Look up exceptions to the Russia trade and transport sanctions
Source: gov.uk (2025-09-25)

As part of statutory guidance to the Russia regulations: a list of exceptions that allow activities otherwise subject to sanctions in certain defined circumstances.

An exception applies automatically so you do not need to get a licence, but some exceptions have reporting obligations.

To check the full legal wording of an exception, go to the regulations listed in Part 7 of the Russia regulations (https://www.legislation.gov.uk/uksi/2019/855/part/7). If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

Exceptions for exporting, making available, supply and transfer

Exceptions for personal effects, personal use, diplomatic missions etc (regulation 60A)

60A exceptions for restricted goods and technology

These exceptions relate to prohibitions in part 5 chapter 2 about the export, supply, delivery, making available or transfer of critical industry goods or technology, or quantum computing or advanced materials goods or technology, and related services to or for use in Russia, to a person connected with Russia, to a Russian-flagged ship, or to a place in Russia, including from a third country.

The exception applies if the goods or technology are:
- the personal effects of a person travelling to Russia, or
- of a non-commercial nature for the personal use of a person travelling to Russia and contained in that person’s luggage, or
- necessary for the official purposes of a diplomatic mission or consular post in Russia, or of an international organisation enjoying immunities in the UK in accordance with international law
60A exceptions for luxury goods

These exceptions relate to prohibitions in regulation 46B about the export, supply, delivery or making available of luxury goods, and related services, to or for use in Russia, or to a person connected with Russia.

The exception applies if the luxury goods are:
- necessary for the official purposes of a diplomatic mission or consular post in Russia, or of an international organisation enjoying immunities in accordance with international law, or
- the personal effects of their staff, or
- within commodity codes 7113 00 00 and 7114 00 00, and for personal use of and owned by the natural person exporting it, or an immediate family member, travelling with them to Russia, contained in their luggage provided that the items are not intended for sale
60A exceptions for G7 dependency and further goods and technology

These exceptions relate to prohibitions in chapter 4H about the export, supply, delivery, making available or transfer of G7 dependency and further goods or technology, and related services, to or for use in Russia, to a person connected with Russia, or to a place in Russia.

The exception applies if the G7 dependency and further goods or technology are:
- necessary for the official purposes of a diplomatic mission or consular post in Russia, or an international organisation enjoying immunities in accordance with international law, or
- the personal effects of their staff
60A exceptions for Russia’s vulnerable goods and technology

These exceptions relate to prohibitions in chapter 4M about the export, supply, delivery, making available or transfer of Russia’s vulnerable goods or technology, and related services, to or for use in Russia, to a person connected with Russia, or to a place in Russia.

The exception applies if the vulnerable goods or technology are:
- necessary for the official purposes of a diplomatic mission or consular post in Russia, or an international organisation enjoying immunities in accordance with international law, or
- the personal effects of their staff
60A exceptions for sectoral software and technology

These exceptions relate to prohibitions in chapter 4N about the making available or transfer of sectoral software or technology, and related services, to or for use in Russia, to a person connected with Russia or to a place in Russia.

The exception applies if the sectoral software or technology are:
- necessary for the official purposes of a diplomatic mission or consular post in Russia or an international organisation enjoying immunities in accordance with international law
Exceptions for consumer communication devices and software updates (regulation 60B)

These exceptions relate to prohibitions in regulations 22, 24(1)(a), 25(1)(a) and (b), 26(1)(a) and (b) about the export, supply, delivery, making available or transfer of certain luxury, G7 dependency and further goods and technology or critical industry goods and technology, and related services, to or for use in Russia, a person connected with Russia or to a place in Russia.

The exception applies if the luxury, G7 dependency and further goods or critical industry goods or technology are:
- consumer communication devices for civilian use, or
- software updates for civilian use
Exceptions for the removal of aircraft and vessels from the UK to Russia (regulation 60C)

These exceptions relate to prohibitions in regulations 22 and 28 about the export of critical-industry goods or aviation and space goods, and related services to or for use in Russia.

