Sanctions tracker: recent UK sanctions developments

Iranian transfer of ballistic missiles to Russia

The UK (in coordination with allies) has announced a range of measures in response to the Iranian regime's transfer of ballistic missiles to Russia.

From a sanctions perspective, the measures include:

• the designation of certain individuals and entities said to be involved in facilitating Iran's military support to Russia (designated under the UK's Iran regime – see the notice from HM Treasury here;
• the designation of Russian military organisations (under the UK's Russia regime – see the HM Treasury notice here; and
• the "specification" of five vessels for their role in transporting military supplies from Iran to Russia. Specified ships are subject to restrictions including being barred from access to UK ports.

The UK government has also introduced the Iran (Sanctions) (Amendment) Regulations 2024 (amending the Iran (Sanctions) Regulations 2023). The amendments seek to strengthen trade sanctions against Iran, targeting items that are used in the production of ballistic missiles, UAVs and other weaponry. The terms "unmanned aerial vehicle goods" and "unmanned aerial vehicle technology" have been replaced with the broader terms of "goods of strategic concern" and "technology of strategic concern". As a result, Schedule 4 now specifies an expanded list of items that will be subject to sanctions, including parts used in cameras, phones, planes and helicopters. However, a new exception has also been introduced that provides that the amended regulations will not apply to goods of strategic concern or technology of strategic concern where they are:

• the personal effects of a person travelling to Iran;
• of a non-commercial nature for the personal use of a person travelling to Iran and contained in that person's luggage; or
• necessary for the official purposes of a diplomatic mission or consular post in Iran, or of an international organisation enjoying immunities in accordance with international law.

In a joint statement, the Foreign Ministers of the UK, France and Germany also stated that they would "work towards" imposing sanctions on Iran Air.

UK ship specifications

On 11 September, the UK announced that a further ten vessels have been "specified" under the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The specified vessels are said to operate as part of Russia's "shadow fleet" and to be involved in the transportation of Russian oil. 

Financial sanctions FAQs

The Office of Financial Sanctions Implementation ("OFSI") has published an additional 20 FAQs relating to the Russia Regulations.

The new FAQs are numbers 100 to 119 and cover various aspects of the Russia Regulations, including the capital markets restrictions imposed by Regulation 16, the lending restrictions imposed by Regulation 17 and the reporting obligations under Regulation 70A.

Office of Trade Sanctions Implementation ("OTSI")

Regular readers of the blog will be aware that the government had previously announced the creation of "OTSI" to act as a trade sanctions counterpart to OFSI (for further background, please see our previous post).

On 12 September, new legislation (the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024) was published, granting the power to impose civil sanctions for breach of trade, aircraft or shipping sanctions.

OTSI's webpage was updated on the same day to add various guidance notes and with confirmation that the UK government plans to launch OTSI in October 2024.

We will publish a further update in due course with more information on the newly published guidance and OTSI's enforcement powers.