May, 2022 - UK imposes further sanctions on Russia

The UK has recently imposed further sanctions on Russia, publishing the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 on 30th March, 2022, and the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 on 14th April, 2022.

A summary of the further restrictions follows below.

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 – 30th March 2022

On 30th March, 2022, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022, which introduced the following further restrictions:

• A prohibition on the provision of “technical assistance” – provided directly or indirectly – relating to an aircraft or ship to, or for the benefit of, a designated person. This provision is not contravened where (i) there was no reasonable cause to suspect that the technical assistance was provided to or for the benefit of a designated person or (ii) a failure to provide technical assistance would endanger the lives of persons on board.
• An expansion of the existing finance, shipping and trade sanctions relating to Crimea to the non-government controlled areas of Donetsk and Luhansk.

The Regulations also confer a power on the Secretary of State to designate persons by description instead of identifying them by name.

The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 – 14th April, 2022

On 14th April, 2022, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022, which provides for new trade restrictions. More particularly:

• Existing measures relating to “Restricted Goods” and “Restricted Technology” have been expanded to oil refining goods and technology, quantum computing and advanced materials goods and technology. The export, supply and delivery, making available, and transfer of such items to or for use in Russia is prohibited. This includes the provision of related technical assistance, financial services, funds and brokering services.
• A prohibition on the export, supply and delivery, making available and transfer of certain luxury products to or for use in Russia, or to a person connected with Russia.
• A prohibition on the import, acquisition, supply and delivery of certain iron and steel products originating in or consigned from Russia.

UK sanctions apply to British citizens and British overseas citizens and UK constituted and incorporated entities (even if operating outside the jurisdiction and irrespective of where their activities take place). They also apply to any persons who are within or undertake activities within the UK’s territory.

Members are reminded that the sanctions position is constantly changing, and the Sanctions List is regularly updated. As such, it is important that Members undertake thorough due diligence in respect of any contractual counterparts and commercial arrangements involving Russia.

Further information and guidance regarding the UK sanctions relating to Russia can be found on the UK government website.