Easing or tightening of Russia sanctions… or both?
The unprecedented level of coordination among the U.S., the EU, the UK and other allies in the design and implementation of sanctions and export controls targeting Russia since 2022 could be coming to an end, with the U.S. reportedly considering easing sanctions while other jurisdictions for now remain silent.
According to recent media reports, President Donald Trump has ordered the U.S. Departments of State and Treasury to draft a list of Russia sanctions that could be “eased,” including a proposal to remove sanctions from certain targeted entities and individuals, including some Russian oligarchs. It is not yet clear which measures will be eased or which sanctions lifted.
The EU and the UK have not (yet) expressed any intention to ease sanctions targeting Russia and may even be considering new sanctions in the near future. In fact, only recently, on February 24, 2025, both the EU and UK further tightened their sanctions targeting Russia. The EU, with its 16th sanctions package targeting Russia, imposed additional sanctions targeting Russia’s trade, maritime, infrastructure, and financial services sectors and companies outside Russia (e.g., in China, Türkiye, United Arab Emirates) considered to be responsible for sanctions circumvention or evasion. Since then, the EU has reportedly been working on a 17th sanctions package. Similarly, the UK recently designated persons, including entities in India, Kazakhstan, Kyrgyzstan, Thailand, Turkey, and Uzbekistan, and imposed shipping sanctions on an additional 40 vessels within Russia’s shadow fleet.
So will easing of U.S. sanctions targeting Russia ease business and sanctions compliance?
The complexity of de-escalation scenarios and differences in approach and pace will likely limit the concrete effects of the easing of U.S. sanctions for companies with global operations. Even if the United States meaningfully eases sanctions targeting Russia, the impact of EU/UK sanctions may continue to restrict business opportunities for global businesses required to comply with EU/UK sanctions, for example because the transaction is handled by an EU/UK entity, involves EU/UK persons, products are shipped via the EU/UK, or payments are processed by EU/UK banks.
Particularly emblematic is the SWIFT ban, which has resulted in the exclusion of a number of Russian banks from the global financial messaging network. Russian banks subject to the SWIFT ban are de facto cut off from the global financial messaging network and unable to transact internationally. Because SWIFT is based in Belgium and as such subject to the jurisdiction of the EU, SWIFT itself must comply with EU sanctions at all times. Thus, even if the United States eases sanctions targeting Russian banks, the Russian banks would still not be able to use the SWIFT network unless the EU eases the SWIFT restrictions.
Companies will need to be particularly vigilant not to engage in prohibited circumvention or to facilitate circumvention or sanctions avoidance when taking steps to benefit from the U.S. easing of sanctions. Further, companies will need to carefully consider contractual sanctions compliance commitments and internal policies when reassessing potential business operations stemming from a potential easing of sanctions.
Is the end of the sanctions targeting Russia in sight?
As companies plan for potential opportunities, it is important to also plan for a re-escalation of sanctions. The easing of sanctions is being considered in the context of U.S. — Russian negotiations regarding the war in Ukraine. Even if some sanctions were eased as a result of these negotiations, geopolitical events may change quickly and sanctions reimposed.
In the context of sanctions easing, governments typically include “snap back” mechanisms allowing for an almost automatic reimposition of sanctions if the situation deteriorates again. The 2015 Iran nuclear deal (the Joint Comprehensive Plan of Action, or JCPOA) contained a “snap back” mechanism allowing JCPOA participants to seek the reimposition of the multilateral sanctions against Iran, which were lifted at the time. More recently, the EU also included a “snap back” mechanism in the temporary sanctions relief granted to Syria in February 2025.
At any point of re-engagement in Russia, companies should therefore make sure that they have adequate contractual protections with their customers, suppliers, and the like in case of sanctions “snap back.”
