freezes, even where a US licence exists.
- Review insurance and shipping clauses, which often contain sanctions-exclusion wording that bites on the UK position.
- Keep a decision log showing who reviewed the deal, when, and on what basis.
Boards should also decide who owns the question. In many mid-sized firms, sanctions risk falls between finance, procurement and legal, and nobody is clearly responsible when a partner announces a new licence. Naming one accountable person, with authority to stop a payment, is a cheap control that regulators tend to view favourably when they assess how a breach happened.
Individuals are less exposed, but not immune. Anyone who sends money abroad for a relative, invests through a platform with Russia-linked holdings, or runs a small import business should be cautious. Fuel-cost stories can also push investors towards energy shares or funds without checking what is inside them. Our earlier piece on UK fuel prices and car running costs covers the motoring side of the same story.
What to do now
If your business trades with, finances or insures anything touching Russian energy, do not treat the US waiver as a green light. Ask your US partner for the licence reference, then take it to a UK sanctions or regulatory solicitor before money moves. Keep the advice in writing.
You can find a vetted legal expert on Expert Zoom in minutes, compare their experience in sanctions and trade compliance, and book a consultation before your next payment date.
This article is general information about a fast-moving news story and is not legal advice. Sanctions rules change often, and your own circumstances will determine the correct position. Consult a qualified solicitor before acting.
