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
- OFSI publishes seven new FAQs on UK financial sanctions. On July 19, 2024, the UK Office of Financial Sanctions Implementation (OFSI) issued seven new FAQs. Six relate to the trust services ban under the Russia regime; one relates to a general licence for inter alia the sale, divestment and transfer of financial instruments held by the National Security Depository. (UK Financial Sanctions FAQs - GOV.UK (www.gov.uk)).
- UK designates 11 ships under the Russia sanctions regime. On July 18, 2024, the UK specified 11 ships under the Russia sanctions regime. According to the FCDO, these sanctions target the Russian shadow fleet which attempts to undermine sanctions in support of the Russian oil trade. (FCDO - UK Sanctions List Search - GOV.UK (search-uk-sanctions-list.service.gov.uk); https://x.com/FCDOGovUK/status/1814194424387092930).
- OFSI amends its Russia Financial Sanctions Guidance. On July 16, 2024, OFSI amended section 9.6 of its Russia Financial Sanctions Guidance, setting out that OFSI may issue a licence under the trust services restrictions for: (i) extraordinary situation, (ii) humanitarian assistance activity, (iii) medical goods or services, (iv) production or distribution of food to the civilian population, (v) diplomatic missions, (vi) safety and soundness of a firm, (vii) financial regulation, (viii) financial stability, and (ix) unauthorised unit trust schemes. (Financial sanctions guidance for Russia - GOV.UK (www.gov.uk)).
- UK House of Commons Library publishes research briefing on post-conflict reconstruction assistance to Ukraine. On July 15, 2024, the UK House of Commons Library published a research briefing on post-conflict reconstruction assistance to Ukraine. The briefing notes, among other things, that while sanctions have not been imposed on nations for continuing to trade with Russia, the United States and allies have increasingly targeted nations and organisations allegedly assisting Russia (such as Belarus, Iran, North Korea and China) in conducting the war in Ukraine or in evading sanctions. The briefing also considers the use of sanctioned Russian assets to pay for reconstruction in Ukraine, noting that this topic will be examined in greater detail in a further research briefing titled 'Sanctions, international law and seizing Russian assets'. (https://commonslibrary.parliament.uk/research-briefings/cbp-9728/?_gl=1*14edvj3*_up*MQ..*_ga*NTkxNjU0NDUxLjE3MjEwNDQ3ODc.*_ga_14RSNY7L8B*MTcyMTA0NDc4Ny4xLjAuMTcyMTA0NDc4Ny4wLjAuMA; CBP-9728.pdf (parliament.uk)).
2. OTHER SANCTIONS
- OFSI publishes blog post relating to reporting obligations in light of global IT outage. On July 19, 2024, OFSI published a blog post acknowledging that technical issues with global IT systems, as reported in the media, may be impacting upon firm's ability to fulfil their reporting obligations to OFSI. The blog post notes that parties that miss a prescribed reporting deadlines should include the reason for any delay, and that OFSI will take this into account when assessing such submissions. (https://ofsi.blog.gov.uk/2024/07/19/global-it-outage-and-ofsi-reporting-obligations/).
- ECJU to attend Farnborough International Airshow (July 22-26). On July 15, 2024, the Export Control Joint Unit (ECJU) announced that it will be attending the Farnborough International Airshow from July 22-26, and will be based at the Government Hub in Hall 3 at the Department for Business and Trade stand.
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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.