Sanctions and Export Control | UK Regulatory Outlook January 2023

Russian sanctions regime

We anticipate that 2023 will bring an increase in further sanctions imposed on Russia in response to the ongoing war in Ukraine. The Office of Financial Sanctions Implementation (OFSI) is expanding its operations and it is expected that it will have 100 staff by April 2023 (an increase from 45 at the start of 2022). Our view is that this increase will lead to a greater pace in enforcement actions and we will start to see fines imposed for breaches of the Russian sanctions that were implemented in 2022.

The Russian sanctions regime is likely to dominate OFSI's work in the coming year, although other sanctions regimes (for example, Iran) will also continue to be supported. See the full UK sanctions list. 

Russian oil price cap update

As previously reported, the UK implemented the price cap on Russian crude oil on 5 December 2022, in line with other members of the G7, the EU, Australia and the US.

The General Licence sets the price cap at $60 per barrel, and is accompanied by an attestation process, as well as reporting and record-keeping requirements for persons supplying or delivering Russian oil or oil products.

The equivalent restrictions and exception for refined oil products will come into force from 5 February 2023 and further guidance can be found on the OFSI website.

UK government updates Russia sanctions statutory guidance

On 5 January 2023, the government updated its Russia sanctions guidance to clarify the application of prohibitions on the provisions of technical assistance relating to aviation and space goods, and technology or critical-industry goods and technology.