Russia sanctions: guidance

Several UK government agencies, including the Office of Financial Sanctions Implementation (OFSI), have published a revised version of their Russia sanctions guidance. With this guidance, the agencies aim to support firms in their efforts to comply with diverse Russia sanction regulations, which have been issued especially since the invasion of Ukrainian territory. The guidance thereby covers issues such as:
(1) the purpose and scope of the sanction regulations;
(2) the prohibitions made by the regulations and the implications for UK firms (what do they have to look out for, which actions are disallowed);
(3) licenses under the regulations and how to obtain such license (a license must be applied for, if permission is sought to conduct an activity that would otherwise be prohibited by the regulations); and
(4) recordkeeping and reporting requirements of UK firms regarding their compliance with the regulations.
This latest revised version reflects the provisions of the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (SI 2023/713) which were published on June 29, 2023 and which primarily extended existing (professional) trade restrictions particularly relating to the provision of legal advice“. Accordingly, the revised version contains modifications throughout to further explain the legal advice prohibition and the agencies‘ interpretation of the rules in SI 2023/731. Additionally, „legal advice provisions“ have also been incorporated in the licensing section of the document. Please refer to EventID 21878 in this context for more information in this context.