Recent Sanctions Imposed on Russia by OFSI
The UK has published RUSSIA (SANCTIONS) (EU EXIT) (AMENDMENT) (NO. 17) REGULATIONS 2022 which came into force on 16th December 2022. The prohibition on the import of Liquified Natural Gas, will come into force on 1st January 2023. These sanctions are part of a broader set of measures that include diplomatic, military, financial, humanitarian support, trade, financial, and designation sanctions.
These amendments will extend restrictions on trade with Russia for the purposes of encouraging Russia to cease actions of destabilising Ukraine or dejection or threatening the territorial integrity, sovereignty or independence of Ukraine.
This instrument amends the 2019 Regulations to impose prohibitions and requirements in relation to trade and financial sanctions measures which are detailed below.
Financial Sanctions
· A prohibition on providing services related to trusts or similar arrangements to, or for the benefit, of persons designated for the purposes of this measure; and on providing new services related to trusts or similar arrangements to, or for the benefit of, persons connected with Russia.
· Amendments to existing restrictions on dealing with securities or money market instruments and loans and credit arrangements to persons connected with Russia.
· Suspension of the Bank of England's duty under the Banking Act 2009 to make a decision in respect of a notification of third-country resolution action in respect of designated persons or persons owned or controlled by designated persons.
Trade Sanctions
· An expansion of the current prohibitions on the export, supply, delivery, and making available of additional products (as well as related to technical assistance, financial services, funds, and brokering services), to the critical-industry goods and critical-industry technology schedule. This measure includes prohibitions on camouflage, oil production and mining equipment.
· An expansion of the current prohibitions on the export of defence and security goods and technology. This measure includes prohibitions in relation to five additional chemicals.
· A prohibition on the direct and indirect provision of auditing services to a person connected with Russia.
· A prohibition on the direct and indirect provision of advertising services to a person connected with Russia.
· A prohibition on the direct and indirect provision of architectural and engineering services to a person connected with Russia.
· A prohibition on the direct or indirect provision of information technology consultancy and design services to a person connected with Russia.
Latest round of EU sanctions on Russia
On 16th December, EU imposed ninth package of sanctions in response to Russia's invasion of Ukraine. This decision has been taken to control and restrict the export of goods and services that can contribute to the technological enhancement of Russia's defence and security sector.
The new ban includes:
· exports of drone engines to Russia and any third country that could supply drones to Russia.
· exports of dual-use goods and technology investments in the mining sector.
· transactions with the Russian Regional Development Bank.
· the provision of advertising, market research and public opinion polling services.
The EU has also suspended the broadcasting licenses of four additional Russian outlets (TV/NTV Mir, Rossiya 1, REN TV and Pervyi Kanal) and has sanctioned an additional 141 individuals and 49 entities.
Further, EU will expand the export ban on aviation and the space industry related goods and technology that include aircraft engines and their parts.
The package includes following measures explained in detail to target the Russian economy:
Banking Services
The EU imposed an asset freeze against two additional Russian banks (Credit Bank of Moscow, ISC Dalnevostochnix) and added the Russian Regional Development Bank to the list of Russian State-owned or controlled entities that are subject to a full transaction ban.
Agricultural Sector
Introduction of new exemption allowing to unfreeze assets to make funds and economic resources available to certain individuals who held a significant role in international trade in agricultural and food products, including wheat and fertilizers, prior to their listing.
Consulting Services
Ban on the provision of EU advertising, market research and public opinion polling services, as well as product testing and technical inspection services to the Russian Federation.
Energy and Mining Sector
The EU will expand the prohibition targeting new investments in the Russian energy sector by additionally prohibiting new investments in the Russian mining sector, except for mining activities involving certain critical raw materials.
How CSL Can Help
CSL has a wealth of expertise advising clients on sanctions.
We have the experience and expertise to deliver pragmatic business centric solutions tokeep you compliant.
If your business requires advice, support, and solutions please reach out to CSL today.
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