UK guidance on exceptions to Russia trade sanctions

The Foreign, Commonwealth & Development Office published statutory guidance setting out a consolidated list of exceptions to the Russia trade and transport sanctions on 25 September 2025.

• Main announcement: The guidance lists multiple automatic exceptions (no licence required) across trade, transport and services including personal effects and personal use (regulation 60A), luxury goods, consumer communication devices and software updates (regulation 60B), removal of aircraft and vessels (regulation 60C), technical assistance in life‑threatening situations (regulation 60D), accounting, legal and consultancy services (regulation 60DA/60DB), maritime goods for humanitarian or health emergencies (regulation 60E) and exceptions relating to non-government controlled Ukrainian territory and humanitarian assistance (regulations 61ZA, 62).
• Key details & timelines: Exceptions generally apply automatically but some have reporting or notification obligations; notable specifics include the £10,000 limit for banknotes carried for personal use when travelling to Russia (regulation 60F); a sectoral software exception for contracts concluded before 23 April 2025 where acts must be carried out and notified to the Secretary of State by 22 July 2025 (regulation 60DZA); emergency justification must be provided to the Secretary of State within 5 working days (regulation 61); and conditions for removal of aircraft/vessels require movement under their own power and not for transfer of ownership (regulation 60C).