On February 7, 2023, the UK Department for International Trade (“DIT”) published an expanded version of its guidance on supplying professional and business services to a person connected with Russia (“DIT Guidance”), following a broadening of the types of services covered by the ban in December 2022. The DIT Guidance sets out additional details regarding the services falling within the scope of these sanctions, enforcement, applicable exceptions, and the licence application process. For more information on the ban on the supply of professional and business services, see our previous blog post (here).
Russia/Ukraine Sanctions
UK Oil Price Cap for Russian Refined Oil Products Comes into Effect
By Alexandra Melia & Elliot Letts on
On February 5, 2023, the UK ban imposed by Part 5, Chapter 4IA of The Russia (Sanctions) (EU Exit) Regulations 2019, as amended (“Russia Regulations”), on the maritime transportation of certain Russian oil products and related services came into effect. Ahead of the measure coming into force, on February 4, 2023, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published an updated version of its guidance on the UK Maritime Services Prohibition and Oil Price Cap (“OFSI Guidance”), which outlines how the oil products price cap will be implemented, OFSI’s approach to enforcement, and the requirements on involved persons. OFSI also issued two new General Licences that establish the level of the oil products price cap and establish a wind-down period with respect to certain Russian oil products.…
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UK Introduces New Wave of Russia Financial and Trade Sanctions
By Alexandra Melia on
Posted in Russia/Ukraine Sanctions, UK Sanctions
On December 15, 2022, The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (“Amendment 17”) were laid before parliament. Amendment 17 revises existing restrictions on dealing with securities, money market instruments, loans and credit to prohibit new investments in Russia via third countries. It also introduces a new prohibition on the provision of trust services to designated persons and persons connected with Russia, as well as expanding the existing ban on the provision of specified professional and business services to persons connected with Russia and making additions to the lists of items subject to existing trade sanctions. Finally, Amendment 17 suspends 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 a designated person, or entities owned or controlled by such a person. These measures came into effect on December 16, 2022.…
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Price Cap Coalition Selects Level for Cap on Price of Seaborne Russian-Origin Crude Oil
Posted in Price Cap, Russia/Ukraine Sanctions
On December 2, 2022, the G7, EU, and Australia (Price Cap Coalition) jointly agreed upon a cap on the price of seaborne Russian-origin crude oil at USD 60 per barrel as of December 5, 2022. The cap is subject to change based on the Coalition’s objectives and market fundamentals.
Upon reaching this consensus, the Treasury Department released a fact sheet on the same day providing additional details on the price cap policy, including its goals, how it works, and the compliance framework for the policy (the Fact Sheet). Most information has been previously discussed in the guidance released on November 22 (see our prior blog post at link). On December 5, the Treasury Department issued a Determination (the December Determination) pursuant to Executive Order 14071 and the prior Determination dated November 22 (the November Determination), to set the cap at USD 60 per barrel formally and to implement the policy.…
OFAC Publishes Determination and Guidance on Implementing the Price Cap Policy for Russian Crude Oil
By Wendy Wysong, Ali Burney, Bo Yue, Wilson Zhao, Dave Stetson, Ed Krauland & Zoey Hong on
Posted in Price Cap, Russia/Ukraine Sanctions
On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a determination pursuant to Executive Order 14071 (EO 14071) (the Determination) and a guidance on the implementation of the price cap policy for Russian-origin crude oil (the Guidance). These followed OFAC’s preliminary guidance released on September 9 (see Steptoe’s earlier blog post here). The Determination sets forth the categories of services relating to the maritime transport of Russian-origin crude oil (Covered Services) that US persons are prohibited from providing directly or indirectly to a person located in Russia, unless the Russian crude oil is purchased at or below the price cap. The Guidance addresses issues relating to the implementation of the price cap policy for Russian-origin crude oil.…
UK Government Publishes Guidance on the UK Ban on Oil and Oil Products
By Alexandra Melia on
Posted in Russia/Ukraine Sanctions, UK Sanctions
