The UK recently issued a General Trade License under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Regulations”) to enable the provision of legal advisory services concerning Russia. The license, which was granted by the Secretary of State on August 11, 2023, authorizes the provision of legal advisory services, which would otherwise be prohibited by Regulation 54D (Legal Advisory Services) of the Regulations, that could trigger restrictive measures, including Russian sanctions and export/import controls, compliance with such measures or the discharge of or compliance with UK statutory or regulatory obligations.
The use of the license is conditioned upon meeting several requirements. The Provider must share with the Secretary of State the name and address of where transaction records are kept within 30 calendar days of the first use of the license. The license specifies that the location of the transaction records should be shared with the Secretary of State via SPIRE (https://www.spire.trade.gov.uk/spire/fox/espire/LOGIN/login). The Provider must also abide by the provisions in Regulation 76 (General Trade Licenses: records) of the Regulations and, in accordance with applicable legislation, keep relevant records for a period of 4 years beyond the end of the calendar year in which the record was created. Furthermore, the Provider must permit these records to be copied and inspected by an authorized representative of the Secretary of State or the Commissioners. Failure to comply with these conditions may cause the Provider’s use of the license to be revoked or suspended.