Sanctions and Export Control | UK Regulatory Outlook June 2023

UK brings in further Russian sanctions legislation

The UK has passed further legislation which introduces a provision that certain Russian sanctions will be maintained until compensation has been paid to Ukraine.

OFSI publishes updated Oil Price Cap guidance and issues new General Licence

On 14 June 2023, the Office of Financial Sanctions Implementation (OFSI) published updated guidance for the maritime services ban and oil price cap in order to provide further clarity on the wind-down period, derivatives and futures trading and the meaning "as soon as reasonably practicable".

In addition, OFSI has also issued General Licence INT/2023/3074680 which permits trading in derivatives and futures related to the supply or delivery by ship of Russian oil and oil products which would otherwise be in breach of the Russia regulations.

The general licence takes effect from 14 June and is of indefinite duration.

UK publishes Russia common high priority items list

On 30 May 2023, the Foreign Office published the common high priority items list, which is composed of sanctioned items which have been identified as being critical to Russian weapons systems and development.

The list also includes items that are essential for the manufacturing and testing of electronic components and circuits retrieved from the battlefield. The Foreign Office warned business to undertake due diligence to ensure that the end destination of the listed products is not Russia.

It is important to note that the list will be continually updated when required.

HM Treasury updates requests for sanctions review and revocation guidance

On 25 May 2023, HM Treasury updated its guidance on how to request variation or revocation of a financial sanction designation under The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019.

Designated persons are advised to submit a sanctions review request form, along with evidence supporting the request explaining why the designation should be varied or revoked.

New guidance on trade sanctions circumvention

On 22 May 2023, the Department for Business and Trade and Export Control Joint Unit published a joint notice to exporters to ensure compliance with the Russia sanctions.

The notice aims to prevent the undermining of trade sanctions, export controls, as well as other restrictive measures implemented in response to Russia's invasion of Ukraine.

OFSI issues new General Licence on prior obligations

OFSI has issued General Licence INT/2023/3024200, which will allow a UK person to receive payment where they are owed funds or economic resources by a designated person (DP) under a contract that was signed before the designation was made.

The General Licence takes effect from 22 May 2022 and will expire at 23:59 on 21 November 2023.

OFSI has issued a blog post explaining the General Licence in more detail.

UK to announce upcoming Russia sanctions following G7

Following the G7 Summit on 18 May 2023, the UK prime minister has announced upcoming sanctions on Russian diamonds, metals and military-industrial complex.

The government will legislate later this year to ban the import of Russian diamonds, as well as all imports of Russian-origin copper, aluminium, and nickel. The UK currently has bans on Russian iron and steel.