Russia Sanctions Amendment Regulations (No. 3) Part 2 Enter Force — September 3

Part 2 of the Russia Sanctions Amendment Regulations (No. 3) 2026 came into force today, September 3, 2026, making substantive amendments to the UK's principal Russia sanctions regulations. The amendments arrive as the UK simultaneously doubles OFSI's maximum penalty ceiling and the EU prepares its largest-ever designations package. Switzerland completed implementation of the EU's 20th Russia sanctions package on August 19, with its extension of managed security services to the software ban taking effect September 21. Belgium's law transposing the EU's sanctions criminalization directive (Directive (EU) 2024/1226) came into force on September 1, harmonizing criminal penalties for deliberate sanctions violations across the EU. The convergence of simultaneous national implementation timelines across UK, EU member states, and Switzerland creates a narrow window in which firms must validate that their Russia sanctions compliance programs reflect all current obligations — not only designations but the expanded sectoral, software, and crypto-platform bans.