07.04.2022
The situation will develop over the coming days and weeks, so it 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.
Latest UK Measures – 6th April
Following further reports of abhorrent attacks on civilians in Ukraine this week, the Foreign Secretary has today (Wednesday 6 April) announced a significant ratcheting up of UK sanctions on Russia.
The UK’s fifth package of measures will cut off key sectors of the Russian economy and end our dependency on Russian energy. Today’s measures have been delivered in lockstep with our global allies as the EU has also banned imports of Russian coal and the US has sanctioned SberBank.
Key sanctions announced include:
- Asset freezes against Sberbank and Credit Bank of Moscow. Sberbank is Russia’s largest bank and this freeze is being taken in co-ordination with the US.
- An outright ban on all new outward investment to Russia. In 2020 UK investment in Russia was worth over £11bn. This will be another major hit to the Russian economy and further limit their future capabilities.
- By the end of 2022, the UK will end all dependency on Russian coal and oil, and end imports of gas as soon as possible thereafter. From next week, the export of key oil refining equipment and catalysts will also be banned, degrading Russia’s ability to produce and export oil – targeting not only the industry’s finances but its capabilities as a whole.
- Action against key Russian strategic industries and state-owned enterprises. This includes a ban on imports of iron and steel products, a key source of revenue. Russia’s military ambitions are also being thwarted by new restrictions on its ability to acquire the UK’s world-renowned quantum and advanced material technologies.
- And targeting a further eight oligarchs active in these industries, which Putin uses to prop up his war economy.
For more information please see the UK Government website: Russian invasion of Ukraine: UK government response - GOV.UK (www.gov.uk)
EU announces further Sanctions – 5th April
The fifth EU package has six pillars.
- The EU will impose an import ban on coal from Russia
- A full transaction ban on four key Russian banks, among them VTB, the second largest Russian bank. These four banks, which we now totally cut off from the markets, represent 23% of market share in the Russian banking sector.
- A ban on Russian vessels and Russian-operated vessels from accessing EU ports. Certain exemptions will cover essentials, such as agricultural and food products, humanitarian aid as well as energy. Additionally, the EU will propose a ban on Russian and Belarusian road transport operators. This ban will drastically limit the options for the Russian industry to obtain key goods.
- Further targeted export bans, worth EUR 10 billion. This includes, quantum computers and advanced semiconductors, but also sensitive machinery and transportation equipment.
- Specific new import bans, worth EUR 5.5 billion, on products from wood to cement, from seafood to liquor.
- The EU will take several targeted measures, such as a general EU ban on participation of Russian companies in public procurement in Member States, or an exclusion of all financial support to Russian public bodies.
For more information, please see EU website: EU solidarity with Ukraine | European Commission (europa.eu)
15th March Measures – Import controls and export bans
On 15 March the UK announced new economic sanctions against Russia, including additional tariffs on a range of imports from Russia as well as additional bans on UK exports.
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.
Government Contact details
For further information on financial sanctions: contact the Office of Financial Sanctions Implementation [email protected].uk or subscribe to the Office of Financial Sanctions Implementation’s e-alerts
For further information on export controls: contact the Export Control Joint Unit Helpline on 020 7215 4594 or email [email protected] or subscribe to the Export Control Joint Unit’s notices to exporters
For further information on import controls: contact the Department for International Trade’s Import Licensing Branch on [email protected]
For further information on transport sanctions: contact the Department for Transport on [email protected]
For general information on sanctions: contact the Foreign, Commonwealth & Development Office’s Sanctions Unit on [email protected]
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.
Government Webinar
On 17 March 2022, the UK government held a webinar briefing on UK sanctions relating to Russia. A recording of this webinar is available for a short time here.
For any questions about the impact of these sanctions on UK businesses operating in any sector, or business operations in Ukraine or Russia, contact the Export Support Service who are providing a front line Russia sanctions support service to all businesses.
Further statutory guidance will be published when the relevant legislation is laid.
Export support team
Telephone: 0300 303 8955
Textphone: 18001 303 8955
Monday to Friday, 8am to 6pm (excluding public holidays)
Trading with Russia
It is for business to decide whether or not to trade with Russia. Sanctions against Russia from UK and allies, and expected retaliatory measures, will continue to create a highly unpredictable trading environment for UK business. Moving goods to and from Russia, settling financial transactions with suppliers and customers, and trading with certain businesses and individuals, have all been impacted by the newly announced sanctions and should be considered. It is advised that any business planning to continue trading with Russia, should seek necessary legal advice.
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)
Imports from Russia
The UK has placed an additional import tariff of 35 percent on a number of goods from Russia and Belarus. This will affect £900 million of Russian imports to the UK.
Around 20 different categories, resulting in hundreds of different goods will be affected including:
Iron, steel, fertilisers, wood, tyres, railway containers, cement, copper, aluminium, silver, lead, iron ore, residue/food waste products, beverages, spirits and vinegar (this includes vodka), glass and glassware, cereals, oil seeds, paper and paperboard, machinery, works of art, antiques, fur skins and artificial fur, ships and white fish.
For a full list of the newly tariffed goods along with their HS codes, please refer to the link “Products requiring additional duties when imported from Russia or Belarus” on this page: https://www.gov.uk/guidance/tariffs-on-goods-imported-into-the-uk#russia-additional-duties-products
For more information please visit: https://www.gov.uk/government/news/uk-announces-new-economic-sanctions-against-russia
Export Controls
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)
Dual use
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)
24th February Measures
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.
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:
Financial Sanctions
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.
EU measures
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)
The EU has decided to act not through an increase on import tariffs, but through a set of sanctions that comprise bans on the imports or exports of goods, notably:
- an EU import ban on those steel products currently under EU safeguard measures. Increased import quotas will be distributed to other third countries to compensate
- an EU export ban on luxury goods to directly hit Russian elites
Please note that alongside joint action at EU level, individual EU member states may also have additional measures in place.