Sanctions and Export Control | UK Regulatory Outlook June 2024

UK general election 2023: sanctions aspects

As the UK approaches its general election, the two main contenders to form the next government, the Conservative and Labour parties, have unveiled their manifestos. Both parties' manifestos contain proposals to secure and repurpose frozen Russian assets to support Ukraine.

New UK sanctions against Russia

On 13 June 2024, the UK announced, in coordination with G7 partners, 50 new individual and entity designations and specifications, with the aim of impeding Russia's war effort against Ukraine.

The sanctions target suppliers of munitions, machine tools, microelectronics, and logistics to Russia's military, as well as shadow fleet vessels. In coordination with the US, entities and an individual associated with Russian financial institutions have also been designated, including the Moscow Stock Exchange.

As set out in the general election guidance, international business continues as normal during the period of the general election, which includes the imposition of sanctions. For these announcements, the opposition (Labour party) have been consulted in line with established convention. See the full list of financial sanctions relating to Russia.

UK expands Russia designation criteria

On 28 May 2024, the Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024 came into force, amending the designation criteria set out in Regulation 6 of the Russia (Sanctions) (EU Exit) Regulations 2019.

The expanded criteria permits the designation of individuals or entities:

• owning or controlling, or working as a director, trustee, manager or equivalent of a person other than an individual involved in destabilising Ukraine, undermining or threatening the territorial integrity, sovereignty or independence of Ukraine; or
• providing financial services or support, or making available economic resources, goods or technology to persons involved in obtaining a benefit from or supporting the Russian government.

OFSI guidance updates

On 12 June 2024, the Office of Financial Sanctions Implementation (OFSI) published guidance setting out its policy on licensing personal staff payments. Applicants are advised to consult the guidance before applying for a licence to allow personal staff payments. OFSI states that it will generally not license payments to personal staff of designated individuals. However, it may consider exceptions for the purposes of basic needs, routine holding and maintenance and prior obligations.

OFSI general licences

OFSI has reissued general licence INT/2024/4761108, which allows non-designated third parties to make use of retail banking services of a designated credit or financial institution for payments intended for personal use, where the total value of payments does not exceed £50,000.

The general licence takes effect on 28 May 2024 and expires on 27 May 2026.