In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.
1. RUSSIA SANCTIONS
- UK Government corrects two entries on the UK sanctions list under the Russia regime: On June 14, 2024, the UK Government corrected the entries for Central Counterparty National Clearing Centre and LLC Kompaniya AMG under the Russia sanctions regime. Both parties remain subject to an asset freeze and trust services sanctions. (https://assets.publishing.service.gov.uk/media/666c1d99cd41e02809222933/Notice_Russia_140624.pdf)
- UK Government adds 42 entries and six vessels to the UK sanctions list under the Russia regime: On June 13, 2024, the UK Government added seven individuals, 35 entities and six vessels to the UK sanctions list under the Russia regime, all of which are now subject to an asset freeze and trust services sanctions. The UK Government announced that these new designations were made "to degrade Putin's war machine, in co-ordinated action with G7 partners to support Ukraine" and to "bear down on Russia's ability to fund and equip its war machine and show the UK's steadfast support for Ukraine". (Notice_Russia_130624.pdf (publishing.service.gov.uk)) (Notice_Russia_140624.pdf (publishing.service.gov.uk)) ( New UK sanctions to crack down on Putin's war machine - GOV.UK (www.gov.uk))
- Two OFSI General Licences Expire: On June 11 and June 13, 2024 respectively, the UK Government moved General Licences INT/2023/3024200 and INT/2024/4576632 to its Expired General Licences page. The former permitted a UK assets freeze target to transfer funders to a UK person in satisfaction of a prior contractual obligation of that assets freeze target subject to certain conditions; the latter authorised certain activities relation to the wind down of certain activities involving Active Denizcilik and Beks Ships. ( OFSI General Licences - GOV.UK (www.gov.uk))
- UK Government updates its Russia sanctions guidance: On June 12, 2024, the UK Government updated its Russia sanctions guidance to incorporate guidance on director disqualification and ship specification under the Russia (Sanctions) (EU Exit) Regulations 2019. (Russia sanctions: guidance - GOV.UK (www.gov.uk))
- UK Court of Appeal overturns High Court judgment in Celestial Aviation v UniCredit: On June 11, 2024, the UK Court of Appeal handed down judgment in Celestial Aviation Services Ltd v UniCredit Bank. Overturning the High Court's decision, the Court of Appeal held that UK sanctions prohibited payments to be made under letters of credit ("LCs") in connection with leases of aircraft to Russian companies. In particular, the Court of Appeal held that Regulation 28 of the UK Russia sanctions regulations prohibited payment under the LCs, because this would be "in connection with" the leases (whose object was the supply of restricted goods - i.e. aircraft - to Russia). Among other things, the Court of Appeal held that the purpose of Regulation 28 is not simply to prevent further aircraft going to Russia (by preventing financing arrangements facilitating that) but it is a "blunt instrument that is intended to cast the net sufficiently wide to ensure that all objectionable arrangements are caught, such that the overall purpose of putting pressure on Russia is achieved." (Celestial Aviation Services Ltd v Unicredit Bank GmbH, London Branch [2024] EWCA Civ 628 (11 June 2024) (bailii.org))
2. MYANMAR SANCTIONS
- UK Government corrects one entry on the UK sanctions list under the Myanmar Regime: On June 13, 2024, the UK Government amended the entry for the International Gateways Group of Company Limited on the UK sanctions list under the Myanmar regime. This entity remains subject to an asset freeze. (Notice_Myanmar_130624.pdf (publishing.service.gov.uk))
3. CENTRAL AFRICAN REPUBLIC SANCTIONS
- UK Government adds two entries to the UK sanctions list under the Central African Republic regime: On June 13, 2024, the UK Government added Diamville and Wood International Group Sarlu to the UK sanctions list under the Central African Republic regime. Both entities are believed to be associated with The Wagner Group, which has allegedly been involved in the commission of violations of international humanitarian law in the Central African Republic. These entities are now subject to an asset freeze. (Notice_Central_African_Republic_130624.pdf (publishing.service.gov.uk))
4. ISRAEL SANCTIONS
- UK Government publishes export control licensing data relating to Israel: On June 11, 2024, the UK Government published an ad hoc management release with certain export control licensing data relating to Israel from 7 October 2023 to 31 May 2024, including: (i) the number of extant licences where Israel was included as a destination as at 31 May 2024; (ii) the number of licences currently in-progress where Israel was included as a destination as at 31 May 2024; and (iii) the number of licensing decisions where Israel was included as a destination from 7 October 2023 to 31 May 2024. (Export control licensing management information for Israel - GOV.UK (www.gov.uk))
5. OTHER SANCTIONS
- UK Government updates its licensing statistics for strategic export controls: On June 13, 2024, the UK Government updated its licensing statistics for strategic export controls for (i) 1 January to 31 March 2023, (ii) 1 April to 30 June 2023, (iii) 1 July to 30 September 2023, and (iv) 1 October to 31 December 2023 to reflect amendments made to existing licences since its previous publication on January 16, 2024. The UK Government also published its annual report for licensing statistics for 2023. (( Strategic export controls: licensing statistics: 1 January to 31 March 2023 - GOV.UK (www.gov.uk); Strategic export controls: licensing statistics: 1 April to 30 June 2023 - GOV.UK (www.gov.uk); (Strategic export controls: licensing statistics: 1 July to 30 September 2023 - GOV.UK (www.gov.uk)); Strategic export controls: licensing statistics: 1 October to 31 December 2023 - GOV.UK (www.gov.uk); https://www.gov.uk/government/collections/strategic-export-controls-licensing-data-annual-reports?utm_medium=email&utm_campaign=govuk-notifications-topic&utm_source=1d9769cc-53e0-4b0f-9c6e-c86e2eb55fa3&utm_content=immediately#full-publication-update-history)
- UK Government updates strategic export control statistics: On June 13, 2024, the UK Government updated the its strategic export control statistics (statement of administrative sources and quality and methodology information) to include up-to-date details on the SPIRE-LITE transition. (Export licensing statistics statement of administrative sources - GOV.UK (www.gov.uk); Strategic export controls statistics: quality and methodology information - GOV.UK (www.gov.uk))
- UK Government updates its licensing data for strategic export controls: On June 13, 2024, the UK Government updated its strategic export controls licensing data to link to the latest quarterly licensing statistics, for the period 1 October to 31 December 2023. ( Strategic export controls: licensing data - GOV.UK (www.gov.uk))
- UK Government publishes guidance relating to Personal Staff Payments licence: On June 12, 2024, OFSI published guidance setting out OFSI's policy on licensing personal staff payments, i.e. payments relating to certain personal staff who provide domestic or non-professional services to a designated person. (OFSI Personal Staff Payments Licensing Guidance - GOV.UK (www.gov.uk)) (OFSI Travel Licensing Guidance - GOV.UK (www.gov.uk))
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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.