United Kingdom: Department for Business and Trade, Office of Trade Sanctions Implementation and DSIT issued guidelines on software export ban in the Russia (Sanctions) (EU Exit) Regulations 2019

On 24 April 2025, the Department for Business and Trade, Office of Trade Sanctions Implementation and Department for Science, Innovation and Technology (DSIT) issued guidance on complying with sectoral software sanctions under the Russia (Sanctions) (EU Exit) Regulations 2019. The guidance explains that the amended Regulations, particularly Chapter 4N and Schedule 3IA, prohibit UK persons, wherever located, from directly or indirectly transferring, supplying, or making available certain sectoral software and technology to persons connected with Russia or for use in Russia. This includes intangible means of transfer such as downloads, cloud access, and software-as-a-service (SaaS) platforms. The measures are designed to increase economic pressure on Russia by restricting access to key technological tools supporting critical sectors such as energy, defence, transport, and industrial production, unless a relevant exception or licence applies.