IBA Global Insight: Russian Sanctions Under Pressure from Iran War — Shadow Fleet at 620 UK Designations; Sanctioning Russia Act Revived

The IBA Global Insight August/September 2026 issue highlights a structural tension: the Iran War has directly tested the coherence of the Russia sanctions regime. The UK Parliament Research Library briefing updated on 4 August records 3,450 designations under the UK Russia regime as of 24 July 2026, including 620 shadow-fleet vessels — the largest category of designation. New UK measures include the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026, which phase in a third-country refined-oil import ban to 1 January 2027, introduce a Russian-LNG maritime services ban, and add a uranium import ban. The UK also recorded its first seizure of a shadow-fleet tanker. On the US side: the seaborne-oil waiver (which temporarily lifted sanctions on Russian-origin oil in transit following the Strait of Hormuz closure) expired in June 2026; the Sanctioning Russia Act — previously a bipartisan proposal — has been revived by President Trump and he wants it extended to Iran. The Iran War context matters: OFAC's temporary oil waiver for Russian-origin oil (while the Strait was effectively closed) created a limited but significant precedent that US Iran and Russia sanctions can be simultaneously loosened for operational reasons — and then tightened again rapidly. For sanctions compliance teams: the UK's new "sanctions end-use controls" licensing trigger — applying across all regimes where trade sanctions extend beyond arms embargoes — introduces a new channel for catching goods diverted via non-sanctioned third countries, operating alongside existing export-control catch-all rules. This is a materially expanded compliance surface for clients with complex supply chains.