The UK Department for Business & Trade (“DBT”) recently released a Notice to Exporters (“NTE”) to provide an update on Russia sanctions licensing for intra-corporate services. With regards to services provided under Regulation 54C of the Russia (Sanctions) (EU Exit ) Regulations 2019 (“the Regulations”), the government decided to remove the licensing consideration related to the provision of professional and business services from UK parent companies and their UK subsidiaries to their Russia subsidiaries. As a result, starting on October 31, 2024, the Statutory Guidance will no longer list the provision of intra-corporate services as a licensing consideration that is “likely to be consistent with the aims of the sanctions regime.”
The Notice states that, while the Secretary of State has the discretion to grant licenses without a licensing consideration, companies will be required to “explicitly demonstrate” in their license applications how the ongoing provision of the service aligns with the overarching purposes of the sanctions, as set out in Regulation 4 of the Regulations. According to the DBT, this update will not apply to license applications submitted before October 31, 2024.
Notice – NTE 2024/26: update on Russia sanctions licensing for intra-corporate services