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. 4) Regulations 2023 (SI 2023/1364) (EventID 24219) and the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023 (SI 2023/1367) (EventID 24220) which were published December 14, 2023 and which primarily extended existing trade restrictions, enhanced sanction-related reporting obligations, prohibited the processing of certain payments, and granted powers to the Treasury for granting additional licenses. Accordingly, the revised version contains modifications throughout, but particularly to
– section 1.3 as regards Financial Sanctions to stipulate the restrictions in relation to the processing of payments in currencies other than Sterling;
– section 1.4 and 2.2 as regards Trade Sanctions to reference the new prohibitions (gold products, diamonds, electrical goods, metals, certain vehicles, and machine parts);
– section 1.7 as regards Information and record keeping to include the new annual and ad hoc reporting requirements of entities providing asset management or foreign exchange services that hold funds (on behalf) of designated parties; and
– section 3.2 as regards Licensing for financial sanctions to include new grounds for issuing a license, namely the divestment of current (financial) engagements or the provision of financial support or technical assistance in relation to „G7 dependency and further goods“.
Please also note the revised Department for Business and Trade (DBT) contact details which read as follows:
– email: exportcontrol.help@businessandtrade.gov.uk or tradesanctions@businessandtrade.gov.uk
– helpline: +44 (0)20 7215 4594
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As the above mentioned modifications are only the key changes made to the document, please refer to the original guidance for more detailed, comprehensive information.