Sanctions tracker – new UK sanctions on provision of services to Russia

On 30 September, Foreign Secretary James Cleverly announced the imposition of a round of new UK sanctions against Russia. These restrictions are not yet in force.

Full details of the new measures had not been published at the time of writing, but we set out below a summary of the new restrictions as announced and will of course provide a further update when more information is available.

Provision of services

The new UK measures will restrict the provision to Russia of the following services:

• IT consultancy services. The press releases states that this will include designing IT systems and software applications;
• architectural services;
• engineering services;
• advertising services;
• transactional legal advisory services. It is said that these measures “will cover certain commercial and transactional services and hamper Russia’s businesses’ ability to operate internationally”; and
• auditing services.

It remains to be seen precisely how each of the above will be defined for the purposes of the new restrictions, and the extent to which exemptions will be available in respect of the wind-down of existing relationships.

Export restrictions

The press release states that “the export of almost 700 goods” to Russia is also being banned, including “goods that are critical for production in Russia’s manufacturing sector”. Further details about the precise goods within scope of the new restrictions were not available at the time of writing, although we anticipate that the restrictions will take the same form as other UK trade restrictions, namely restrictions on the export, sale, supply or transfer of the relevant goods to Russia, together with associated restrictions on technical assistance, brokering services, financing and financial assistance.

New asset freeze designation

Elvira Nabiullina, the Governor of the Central Bank of the Russian Federation has been added to the UK’s asset freezing list. HM Treasury have issued a notice confirming this designation.

The Foreign Commonwealth and Development Office have confirmed (in the press release mentioned above) that they do not consider Ms Nabuillina to control the Central Bank (i.e. the Central Bank does not need to also be regarded as subject to the UK asset freeze).

Management of the failure of Russian banks

The press release also notes that the UK will suspend the process by which Russian actions taken to manage the orderly failure of Russian banks are recognised under the laws of the UK, in cases where the bank is a sanctioned entity. The press release states that this will prevent those Russian actions from taking legal effect in the UK and potentially providing economic benefit to the Russian state.

Price cap on Russian oil

Finally, the press release notes that the UK continues to work with the G7 to finalise and implement the proposed price cap on Russian oil (discussed in our previous briefings here and here). It does not provide any further detail on how the UK intends to implement the price cap.