Since Russia’s invasion of Ukraine, the United Kingdom has implemented further sanctions against Russia which infringe and prohibit Russia’s dealings with the United Kingdom. The sanctions have been continually evolving. They restrict Russia’s access to:
- IT Consultancy services;
- Architectural services;
- Engineering services;
- Advertising services;
- Transactional legal advisory services; and
- Auditing services.
The Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) were made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act) (“the Regulations”). The Regulations impose various financial sanctions including the freezing of funds and restrictions on individuals and commercial corporations who have been specified by way of their involvement in Ukraine or from benefiting from supporting the Government of Russia.
Companies and individuals must therefore check against the list for any dealings that it may have with those listed and take steps to freeze or cease any dealings. Failure to do so is a criminal offence.
The UK Sanctions List can be found here:
https://www.gov.uk/government/publications/the-uk-sanctions-list
Recent Updates
More recently, in March 2023, the Russia sanctions regulations have recently been amended by the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (S.I. 2022/1331). In summary, the latest amendments:
- Imposed a new restriction in relation to the provision of trust services to designated persons or persons connected with Russia (and associated reporting requirements);
- Extended financial and investment restrictions;
- Added additional services to the existing provisions imposing restrictions relating to professional and business services and added further items to the lists of goods subject to trade prohibitions; and
- Provided for exceptions and licences relating to the new restrictions introduced by the amendments.
On 12 April 2023, the Foreign, Commonwealth and Development Office updated the UK Sanctions List on GOV.UK which lists an additional 14 entries. The additional 14 entries are now subject to an asset freeze.
The additional and extended sanctions therefore make it clear that the United Kingdom has an ongoing commitment in relation to sanctions and is continually responding to the situation in the Ukraine and continues to send a clear message to Russia. We fully expect the sanctions to continue against Russia and to develop further.
Companies and individuals need to be continually aware of updates to the sanctions list and check against the same.
How we can help
If you provide any of the services set out above to an individual or company in Russia and require advice on whether sanctions will apply, please contact Anil Rajani at anil.rajani@rosenblatt.co.uk.
Authors
Anil Rajani, Partner, Dispute Resolution
Madeleine Binkley, Associate, Dispute Resolution
Disclaimer: We at Rosenblatt (and our parent company RBG Holdings plc) support and encourage free/independent thinking in relation to issues which are sometimes considered to be controversial subject matters. However, the views and opinions of the authors do not necessarily reflect the opinions, views,
