On December 6, 2023, the UK government announced 46 new sanctions targeting individuals and entities that supply and fund Putin’s war machine and circumvent UK sanctions. The new designees include entities based in several regions, including Belarus, China, Serbia, Turkey, the United Arab Emirates and Uzbekistan, bringing the number of third-country entities sanctioned by the UK for supporting Russia’s war efforts to more than 30. The UK government reported that its new sanctions package was issued just as G7 leaders were set to discuss additional measures that, among other things, would further diminish Russia’s access to revenue needed to fund its unjustified war.
A majority of the designations were issued in accordance with the Russia (Sanctions) (EU Exit Regulations 2019; however, JSC Display Design Bureau, an entity that operates in Belarus’s defense and information, communications and digital technologies sectors, was designated pursuant to Belarus (Sanctions) (EU Exit) Regulations 2019. Thirty-one of the designees are linked to the design and manufacture of drones, missile parts and the import of electronic components, including the companies’ directors and their immediate family members. The designations also include three supporters of the Wagner Group network and four entities that operate “shadow fleet“ vessels used by Russia to evade oil-related sanctions imposed by the UK and G7 partners.
The UK National Crime Agency concurrently issued an advisory to warn UK financial institutions and other members of the regulated sector of Russia’s continued attempts to circumvent sanctions and procure sanctioned goods and services through intermediary countries. The advisory, which was aimed at UK’s regulated sector, is also relevant for businesses outside of the regulated sector as it provides several key red flags that will help identify transactions and customers that might be engaged in sanctions evasion efforts. The UK also urged the industry to report all suspicious activity and any potential sanctions breaches discussed in the guidance.