The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023

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. 4) Regulations 2023 amend the existing Russia sanction regulations, the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855), primarily to extend existing trade restrictions, enhance sanction-related reporting obligations, prohibit the processing of certain payments, and grants powers to the Treasury for granting additional licenses.
#### In detail, the key provisions of the new sanction regulations include the following:
(1) Trade restrictions: The new regulations extend the existing trade restrictions with respect to certain goods that could be used for military or industrial purposes in Russia. Specifically, they prohibit the export, supply, and provisions of items like chemicals, electrical goods, metals, certain vehicles, and machine parts. These restriction also apply to ancillary services such as payments, financing, or brokerage. Furthermore, the existing restrictions on the provision of luxury goods to Russia are also extended to include technical services, the provision of financial services, and the brokering of such goods. Finally, the regulations further restrict the import of certain goods from Russia, particularly metals, including such import via third countries, if the origin is the Russian Federation.
(2) Payment services restrictions: The new regulations broaden the scope of the existing regulation 17A(2) of the 2019 sanctions regulations dealing with correspondent accounts, which presently prohibits UK credit and financial institutions to process sterling payments involving designated credit or financial institutions or those owned or controlled by them. Specifically, the new regulations prohibit the processing of payments in any currency, not just Sterling.
(3) Enhanced reporting obligations: The new regulations impose additional reporting obligations on those that are designated and on (legal) persons holding funds (on behalf) of designated parties. Specifically, individuals that have been subjected to an asset freeze must reveal the value and details of any funds or economic resources they possess in the UK or as UK persons. These assets must be disclosed within 10 weeks of these regulations taking effect or from the date of designation, whichever is later. Additionally, any new assets acquired or disposed of during this period must be reported promptly to the Treasury.
(Legal) persons providing asset management or foreign exchange services that hold funds (on behalf) of designated parties must report to the Treasury by October 31 of each calendar year the „nature and amount or quantity of those funds or economic resources“ held by these firms as per September 30 of each year. An initial report must be provided as soon „practicable“.
(4) Additional licenses: The Treasury is granted the power to provide licenses to UK firms and persons for purposes of divesting existing engagements with newly designated entities. This includes divesting from financial securities positions as well as other holdings of Russian interests. Licenses may also be granted for parties involved in the facilitation of such divestments.
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The above summary only presents the key provisions outlined in the new regulations. Please ensure to carefully review the original legal document for comprehensive detailed information.