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 (most recently amended by Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2023, SI 2023/665) 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.  Additional economic, trade and financial restrictions are in place in connection with the illegal annexation of Crimea and Sevastopol, and in relation to the 2022 invasion of Ukraine.  These measures consist of asset freezes, sectoral economic sanctions, and trade 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 certain persons or entities;
  • make loans or credit with a maturity exceeding 30 days to certain persons or entities;
  • transact or deal with certain financial instruments issued by certain 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;
  • make investments in relation to non-government controlled Ukrainian territory;
  • 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; and
  • provide various services for certain sectors including but not limited to oil exploration and production, tourism, professional and business services, trust services, legal advisory services, or internet services.

More information can be found here and in the Latest Developments section of Compliance Concourse available here.


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