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Updates to UK Russia Sanctions Regulations: Key Changes

27 Jun 2024

Recently, the UK Government published significant updates to its sanctions regulations aimed at enhancing the effectiveness of its measures.

  1. Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024

These amendments modify the existing Russia (Sanctions) (EU Exit) Regulations 2019 under the Sanctions and Anti-Money Laundering Act 2018. These updates aim to enhance the effectiveness of existing sanctions against Russia and come into force from 28 May 2024

Key changes include:

  • Expanded Designation Criteria: New activities that can lead to a person being designated under sanctions have been added.
  • Updated Ship Specification Criteria: Additional activities that can result in a ship being specified under the sanctions are now included.

Read the full Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024, here.

  1. Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2024

Effective from 5 June 2024, these amendments update various sanctions regimes. Key changes include:

  • Director Disqualification Power: New powers to disqualify designated individuals from serving as company directors in the UK.
  • Trade Sanctions Enforcement: Clarifications on enforcement responsibilities, particularly concerning non-customs provisions.
  • Immigration Sanctions: The introduction of travel bans under the domestic counter-terrorism regime.

These changes impact several existing regulations, ensuring a consistent approach across various sanctions regimes, and apply throughout the UK, including to UK persons' conduct abroad. Some provisions also apply to activities in the UK's territorial sea.

Read the full Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2024 here.

  1. Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024

Published by the UK Foreign, Commonwealth, and Development Office and in force from 16 May 2024, these amendments update and refine the UK's sanctions regime. Key points include:

  • New Power to Disqualify Company Directors: Individuals or entities can now be designated to prevent them from acting as directors of UK companies.
  • Trade Sanctions Enforcement: HM Revenue & Customs (HMRC) will enforce trade sanctions within its customs remit, with a referral system to HMRC for non-customs related offences.
  • Belarus Sanctions Updates:
    • Designated persons must now disclose their assets.
    • Prohibitions on exporting items critical to Russian weapons systems and aerospace goods, and on importing Belarusian aluminium.
    • Restrictions on ancillary services related to prohibited goods.

Read the full Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024 here.

Along with these updates to guidance, the reporting forms for the designated person asset reporting requirements have been updated on OFSI’s page and can be found here.