Sanctions tracker – recent UK sanctions developments

In this post, we bring you a round-up of UK sanctions news, including (in particular) some significant new designations.

New UK designations

On 13 June, the UK announced an expansion of its sanctions against Russia, comprising 50 additional designations and "specifications" of ships (a specified ship is prohibited from entering UK parts and is subject to certain other restrictions).

The targets of these new measures include the following:

• entities operating in or supporting the Russian liquified natural gas sector;
• an insurer;
• a ship manager;
• entities involved in the Russian civil nuclear sector;
• suppliers of munitions, machine tools, microelectronics, logistics or other supplies to the Russian military; and
• entities and an individual connected to Russia's financial system.

Of particular relevance are some of the designations in this final category, which include the Moscow Exchange and the National Settlement Depository (the "NSD"). Companies which continue to hold Russian shares via the NSD should carefully consider the impact of this designation.

A full list of the new UK designations can be found in the relevant HM Treasury notice. See also here for the details of two entities linked to the Wagner Group which were designated under the UK's Central African Republic sanctions regime. 

The UK's measures were made in consultation with other G7 members. For more detail on the US sanctions announced at the same time, please see our separate blogpost.

Shortly before this announcement, the UK published the Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024 (amending the Russia Sanctions (EU Exit) Regulations 2019), which expand the available designation criteria applicable to the Russia regime. In particular, persons may now be designated for: (i) providing financial services or making available funds, economic resources, goods or technology to persons involved in obtaining a benefit from or supporting the Government of Russia; or (ii) owning or controlling, directly or indirectly, or working as a director, trustee, other manager or equivalent of an entity involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.

Licensing guidance

The Office of Financial Sanctions Implementation ("OFSI") has published new licensing guidance setting out its policy on the licensing of payments for the personal staff of designated individuals (e.g. chefs, cleaners, drivers etc.).

The guidance confirms that OFSI will not generally license such payments but will consider exceptions to this position if there are specific attenuating circumstances. Exceptions may be made under the following licensing grounds: (i) basic needs, (ii) routine holding and maintenance, and/or (iii) prior obligations, and the guidance sets out further information on when OFSI may consider granting a licence under each ground.

Guidance on sale of oil tankers to third countries

The Export Control Joint Unit within the Department for Business and Trade has published guidance on the sale of oil tankers to third countries. It is aimed at those involved in the sale and brokering of second-hand vessels and seeks to provide further information and tools to counter current and emerging trends related to Russian sanctions evasion.

The guidance sets out the identified circumvention risk arising from Russia's effort to procure restricted goods and services via indirect routes and complex supply chains. This includes the purchase of second-hand tankers which can be used to service the export of Russian oil. The guidance provides examples of appropriate due diligence on potential buyers in these types of transactions, and key risk indicators of which market participants should be aware.