Russia sanctions update 2026: UK regulatory compliance under health and safety law and business risk for duty holders
What has changed
The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 introduce amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 and update the enforcement framework via the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024. Regulations 3 to 29 make these amendments to the 2019 Regulations, while Regulation 30 amends the 2024 TASSCE enforcement regime. The changes reflect ongoing adjustment of UK sanctions policy in response to evolving international considerations and post EU exit arrangements.
Why this matters
For organisations, the amendments tighten the landscape of transactions that are prohibited or restricted and alter how enforcement can be pursued. This intersects with UK health and safety law by heightening governance and risk management expectations around regulatory compliance and responsibility for supplier due diligence, contract controls and audit readiness. Businesses across sectors such as import/export, logistics and manufacturing may face new or expanded screening duties and penalties for non compliance.
What organisations should do next
Prioritise a sanctions compliance review as part of your health and safety and legally required governance framework. Actions include:
- Review current sanctions screening processes for suppliers, customers and payment flows to ensure alignment with the amended 2019 Regulations and the TASSCE framework.
- Update due diligence procedures and contract clauses to reflect the new restrictions and enforcement options.
- Enhance training for relevant staff on sanctions obligations and high risk jurisdictions.
- Revisit risk assessment and control measures to address sanctions related financial and operational risk alongside health and safety risk controls.
- Engage competent advice where needed (see Competent Person support) and consider integrating these controls with your ISO 45001 management system for systematic oversight.
Synergos Consultancy can assist with compliant policy design and risk controls, including integration with ISO 45001 and health and safety risk assessments. Relevant resources:
UK organisations must strengthen sanctions screening and enforcement readiness to stay compliant.
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