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On February 9, 2023, the UK announced the designation of seven individuals said to be part of a Russia-based cybercrime gang under the UK’s thematic cyber sanctions regime pursuant to The Cyber (Sanctions) (EU Exit) Regulations 2020.  The designations were coordinated with the US.  Concurrently, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”), in partnership with other HM Government  (“HMG”) organisations, published guidance on sanctions and ransomware, which addresses the impact of ransomware payments, cyber resilience, and HMG’s approach to enforcement of financial sanctions breaches related to ransomware attacks.…

Continue Reading UK Sanctions Russian Cybercrime Gang and Issues New Guidance on Sanctions and Ransomware

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).…

Continue Reading UK Expands Guidance on the Supply of Professional and Business Services to Persons Connected with Russia

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.…

Continue Reading UK Oil Price Cap for Russian Refined Oil Products Comes into Effect

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.…

Continue Reading UK Introduces New Wave of Russia Financial and Trade 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.…

Continue Reading UK Government Publishes Guidance on the UK Ban on Oil and Oil Products

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).…

Continue Reading OFSI Publishes Guidance on the UK Maritime Services Prohibition and Oil Price Cap

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.…

Continue Reading New UK Russia Sanctions Legislation Bans the Maritime Transport of Russian Oil

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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Continue Reading 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

On September 27, 2022, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) announced that a monetary penalty of £30,000 was imposed on April 26, 2022 against Hong Kong International Wine and Spirits Competition Ltd. (“HKIWSC”) for breaches of the Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 (the “UK Regulations”) and Council Regulation (EU) No. 269/2014 (Ukraine Misappropriation and Human Rights) (the “EU Regulations”).  HKIWSC is a UK registered company.

According to OFSI’s penalty report, HKIWSC received three payments and 78 wine bottles from State Unitary Enterprise of the ‘Republic of Crimea’ Production-Agrarian Union (“Massandra”), a designated entity since July 25, 2014, for entry into competitions between September 2017 and August 2020.  The total cumulative value of the payments and wine bottles received by HKIWSC was estimated at £3,919.62.  Additionally, HKIWSC made publicity – considered an intangible economic resource – available to a UK designated person.

The HKIWSC case represents the eighth use of OFSI’s civil monetary penalty powers since they were introduced under Part 8 of the Policing and Crime Act 2017 (“PACA”).  Several useful hints as to OFSI’s enforcement priorities and interpretation of the scope of asset freeze sanctions can be discerned from the HKIWSC case.…

Continue Reading OFSI Imposes Eighth Monetary Penalty on Hong Kong International Wine and Spirits Competition Ltd.

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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Continue Reading 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