For the removal of an aircraft, the exception applies if:
- it travels under its own power, and
- it is carrying goods or passengers, or travelling from the UK in order to undertake a return flight carrying goods or passengers, and
- its removal is not for the purpose of a transfer of ownership (including any of its component parts) or a change of operator
For the removal of a vessel, the exception applies if:
- it is removed from the UK under its own power, and
- its removal is not for the purpose of a transfer of ownership (including any of its component parts) or a change of operator
The exceptions also provide that prohibitions about the supply, delivery, making available or transfer of critical industry goods or technology or space and aviation goods or technology, or the provision of insurance and reinsurance services, are not contravened when certain activities are carried out in connection with a qualifying removal.

The exceptions also provide that the prohibition in regulation 27(1)(a) is not contravened by the provision of technical assistance to an aircraft owned, chartered or operated by a person connected with Russia, at a UK airport provided that the assistance is not for the purposes of facilitating a transfer of ownership of the aircraft or any of its component parts; or a change in the operator of the aircraft.

Exception for technical assistance to aircraft and ships when lives would be endangered (regulation 60D)

This exception relates to prohibitions in regulation 46A about technical assistance relating to aircraft or ships provided to or for the benefit of a designated person.

The exception applies if:
- a failure to provide technical assistance would endanger the lives of persons on board or the safety of an aircraft in flight or a ship at sea
Exceptions for accounting, business and management consulting and other services (regulation 60DA)

These exceptions relate to prohibitions in regulation 54C about the provision of accounting, advertising, architectural, auditing, business and management consulting, engineering, IT consultancy and design, or public relations services.

The exceptions apply if the services are:
- authorised conduct in a relevant country, such as the Channel Islands, Isle of Man, or any British overseas territory, as in regulation 62A (applies to all prohibitions in regulation 54C)
- official purposes of a diplomatic mission or consular post in Russia or of an international organisation enjoying immunities in accordance with international law (applies to all prohibitions in regulation 54C)
- the discharge or compliance with UK statutory or regulatory obligations, such obligations not arising under contract (applies only to accounting, business and management consulting, engineering and public relations services prohibitions, and a similar tailored exception applies to the auditing services prohibition)
- services provided to a Russian subsidiary of a UK credit institution (applies to auditing services prohibition only)
- provision of ensuring the continuance or resumption of civilian telecommunications services or services incident to the exchange of communications over the internet (applies to IT consultancy and design services prohibition only)
Further exceptions relating to obligations arising or concluded prior to certain regulations coming into force in 2022 and 2023 are still active, but are unlikely to to be needed in practice.

Exceptions for sectoral software and technology (regulation 60DZA)

These exceptions relate to prohibitions in chapter 4N about the making available, supply or transfer of sectoral software or technology to or for use in Russia, to a person connected with Russia, or to a place in Russia, and related services.

The exceptions apply if the software or technology are:
- in satisfaction of an obligation arising under a contract concluded before 23 April 2025 (or ancillary contracts necessary for their execution) provided that the act is carried out by 22 July 2025 and is notified to the Secretary of State by that date, or
- of a non-commercial nature, or
- for personal use, or
- where that act is to discharge, or comply with, UK statutory or regulatory obligations and the Secretary of State is notified within 12 months
Exceptions for legal advisory services for diplomatic, compliance or contractual reasons (regulation 60DB)

These exceptions relate to prohibitions in regulation 54D about the provision of legal advisory services.

The exceptions apply if the services are:
- necessary for official purposes of a diplomatic mission or consular post in Russia or of an international organisation enjoying immunities in accordance with international law- the discharge or compliance with UK statutory or regulatory obligations
- in relation to the discharge or compliance with UK statutory or regulatory obligations
- for the purpose of advising on compliance with the regulations
- for the purpose of advising on compliance with, or the consequence of compliance with any relevant law, where ‘relevant law’ includes sanctions and criminal law imposed by any jurisdiction, and any Russian law that frustrates, or is intended to frustrate, sanctions
- for the purpose of advising on the discharge of obligations under the relevant law- the potential or actual application of punitive measures
- for the purpose of advising on the potential or actual application of punitive measures
Exceptions for the export of maritime goods and maritime technology (regulation 60E)

These exceptions relate to prohibitions in chapter 2 of part 5 about the export, sale, making available, supply or transfer of maritime goods or maritime technology, and related services, to or for use in Russia, for a Russian flagged ship, to a person connected with Russia, or to a place in Russia.

