UK Strengthens Sanctions on Russia: New Measures Target Key Technological Goods and Revenue Generating Imports

1 minute read | May.15.2023

Last month, the UK introduced new sanctions against Russia by way of the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 SI 2023 No. 440 (the “2023 Amendment”), which amends the Russia (Sanctions) (EU Exit) Regulations 2019.  As the Foreign Secretary had announced on 24 February 2023, and in line with the US and EU sanctions regimes, the 2023 Amendment expands existing export bans to prohibit the export, delivery, supply and/or making available of key technological goods which Russia has used on the battlefield against Ukraine.  This includes: (i) critical-industry goods and technology; (ii) defence and security goods and technology; and (iii) quantum computing and advanced materials goods and technology. 

In addition, the 2023 Amendment amends the prohibitions relating to the import and acquisition of revenue generating goods from Russia, including by addition of a new category of “Schedule 3DA revenue generating goods”, which includes caviar, different types of wood, tyres, and silver.  The sanctions prohibit the direct or indirect provision of ancillary services in relation to the import of such goods, namely: (i) supply and delivery; (ii) technical assistance; (iii) financial services; and (iv) brokering services.  The direct or indirect supply and delivery of Schedule 3DA revenue generating goods from Russia to third countries is also prohibited. These prohibitions target Russia's ability to raise money to fund its war effort.

From 30 September 2023, the import to the UK of iron and steel products which originated in Russia but have been processed in a third country will be prohibited.  From that date, no person can directly or indirectly provide technical assistance, financial services and funds, and/or brokering services relating to processed iron and steel products which originated in Russia.  This prohibition seeks to curb Russia’s revenue from iron and steel exports to third countries.