On 15 March the UK announced new economic sanctions against Russia.
The new sanctions will deny Russia and Belarus access to Most Favoured Nation tariffs for hundreds of their exports and ban UK exports of high-end luxury goods to both countries. The full press release can be viewed here.
In addition, UK Export Finance has announced it will no longer issue any new guarantees, loans and insurance for exports to Russia and Belarus, whilst retaining £3.5 billion of financial support for trade to Ukraine. You can view the press release here.
UK Government officials will host a webinar for businesses about the recent changes to UK sanctions relating to Russia.
UK sanctions against Russia, Thursday 24 March, 14:00 – 15:30 GMT
The webinar will cover; the scope of sanctions, scope and application of trade sanctions; financial sanctions: restrictions and general licenses; the Export Support Service and enforcement of trade sanctions. Further details can be found here, and you can register here.
Previous measures still applicable
On 24 February the UK Government announced a new package of sanctions on Russia, full details are available here: https://www.gov.uk/government/news/foreign-secretary-imposes-uks-most-punishing-sanctions-to-inflict-maximum-and-lasting-pain-on-russia
These measures include:
- Comprehensive sanctions covering Russian elites, companies and financial institutions announced following Russia’s full-scale invasion of Ukraine
- Russian bank assets in UK to be frozen totally shutting off its banking system from UK finance markets
- The UK is banning Russian state-owned and key strategic private companies from raising finance on the UK financial markets
- More than 100 companies and oligarchs at the heart of Putin’s regime hit with sanctions today worth 100s of billions of pounds, asset freezes and travel bans
- Punitive new restrictions on trade and export controls against Russia’s hi-tech and strategic industries
- Russia’s national airline Aeroflot banned from UK airspace
- New restrictions to cut off wealthy Russians’ access to UK banks
- The UK is working with allies to exclude Russia from the SWIFT financial system
It is important that manufacturers ensure their business activities are compliant with the current sanctions against Russia and seek independent legal advice if necessary. UK firms will be legally liable for failure (knowingly or otherwise) to comply with UK Sanctions law.
The situation will obviously develop over the coming days and weeks, so if is essential to continue to check the relevant government guidance pages to understand the potential impact on your business and action you may need to take.
Trade with Russia
If you are planning to trade with Russia, you should check if your product is on the export ban list which can be found in the Russian Sanctions: Guidance document:
Russia sanctions: guidance - GOV.UK (www.gov.uk)
There is a suspension of dual-use goods. You can assess your products to determine whether or not they are controlled and are subject to this suspension at the following link
Export controls: dual-use items, software and technology, goods for torture and radioactive sources - GOV.UK (www.gov.uk)
British nationals in Ukraine and Russia
Consular support is available to British nationals in Ukraine and Russia:
Consular support for Ukraine: https://www.gov.uk/world/organisations/british-embassy-kyiv
Consular support for Russia: https://www.gov.uk/world/organisations/british-embassy-moscow
UK Sanctions List
The UK government publishes the UK Sanctions List, which provides details of those designated under regulations made under the Sanctions Act. The list also details which sanctions measures apply to these persons or ships, and in the case of UK designations, provides a statement of reasons for the designation. For more information please see:
The UK Sanctions List - GOV.UK (www.gov.uk)
HM Treasury’s Office for Financial Sanctions Implementation provides a consolidated list of persons and organisations under financial sanctions, including those under the Sanctions Act and other UK legislation. Find out:
Manufacturers can stay up to date with the latest government notifications on export controls by signing up to the Export Control Joint Unit (ECJU) e-alert service.
Notice to Exporters e-alerts: Export Control Organisation (govdelivery.com)
There are also financial sanctions relating to Russia. It is important that businesses also consult the links below, which refer to 2019 and the latest 2022 financial sanctions relating to Russia.
UK Sanctions Relating to Russia: UK sanctions relating to Russia - GOV.UK (www.gov.uk)
Russian Sanctions: Guidance: Russia sanctions: guidance - GOV.UK (www.gov.uk)
Financial Guidance, Russia: Financial sanctions, Russia - GOV.UK (www.gov.uk)
Seek Legal Advice
Companies doing business with countries subject to sanctions must accept the risks of doing so, just as they accept other political and market risks. We suggest you take legal advice if you suspect your business could be impacted.
UK Government Support Service
Businesses who have questions about trading with Ukraine or Russia should use the dedicated online service from the Export Support Service or call 0300 303 8955.
In addition to actions taken directly by the UK Government, the European Union (EU) has adopted a comprehensive package of restrictive sanctions. These include travel bans; asset freezes as well as restrictions on trade and investments such as import bans and further controls on dual use items. The EU has also imposed significant financial sector sanctions, energy sanctions and taken strong action in transport sector. For more details on the measures taken at an EU level please see the link below.
EU sanctions against Russia following the invasion of Ukraine | European Commission (europa.eu)
Please note that alongside joint action at EU level, individual EU member states may also have additional measures in place.