In view of the continuing aggression of Russia towards Ukraine, new sanction regulations relating to Russia and Russian activities were published on legislation.gov.uk, the official UK platform for publicizing legal documents. Specifically, the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 amend the existing Russia sanction regulations, the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855), primarily to extend existing professional (trade) restrictions and set out corresponding provisions.
In detail, the instrument
– prohibits the provision of legal advisory services by UK (legal) persons and (legal) persons located in UK related to activities that are prohibited under the UK sanctions regime. This aims to prevent UK legal services providers from supporting commercial activities that advance the (illegal) interests of Russia, so the accompanying explanatory memorandum;
– permits the provision of expert evidence in legal proceedings and the provision of legal advice related to compliance with the sanctions regime itself.
– permits the provision of auditing services by UK (legal) persons so long as these services are needed to fulfill regulatory requirements (e.g. to prepare regular shareholder reports).
– modifies provisions relating to WHEN the HM Revenue and Customs (HMRC) may conduct investigations as regards certain sanction violations.
– makes consequential adjustments (e.g. to include the new prohibitions within the penalty and enforcement sections of the 2019 regulations).