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6 August 2024

UK Weekly Sanctions Update - Week Of July 29, 2024

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The UK extended General Licence INT/2024/4919848 until October 12, 2024, to facilitate transactions of financial instruments held at the NSD. Additionally, the UK revoked and re-specified 17 ships for carrying Russian oil and confiscated £780,000 from Petr Aven under sanctions.
United Kingdom International Law
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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 extends General Licence relating to transactions in financial instruments held at the National Settlement Depository (NSD). On August 2, 2024, the UK extended General Licence INT/2024/4919848, which relates authorises any activity reasonably necessary to sell, divest or transaction certain financial instruments held at the NSD and the payment of safe keeping fees, subject to certain conditions. The general licence now expires on 12 October 2024. (INT.2024.4919848_GL.pdf (publishing.service.gov.uk)).
  • UK revokes and re-specifies 17 ships under the Russia sanctions regime. On July 31, 2024, the UK revoked and re-specified 17 ships under the Russia sanctions regime relating to Russian ships. A specified ship: is prohibited from being provided with access to or having its master or pilot cause it to enter a port in the UK; may have its registration on the UK Ship Register terminated; and a master or pilot of a specified ship may be given a port barring direction, a detention direction, and a port entry direction or a movement direction. According to the UK Statement of Reasons, the specified ships have each been involved in carrying oil or oil products that originated in Russia from Russia to a third country.(FCDO - UK Sanctions List Search - GOV.UK (search-uk-sanctions-list.service.gov.uk)).
  • UK National Crime Agency (NCA) confiscates over £780,000 from Petr Aven. On July 29, 2024, the NCA announced that it had secured the forfeiture of more than £780,000 from Petr Aven, the former head of Russia's largest commercial bank under the Proceeds of Crime Act 2002. (NCA recovers £780,000 in the first UK forfeiture of sanctioned funds - National Crime Agency).

2. Syria Sanctions

  • UK amends exceptions relating to petroleum products in Syria sanctions regulations. On July 31, 2024, the UK introduced the Syria (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024 which inter alia expands regulation 57 (exceptions relating to petroleum products) of the Syria (Sanctions) (EU Exit) Regulations 2019. Regulation 57 creates an exception to a number of prohibitions for persons who receive funding from the UK Government for the purpose of providing a humanitarian assistance activity in Syria. (The Syria (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024 (legislation.gov.uk)).

3. Yemen Sanctions

  • UK de-lists two individuals under the Yemen sanctions regime. On August 1, 2024, the UK delisted Ali Abdullah Saleh and Ahmed Ali Abdullah Saleh under the Yemen sanctions regime. These individuals are no longer subject to an asset freeze. (Notice_Yemen_010824.pdf (publishing.service.gov.uk)).

4. Other Sanctions

  • The Foreign, Commonwealth and Development Office (FCDO) introduces a new UK Sanctions List search function. On August 1, 2024, the FCDO announced the release of a new UK sanctions list search function to enable users to more effectively search for designated persons without downloading the list in its entirety. This improvement is part of ongoing efforts to improve the UK's sanctions infrastructure and the overall user experience to support sanctions compliance. (FCDO - UK Sanctions List Search - GOV.UK (search-uk-sanctions-list.service.gov.uk)).
  • UK Sanctions Implementation and Strategy Taskforce ("Taskforce") publishes first report: On July 23, 2024, the Royal United Services Institute published the first meeting report of the Taskforce. The Taskforce was established to examine how the UK has responded to the "need to design, implement and enforce sanctions on Russia." The Taskforce identified "several deficiencies undermining the effectiveness and credibility of UK sanctions." (https://static.rusi.org/Sanctions-Taskforce-first-meeting-july-2024_0.pdf).

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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.

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