Further Expansion of UK Sanctions Legislation with Russia - August 2022

August.02.2022

The UK Government has introduced further restrictions on trade with Russia to build on those already in place. The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 (“No.14 Amendment”) came into force on 21 July 2022. It has amended the Russia (Sanctions) (EU Exit) Regulations 2019 (the “2019 Regulations”) by restricting trade by UK persons or other persons in the UK in several areas, including the provision of certain professional and business services, and the energy sector. We set out the details below.

The prohibited activities are as follows:

  1. Professional and Business Services. Direct or indirect provision of accounting services, business and management consulting services, and public relations services, to persons connected with Russia, including to Russian residents temporarily located in another country (including the UK). Pursuant to the 2019 Regulations, an individual is regarded as “connected with” Russia if they are ordinarily resident or located in Russia, and an entity is “connected with” Russia if it is incorporated or constituted under the law or Russia or domiciled in Russia.
  2. G7 Dependency Goods. Export, supply and delivery, and making available of certain goods deemed to be of significant importance to the Russian economy and listed on the “G7 Dependency and Further Goods List” (inserted as a new Schedule 3E to the 2019 Regulations) to or for use in Russia, as well as related technical assistance, financial services and funds, and brokering services.
  3. Energy-related Goods and Services. The export of energy-related goods to Russia, regardless of their eventual point of use (which could be outside of Russia), the making available of energy-related goods to a person connected with Russia, and the provision of technical assistance, financial services and funds, and brokering services related to these activities, and the provision of energy-related services (such as drilling or well testing) to all oil and gas exploration and production projects in Russia.
  4. Oil and Oil Products. The import of oil and oil products that originate in or are consigned from Russia or the acquisition or supply and delivery of oil and oil products with the intention of those goods entering the UK (as well as related technical assistance, financial services and funds, and brokering services). This measure will take effect on 31 December 2022.
  5. Coal and Coal Products. The import of coal or coal products that originate in or are consigned from Russia or the acquisition or supply and delivery of coal and coal products with the intention of those goods entering the UK (as well as related technical assistance, financial services and funds, and brokering services). This measure will take effect on 10 August 2022.
  6. Gold. The direct or indirect import, acquisition or supply and delivery of gold that originates in Russia, and ancillary services (related technical assistance, financial services and funds, and brokering services) on gold exported from Russia. Russian-origin gold exported from Russia before 21 July 2022 is not in scope.

The No.14 Amendment also makes amendments to the 2019 Regulations to provide certain exceptions from the above measures.

In addition, the Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 (“No.13 Amendment”) came into force on 18 July 2022 and broadens the designation criteria of the 2019 Regulations, expands the scope of those “involved in obtaining a benefit from or supporting the Government of Russia”, and broadens the definition of being “associated with” a designated person to include specified immediate family members. The No.13 Amendment also introduces an exception from the prohibition on outward trade in goods and infrastructure-related services for humanitarian assistance activities in the non-government controlled areas of Ukraine (Donetsk and Luhansk).

The UK Government has updated its statutory guidance on Russian sanctions to reflect the latest amendments.