Sanctions and Export Control | UK Regulatory Outlook November 2024

Changes to sanctions legislation

On 14 November 2024, the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 were laid before Parliament. The regulation makes a number of changes, including:

• expanding the definition of relevant firms subject to financial sanctions reporting obligations to cover high value dealers, art market participants, insolvency practitioners and letting agents;
• amending existing reporting requirements on relevant firms and persons to report suspected breaches of sanctions regulations;
• introducing a requirement for all UK persons holding funds or economic resources owned, held, or controlled by a designated person, to provide an annual report to the Office of Financial Sanctions Implementation (OFSI) with details of the assets; and
• introducing new civil monetary penalty powers in relation to Russia land prohibitions.

All of the changes will come into force on 5 December 2024, save for the extension of reporting obligations to high value dealers, art market participants, insolvency practitioners and letting agents, which will come into force on 14 May 2025.

The guidance on Russia financial sanctions, reporting information to OFSI, high value dealers and art market participants as well as enforcement and monetary penalties has been updated to reflect the above changes. New guidance has also been published for insolvency practitioners and letting agents. 

See the OFSI press release.

New sanctions package against Russia

On 7 November 2024, the UK announced its largest sanctions package against Russia since May 2023, targeting the country's military activity.

The package consists of 56 new designations on the UK Sanctions List. Sanctioned entities include suppliers of machine tools, microelectronics, drone components, ball bearings and other military equipment used in Russia's war against Ukraine.

As previously reported, the Foreign, Commonwealth and Development Office launched a new search function to the UK Sanctions List in September 2024.

OFSI and OFAC two-year enhanced partnership anniversary

On 19 November 2024, OFSI published a blog post celebrating the two-year anniversary of its enhanced partnership with the US's Office of Foreign Assets Control (OFAC) in global sanctions implementation.

The post reflects on the partnership's work, including joint engagement with the private sector, information-sharing initiatives and organisational modernisation efforts. The organisations reaffirmed their commitment to global security through the continued development and implementation of sanctions.

OFSI clarifies deadline for frozen assets review

On 7 November 2024, OFSI added a financial sanctions FAQ in relation to the submission date of reports to the Frozen Assets Review 2024.

FAQ 123 clarifies that the "as of" date for frozen assets reported under the review is 30 September 2024. Therefore, relevant institutions should have collected the information by 30 September in advance of the reporting submission deadline.

To support industry stakeholders, OFSI has extended the reporting submission deadline by two weeks to 25 November 2024.

OFSI general licences

OFSI has published general licence INT/2024/5394840. This allows relevant institutions to process payments made in 2022, from or through a designated credit or financial institution, provided that the original sender and recipient are not designated persons. The licence takes effect from 7 November 2024 and expires on 6 November 2025.

OFSI has extended general licence INT/2022/1710676. The extended licence allows for the continuation of business operations of the North American subsidiaries of Evraz. The licence now expires on 30 September 2025.