英国对俄罗斯能源的制裁——2026年5月20日发布两项新的OTSI/DBT一般贸易许可证

The two new OTSI/DBT general trade licences of 20 May 202621 May 2026 On 19 May 2026, the UK Department for Business and Trade (DBT), acting through the Officeof Trade Sanctions Implementation (OTSI), signed and published two general trade licences(the liquefied natural gas (LNG) Licence and the Processed Oil Products Licence, together the Both Licences operate by disapplying named regulationsrather than by creating new permissive rights. The LNGLicence disapplies the entirety of Chapter 4LA, whichprohibits the supply, delivery, financing and brokering ofmaritime transportation services for Russian LNG to thirdcountries (import of LNG into the UK remains prohibitedby other Regulations).The Processed Oil Products Licencedisapplies regulations 46Z9F (import), 46Z9G (supply),46Z9H (making available) and 46Z9I (dealing in) of Chapter4IB, which targets refined oil products processed in a thirdcountry from Russian-origin crude, in respect of diesel and jetfuel. Both Licences effectively display restrictions that werepromulgated on the same day, so the effect is suspending Both instruments entered into force on 20 May 2026. TheLicences disapply, in carefully calibrated terms, two of themost recent prohibitions inserted into the Russia Regulations:the Chapter 4LA services ban on Russian LNG and theChapter 4IB import-and-dealing ban on petroleum productsrefined in third countries from Russian-origin crude. Their The instruments These are general trade licences issued under Regulation 65of the Russia Regulations. This rule lets the secretary of stateapprove broad groups of people and actions all at once,rather than forcing everyone to apply individually. Regulation65, the trade-sanctions counterpart to regulation 64, underwhich the Office of Financial Sanctions Implementation of His The political and geopolitical backdrop The Licences emerge from a sequence of UK policy decisionsin late 2025 and early 2026 that, at regime level, installedprohibitions paralleling the EU’s 18th sanctions package, butat the licensing level depart from it. The proximate driverof the carve-outs is the supply-side pressure on refined products and LNG arising from the closure of the Strait ofHormuz to commercial traffic following the late-February2026 strikes on Iran, which materially tightened the diesel,kerosene-type jet fuel and LNG markets serving the UK.Article 3ma of Council Regulation (EU) 833/2014, inserted by The UK announced on 12 November 2025,that it wouldintroduce a maritime services ban on Russian LNG andwould legislate, separately, to close the refining loopholeon its own market. The measures were brought into forcethrough amending instruments made on the same day(20 May 2026) as the Licences are issued. Yamal LNG, theNovatek-controlled Russian Arctic project, was the principaltarget of the LNG measure: it is the largest single RussianLNG export source and depends on a fleet of ice-classcarriers many of which use UK-linked shipping, financing and In the UK’s case, the driver for suspending the applicationof these prohibitions in a new sanctions package (whichotherwise covers uranium imports, imports of variouschemical and biological components and ancillaries, aswell as construction services) arises from the stress inthe international energy markets. In the case of LNG, themotivation is the global price (the prohibition on import ofLNG into the UK remains) and reflects the role the UK enjoysin the global shipping industry, in the case of diesel and jet The issuance of the general licences has created somepolitical debate in the UK,a departure from the usual politicalconsensus on Ukraine-related policy,not least because Licence B, sanctioned processed oil Licence A, maritime transportation of The LNG Licence disapplies Chapter 4LA of the RussiaRegulations in respect of activities concerning LNG thatoriginates at the Sakhalin-2 LNG terminal or the Yamal LNGterminal. Four classes of act are authorised: first, the supply ordelivery of LNG by ship from either terminal to a destinationin a third country; secondly, the supply or delivery of LNGbetween two third-country destinations where the cargo The Processed Oil Products Licence disapplies the fourprohibitions of Chapter 4IB, regulations 46Z9F, 46Z9G, 46Z9Hand 46Z9I, only in respect of relevant processed oil products,a defined term capturing specific products that fall withincommodity code 2710 and have been processed in a thirdcountry from 2709 oil and oil products of Russian origin. TheLicence operates by reference to Combined Nomenclaturesubheadings and is narrowly drawn: the disapplication appliesonly where the products fall within 2710 19 21 (kerosene-type Two conditions govern reliance on the Licence. First, therelevant activity must fulfil a relevant contract, definedwithin the Licence as a contract with a duration of one yearor less. The condition expressly excludes long-term offtakearrangements, which must be supported by specific licencesif at all. Secon