The exceptions apply if the export, sale, making available, supply or transfer are for:
- non-military use and for a non-military end-user
- humanitarian assistance activity
- health emergencies
- the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment
- responding to natural disasters
Exceptions for the export of banknotes for personal use or for diplomatic missions or international organisations (regulation 60F)

These exceptions relate to prohibitions in chapter 4E of part 5 about the export, supply, delivery and making available of banknotes to or for use in Russia.

The exceptions apply if:
- the banknotes are intended for the personal use of people and their families travelling to Russia up to a value of £10,000
- the banknotes are for the official purposes of diplomatic missions, consular posts and international organisations, which does not have a limit
- a person does not know and has no reasonable cause to suspect that the banknotes were ultimately to be exported to be exported, supplied, delivered or made available to person connected with Russia or for use in Russia
Exception for emergencies in certain cases where time is short (regulation 61)

This exception relates to certain trade prohibitions about energy-related goods, infrastructure in non-government controlled Ukrainian territory, restricted goods and technology, and services relating to critical-industry goods, aviation and space goods, oil refining goods, critical-industry technology, aviation and space technology and oil refining technology, G7 and further goods and technology, Russia’s vulnerable goods and technology, sectoral software and technology, professional and legal advisory services, and maritime services relating to Russian oil.

The exception applies to acts dealing with an emergency, where satisfactory justification is provided to the Secretary of State within 5 working days.

An emergency is defined as an act assisting with the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, infrastructure or the environment.

Exceptions for importing, acquisition and supply

Exceptions for the import of personal effects, personal use, diplomatic missions etc (regulation 60A)

60A exceptions for gold and gold jewellery

One exception relates to prohibitions in chapters 4J and 4JA about the import of gold, processed gold, gold jewellery or diamond jewellery, or the acquisition of gold, gold jewellery, or the supply or delivery of gold, and related services, from Russia to a third country or to the UK.

The exception applies if the goods are:
- necessary for the official purposes of a diplomatic mission or consular post in Russia, or an international organisation enjoying immunities in accordance with international law
A second exception relates to prohibitions in chapters 4JA and 4JB about the import of gold, processed gold, gold jewellery or diamond jewellery, or the acquisition of gold, gold jewellery or diamond jewellery, or the supply or delivery of gold, and related services, from Russia to a third country or to the UK.

The exception applies if the goods are:
- non-commercial jewellery that is for personal use of and owned by the natural person importing it, or an immediate family member, travelling with them to the UK, contained in their luggage provided that the jewellery is not intended for sale
60A exception for certain revenue-generating goods

This exception relates to prohibitions in regulation 46XC about the acquisition of schedule 3DA revenue-generating goods that originated in Russia or are located in Russia.

The exception applies if the goods are:
- necessary for the official purposes of a UK diplomatic mission or consular post in Russia
Exception for certain goods consigned from Russia before sanctions were imposed (regulation 60G)

These exceptions relate to certain goods imported into the UK before either 20 May 2023 or 14 January 2024.

Exception for the acquisition of iron and steel products and metals (regulation 60GA)

This exception relates to certain prohibitions in chapter 4C, as well as in regulation 46IH(1)(a), concerning the acquisition of iron and steel products, acquisition of metals, and related services.

The exception applies where the relevant iron and steel products, or metals, are located in the United Kingdom or the Isle of Man, having been lawfully imported there.

Exception for iron and steel products and relevant processed iron or steel products and metals exported from Russia before sanctions were imposed (regulation 60GAA)

This exception relates to certain prohibitions in chapter 4CA concerning iron and steel products, certain processed iron or steel products and metals, and related services.

The exception applies if the relevant iron and steel products, processed iron and steel products, or metals:
- were exported from Russia before the applicable prohibition came into force, and
- are not to be released into free circulation in the United Kingdom or Isle of Man
Exception for acquisition of ancillary services when iron and steel products are in third countries (regulation 60GAB)

This exception relates to certain prohibitions in chapter 4C about services related to iron and steel products.

