On November 4, 2022, the UK Office of Financial Sanctions Implementation issued General License INT/2022/2349952 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). The general license authorizes, under certain conditions, transactions related to Agricultural Commodities such as food, fertilizer, seed and feed, including the provision of insurance and other services. Specifically, the general license allows Relevant Exporters (transporters of Agricultural Commodities that are not persons designated under Russia Regulations (“DPs”)) or DIT License Holders to continue receiving funds or economic resources from any individual or body of persons (“Person”), including DPs, who are involved in the export, sale, production and transport of Agricultural Commodities, and continue transferring funds to Relevant Institutions, Insurance Providers, Relevant UK Nationals, DPs, and Persons in connection with these transactions. In addition, DPs may continue to transfer funds to Relevant Institutions or Insurance Providers to pay for insurance services, banking fees or other costs associated with transactions that relate to Agricultural Commodities; transfer funds to Relevant Exporters, DIT License Holders or UK Corporates in connection with export, sale or production of Agricultural Commodities; and receive funds in connection with these transactions.
Under GL INT/2022/2349952, any Person that utilizes this license must notify HM Treasury, in writing, and provide current, valid contact details within 7 days of commencing the activity. In addition, Persons who utilize this license must keep complete and accurate records related to the permitted activity for a minimum of 6 years.