Sanctions and export control | Regulatory Outlook July 2022

Government introduces new sanctions legislation against Belarus

On 5 July, the UK Government and the Office of Financial Sanctions Implementation (OFSI) introduced new economic, trade and transport sanctions on Belarus as the Lukashenko regime continues to actively facilitate Putin’s illegal invasion. As mentioned in the government's announcement, the package extends some of the significant measures made against Russia to Belarus, including import and export bans on goods worth around £60 million.

Businesses dealing with Belarus, directly or up and down the supply chain, should be aware of the changes to avoid breaching the sanctions.

OFSI developments

OFSI updates its Russian sanctions guidance

OFSI has published additional guidance on various issues relating to the Russian Sanctions regime and updated its questions and answers section. Some of the points covered in this guidance can be found in this Insight.

OFSI issues a 'red alert' on how to spot sanctions evasion

OFSI, in conjunction with other UK authorities (including the National Crime Agency) has issued a "Red Alert" to promote awareness of various indicators of sanctions evasion. As a new strict civil liability test was recently introduced for breaches of the UK sanctions regime, it is particularly important that businesses are aware of the indicators and factor them into their due diligence. See more on this in our Insight.

OFSI imposes new reporting obligation on crypto-firms

Mainstream financial institutions, regulated by the Financial Conduct Authority (FCA), are already required to notify OFSI if they become aware of a person subject to financial sanctions (a 'designated person') or of a breach of the UK financial sanctions regime in the course of their business.  From 30 August 2022, this obligations will be expanded to include all crypto-asset exchange provides and custodian wallet providers who are registered with the FCA.