The United Kingdom recently published updated Russia sanctions guidance in order to incorporate the amendments made to the Trade License for acquisition of metals, on April 12, 2024, concerning Russian metals. On April 12, 2024, the United Kingdom joined the United States to implement new policies regarding the import and acquisition of Russian-origin metals (particularly aluminum, copper and nickel in the United States) that were produced after April 12, 2024. The new policies essentially block Russia’s ability to profit from the London Metal Exchange and the Chicago Mercantile Exchange, the two largest metal exchanges in the world.
The import and acquisition of all Russian metals have been banned in the United Kingdom since December 2023. However, the Russian sanctions guidance was updated to include 1) a prohibition on a UK Persons’ ability to acquire, via a global metal exchange, a warrant related to Russian metal produced after April 12, 2024 and 2) permission for UK Persons to take physical delivery, outside of the UK, of Russian metals that were under warrant on a global metal exchange before April 12, 2024.