On November 21, 2022, the UK Department for Business, Energy and Industrial Strategy published guidance on the UK ban on Russian oil and oil products intended for entry into the UK (the “BEIS Guidance”) that was legislated for by the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 and will come into effect on December 5, 2022. Among other things, the BEIS Guidance explains how to determine the origin of oil or oil product imports to the UK and sets out UK sanctions authorities’ expectations with respect to compliance controls in relation to the ban.…
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OFSI Publishes Guidance on the UK Maritime Services Prohibition and Oil Price Cap
By Alexandra Melia on
On November 14, 2022, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published detailed guidance on the recently published ban on the provision of maritime transportation of Russian oil and oil products and related services (“OFSI Guidance”). The OFSI Guidance sets out additional details regarding how the oil price cap exception will operate as well as the attestation process and reporting obligations with which all parties involved in the maritime supply chain will need to comply. The OFSI Guidance also addresses OFSI’s proposed approach to enforcement of the new ban. For more information on the ban on the maritime transportation of Russian oil and oil products and related services, see our previous blog post (here).…
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New UK Russia Sanctions Legislation Bans the Maritime Transport of Russian Oil
By Alexandra Melia on
Posted in Russia/Ukraine Sanctions, UK Sanctions
On November 3, 2022, a sixteenth amendment to the UK’s Russia sanctions regime was laid before parliament. The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (“Amendment 16”) introduces a ban on UK ships and services such as insurance, brokerage and shipping facilitating the maritime transport of Russian crude oil from December 5, 2022. A General Licence is expected to be published shortly that lays the basis for an oil price cap exception, which will allow continued access to services provided that Russian crude oil is purchased at or below the price cap. The level of the price cap will be set by the price cap coalition of the G7 and Australia in due course. Amendment 16 brings forward the implementation date for the import bans relating to Russian oil and oil products discussed in our previous blog post (here) from December 31, 2022 to December 5. Amendment 16 also introduces a comparable ban on refined oil products, which will come into effect on February 5, 2023.…
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New UK Russia Sanctions Legislation Amends Loan and Credit Restrictions; Expands the Range of Items Targeted by Existing Trade Prohibitions; and Introduces New Trade Prohibitions on Liquefied Natural Gas, Items Critical to the Functioning of Russia’s Economy and Certain Gold Items
By Alexandra Melia on
Posted in Russia/Ukraine Sanctions, UK Sanctions
On October 28, 2022, further amendments to the UK’s Russia sanctions regime were laid before parliament. The new measures introduced under the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (“Amendment 15”) include an expansion of the ban on loan and credit arrangements and the items covered by existing trade restrictions on oil refining, revenue generating, G7 dependency and further goods and technology. Amendment 15 also introduces an import ban on liquefied natural gas (“LNG”) and the creation of new trade prohibitions on gold jewellery, certain processed gold and the export of so-called “Russia’s vulnerable goods.” All of the new measures will enter into force on October 29, 2022, with the exception of the provisions relating to the import of LNG, which will enter into force on January 1, 2023.
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UK Announces Further Russia Sanctions with Expanded Services Ban; New Export Ban on Goods; Asset Freeze Measures; and Measures Relating to the Failure of Sanctioned Russian Banks
By Alexandra Melia on
Posted in Russia/Ukraine Sanctions, UK Sanctions
On September 30, 2022, the UK Foreign Secretary, James Cleverly, announced new services and goods export bans targeting vulnerable sectors of the Russian economy in response to President Putin’s announcement of the annexation of the Ukrainian regions of Donetsk, Luhansk, Kherson and Zaporizhzhia following sham referendums. The imposition of an asset freeze also was announced on the Governor of the Central Bank of the Russian Federation (CBR), alongside measures to suspend the process by which actions taken to manage the orderly failure of Russian banks are recognized under the laws of the United Kingdom. The announcements were made in tandem with the UK’s international partners.
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