The exception applies if:
- the relevant iron and steel products were exported from Russia before the applicable prohibition came into force
Exception for acquisition of certain revenue-generating goods (regulation 60GB)

This exception relates to prohibitions in chapter 4GA about the acquisition of schedule 3DA revenue-generating goods, and related services.

The exception applies if:
- the goods are located in the UK or the Isle of Man, having been lawfully imported there
- a UK national located in Russia engages in these activities in relation to goods which are located in Russia and are for personal use of that UK national or their immediate family members
Exception for the acquisition of diamonds and diamond jewellery (regulation 60GC)

This exception relates to prohibitions in chapter 4JB about the acquisition of diamonds and diamond jewellery that originated in Russia, and related services.

The exception applies if:
- the goods are located in the United Kingdom or Isle of Man having been lawfully imported there
Exception for oil and oil products located in Russia (regulation 60H)

This exception relates to prohibitions in chapter 4I about the import and acquisition of oil and oil products located in Russia, and related services.

The exception applies if the oil or oil products:
- originated in a country that is not Russia, and
- are not owned by a person connected with Russia, and
- are only being loaded in, departing from or transiting through Russia
Exceptions for energy-related goods and energy-related technology (regulation 60I)

One exception relates to prohibitions in regulations 44 and 45 about financial or brokering services for energy-related goods and energy related technology.

A second exception relates to prohibitions in chapter 4 about the export, supply and delivery, making available and transfer of energy-related goods and technology and related activities and services.

The exception relating to regulations 44 and 45 applies if insurance or reinsurance services are:
- provided to a relevant person with regard to that person’s activities outside the energy sector in Russia
The second exception applies if a relevant activity:
- is necessary for the purposes of a UK petroleum project
Exceptions relating to non-government controlled Ukrainian territory

Exceptions for non-government controlled areas of the Donetsk and Luhansk oblasts (regulation 60ZA)

Certain time-limited exceptions relating to non-government controlled areas of the Donetsk and Luhansk oblasts, apply if they relate to an obligation arising from a contract concluded before various dates in 2022, and so are unlikely to to be needed in practice.

Exception for humanitarian assistance activity in non-government controlled areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts (regulation 61ZA)

There is an exception to certain prohibitions concerning infrastructure-related goods, and related services, in relation to non-government controlled Ukrainian territory for activities necessary to ensure the timely delivery of humanitarian assistance activity in non-government controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts.

Exception for imports from non-government-controlled Ukrainian territory where the goods originate in Ukraine (regulation 62)

This exception relates to prohibitions in regulations 47 and 52(3)(a), and chapter 2 and 2A of part 5 so far as they relate to the import of goods originating in non-government controlled Ukrainian territory, and the provision of related financial services or funds.

The exception applies if:
- the goods originate in non-government controlled Ukrainian territory and have been satisfactorily certified by or on behalf of the Government of Ukraine as originating in Ukraine.
Exceptions for transport sanctions

Exception for certain ships to enter UK ports (regulation 61A)

This exception relates to prohibitions in regulation 57A about the granting of, or causing or permitting, access to a UK port.

The exception applies if:
- the access is needed by a ship in the case of an emergency, or
- required in accordance with a movement direction
Exception for certain aircraft to make UK landings and use UK airspace (regulation 61B)

This exception relates to prohibitions in regulation 57J about the overflight and landing in the UK of certain aircraft.

The exception applies to a landing, or overflight preparatory to a landing, if:
- failing to land would endanger the lives of persons on board or the safety of the aircraft, or
- required in accordance with a movement direction
General exceptions

Exception for authorised conduct in a relevant country (regulation 62A)

This exception relates to prohibitions in regulations 11 to 15, r16, 17, 17A, 18, 18A, 18B and chapters 2 to 6 and chapter 6B of part 5 (Trade).

The exception applies if:
- conduct is authorised by a licence or other authorisation that is issued under the law of the Channel Islands, Isle of Man or any British Overseas Territory for the purpose of disapplying a prohibition in that jurisdiction which corresponds to the relevant prohibition
Exception for acts done for purposes of national security or prevention of serious crime (regulation 63)

There is an exception that can be used in relation to any prohibition or requirement imposed by the regulations. The exception applies if:
- a responsible officer has determined the relevant actions to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere