Sanctions tracker – new UK trade sanctions

This briefing summarises the new Russia sanctions measures introduced by the UK on 23 June 2022 and provides a round-up of other key UK and EU developments since our last sanctions tracker post.

UK

Amendments to existing Russia sanctions legislation

On 23 June, the Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 (the "Amending Regulations") were published, coming into force on the same day. The Amending Regulations make various amendments to the UK's principal Russia sanctions legislation: the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"), as summarised below.

• The Amending Regulations introduce a prohibition on the export of maritime goods and technology for the placing on board of a Russian-flagged vessel, along with restrictions on the supply, transfer or making available of such equipment for the same purpose. The relevant goods are defined by reference to Annex 1 of the Merchant Shipping Notice 1874.
• The Amending Regulations also introduce further restrictions on dealings with "non-government controlled Ukrainian territory" (the "Territory" i.e. Crimea, Donetsk and Luhansk). It is prohibited to export, supply, deliver, make available or transfer military goods to the Territory. The Amending Regulations also include restrictions regarding related technical assistance, brokering and financial services.
• Amendments have also been made to the existing restrictions on iron and steel products. The Regulations already prohibit the import or purchase of Russian iron and steel products, but the Amending Regulations introduce restrictions on related technical assistance, brokering and financial services.
• The Amending Regulations introduce a new prohibition on the provision of "interception and monitoring services" to or for the benefit of the Government of Russia. This covers "any service that has as its object or effect the interception of a communication in the course of its transmission by means of a telecommunication system", with a more detailed definition included in new Regulation 21A of the Russia Regulations.
• The Amending Regulations prohibit the export of banknotes denominated in sterling or any official currency of the EU ("Banknotes") to Russia, the supply delivery or making available of Banknotes to a person connected with Russia, and the making available of Banknotes for use in Russia.
• New trade restrictions have been introduced in relation to the supply to Russia of jet fuel and fuel additives (as listed in Part 8 of Schedule 2A to the Russia Regulations), along with related restrictions on technical assistance, brokering and financial services.
• Restrictions have also been introduced in relation to the import, acquisition, supply or delivery of "revenue generating goods" from Russia, again along with related restrictions on technical assistance, brokering and financial services. These goods are listed in Schedule 3D to the Russia Regulations and comprise a broad range of products, including seafood, various chemicals, wood and paper products, and ships.
• The Amending Regulations also extend the existing Russia-related trade sanctions contained in Chapter 2 of Part 5 of the Russia Regulations to the Territory. These include restrictions relating to dual-use goods, aviation and space goods, and oil refining goods.
• The definition of "restricted goods" has also been expanded to include "defence and security goods"; this includes interception and monitoring goods, internal repression goods (including firearms, explosives, body armour etc.), and goods relating to chemical and biological weapons.
• Certain specific exemptions have been introduced in relation to the new maritime goods, Banknotes and revenue generating goods restrictions, as set out in Regulation 10 of the Amending Regulations. The statutory guidance on Russia (which summarises which exceptions and licensing grounds apply to different types of goods) has been updated in respect of the Amending Regulations.

The Department for International Trade ("DIT") has published a new Notice to Importers and Notice to Exporters in relation to these developments. DIT also published guidance on trading under sanctions with Russia on 8 June although, at the time of writing, this had not been updated in respect of the Amending Regulations.

Additional designations

On 16 June, the Office of Financial Sanctions Implementation announced the designation of 12 further individuals. The corresponding press release announces that the designations relate to those involved in the forced transfer and adoption of children in Ukraine and also include other public figures supporting the war in Ukraine, and those involved in military and transport activities.

Guidance on designation data

The Foreign, Commonwealth & Development Office has published information on designation data, explaining how the UK government collects data on designations and what it means. This includes an explanation of the methodology for estimating oligarchs' net worth, identification of oligarchs' family members, and the identification/estimation of data about the subsidiaries of designated companies.

EU

EU FAQs

The EU has continued to update its FAQ page relating to the Russian sanctions, including through the addition new FAQ documents on the execution of prior contracts, the import and purchase of goods, trade in agricultural products from Russia and Ukraine, and energy financing.

The Commission has also published a consolidated version of its FAQs.