What’s this about?
The UK has continued to impose sanctions on Russian individuals and entities under the UK sanctions regime with regard to the war in Ukraine; for more about how the UK sanctions regime works see the What is the UK sanctions regime? section of our article here https://www.corderycompliance.com/add65uksanctions/.
This article looks in brief at the latest developments.
What are the most recent additional UK sanctions concerning Russia?
The situation concerning Russia sanctions continues apace. The most recent sanctions are as follows.
New trade sanctions have been introduced which restrict the trade of the following:
- Maritime goods and maritime technology for the placing on board of a Russian-flagged vessel;
- Restricted military goods and restricted technology to, or for use in, non-government controlled Ukrainian territory, including the supply, delivery, making available, transfer, provision of technical assistance, financial services or brokering services in relation to such goods;
- Defence and security goods and technology;
- Interception and monitoring services for the benefit of the Government of Russia (any service that has as its object or effect the interception of a communication in the course of its transmission by means of a telecommunication system), including the supply and delivery of such goods;
- Banknotes to, or for use in, Russia including the supply or delivery, or making available such items;
- Jet fuel and fuel additives to for the use in Russia including the supply, delivery, making available, provision of technical assistance, financial services or brokering services in relation to such goods; and,
- Goods which generate significant revenues for Russia including the importing, acquiring, supply, delivery, provision of technical assistance, financial services or brokering services in relation to such goods, covering a wide range of goods from caviar to Portland cement to wood to certain fertilisers and a range of chemicals.
In addition, the following six individuals in the Russian media industry have been added to the UK list (who are now subject to an asset freeze) along with an online news site:
- Aleyona Anatolyevna Chuguleva;
- Darya Aleksandrovna Dugina;
- Yuriy Sergeyevich Fedin;
- Yevgeniy Eduardovich Glotov;
- Aelita Leonidovna Mamakova;
- Mikhail Anatolyevich Sinelin; and,
- United World International, an online news site.
Takeaways
With regard to sanctions in general, organisations should consider doing the following:
- Undertaking a rigorous due diligence screening against individuals and entities on sanctions lists;
- Checking whether any accounts are maintained or any funds or economic resources are held for sanctioned persons and entities;
- Freezing sanctioned accounts, and other funds or economic resources and any funds which are owned or controlled by sanctioned persons and entities, and refraining from dealing with the funds or assets or making them available (directly or indirectly) to sanctioned persons (unless licenses have been granted);
- Reporting any findings to the regulator and co-operating with any investigations that the regulator may undertake;
- Doing a contracts clauses check on relevant contracts to ensure that provisions concerning warranties, force majeure, termination, and, liability are all up to scratch as regards sanctions;
- Updating policies, procedures and risk assessments – be prepared to deal with sanctions breaches;
- Where possible and of use (either as an alternative or a complement to contract breach risk), considering obtaining insurance (export credit, political risk, and, trade disruption) against sanctions risks; and,
- Training staff on sanctions issues.
Resources
We report about sanctions issues here: https://www.corderycompliance.com/news/.
We spoke at an event about Russian sanctions, where we focused on sanctions policies & due diligence/screening issues: https://www.corderycompliance.com/rbcc-dit-russia-uk-02-dec/.
We have also written about the UK Economic Crime (Transparency & Enforcement) Act 2022 here https://www.corderycompliance.com/uk-ecte-act-sanctions-russia-belarus/.
For UK official guidance about the UK sanctions on Russian see here https://www.gov.uk/government/collections/uk-sanctions-on-russia and the UK sanctions list can be found here https://www.gov.uk/government/publications/the-uk-sanctions-list.
The UK Sanctions and Anti-Money Laundering Act 2018 can be found here https://www.legislation.gov.uk/ukpga/2018/13/contents/enacted.
For more information please contact André Bywater or Jonathan Armstrong who are lawyers with Cordery in London where their focus is on compliance issues.
| Jonathan Armstrong, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH | André Bywater, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH | |
| Office: +44 (0)207 075 1784 | Office: +44 (0)207 075 1785 | |
| Jonathan.armstrong@corderycompliance.com | Andre.bywater@corderycompliance.com | |
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