In March 2014, the EU imposed restrictive measures against those responsible for actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine.  The Russia (Sanctions)(EU Exit) Regulations 2019 implement the policy objectives of the pre-Brexit EU regime into English law, albeit certain of the provisions are broader in scope than under EU law.  These measures consist of asset freezes and sectoral economic sanctions.  For instance, among other restrictions, it is prohibited to:

  • import or export arms and related material to or from Russia;
  • sell, supply, transfer or export dual-use goods and technology for military use in Russia or to any designated person or entity;
  • make loans or credit with a maturity exceeding 30 days to any designated person or entity;
  • transact or deal with certain financial instruments issued by designated persons or entities;
  • export certain equipment without prior authorization, or provide technical or financial assistance, or other services, in connection with the export, sale, or transfer of such equipment to Russia, or making it available for use in Russia, or to persons connected with Russia, without prior authorization or notification; 
  • provide services for oil exploration and production (1) in Russian waters deeper than 150 meters, (2) in the offshore area north of the Arctic Circle, or (3) for projects with the potential to produce oil from shale formations through hydraulic fracturing; and
  • provide financial services in relation to military goods and military technology, dual-use goods and dual-use technology, energy-related goods and energy-related technology and infrastructure-related goods.  Unlike the EU sanctions regime, under the UK sanctions regime "financial services" include payment processing services.

Additional economic, trade and financial restrictions are in place in connection with the illegal annexation of Crimea and Sevastopol.  More information can be found here.


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