In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.

1. Russia Sanctions

  • UK Government issues new general licence for payments to local authorities: On December 8, 2023, OFSI issued a new General Licence INT/2023/3781228 covering certain payments to local authorities. Under the General Licence, UK assets freeze targets (and persons acting on their behalf) may make certain "Permitted Payments" to Local Authorities in the United Kingdom. Any person making use of the General Licence must report such use to OFSI within 14 days of a Permitted Payment being made. (General_Licence_INT3781228_Payments_to_Local_Authorities.pdf (publishing.service.gov.uk))
  • UK Government designates two Russian cyber hackers: On December 7, 2023, the UK Government added two Russian individuals to the UK sanctions list under the UK's cyber sanctions regime. The individuals are members of Star Blizzard which, according to the UK Government, is a cyber-hacking group subordinate to Russia's Intelligence Services. The designated individuals are (i) Andrey Stanislavovich Korinets and (ii) Ruslan Aleksandrovich Peretyatko, both of who are now subject to an asset freeze. (Notice_Cyber_071223.pdf (publishing.service.gov.uk))
  • G7 introduce import restrictions on Russian diamonds: On December 6, 2023, the G7 nations confirmed in a statement that they will introduce import restrictions on non-industrial diamonds which are mined, processed, or otherwise produced in Russia. The restrictions will begin from January 1, 2024, followed by further phased restrictions on the import of Russian diamonds processed in third countries by 1 March 2024. (G7 to ban Russian diamonds, announce measures on price cap, assets-sources | Reuters)
  • NCA issues a red alert on circumvention of Russia export controls: On December 6, 2023, the Office of Financial Sanctions Implementation (OFSI) and National Crime Agency (NCA), among others, issues a cross-agency red alert warning that Russia is attempting to circumvent sanctions to purchase restricted goods and services. The alert sets out common techniques suspected to be in use to evade sanctions on the export of high-risk goods and discusses certain red flags for the financial sector in respect of sanctions, which include features of suspicious transactions, customers and requested services. (file (nationalcrimeagency.gov.uk))
  • UK Government adds 45 entries to the sanctions list under Russian regime: On December 6, 2023, the UK Government added 25 individuals and 20 entities to the UK sanctions list under the Russia regime, all of whom are believed to be supporting the Russian military. All such entries are now subject to an asset freeze and trust services sanctions. (Notice_Russia_061223.pdf (publishing.service.gov.uk))
  • FCA and OFSI introduce new memorandum of understanding: On December 5, 2023, the FCA and OFSI published a new memorandum of understanding, which sets out the arrangements for their co-operation and exchange of information. The memorandum replaces its previous iteration, from April 2019. (Memorandum of Understanding between the Office of Financial Sanctions (OFSI) and the Financial Conduct Authority (fca.org.uk))

2. Belarus Sanctions

  • UK Government adds one entity to the sanctions list under Belarus regime: On December 6, 2023, the UK Government added JSC Display Design Bureau to the UK sanctions list under the Belarus regime. This entity is now subject to an asset freeze. (Notice_Belarus_061223.pdf (publishing.service.gov.uk))

3. Human Rights sanctions

  • UK Government adds 46 entries to sanctions list under human rights regime: On December 8, 2023, the UK Government, in a coordinated effort with international partners, announced a new sanctions package targeting 41 individuals and 5 entities connected to human rights abuses and violations around the world. The announcement comes alongside the 75th anniversary of the Universal Declaration of Human rights, which was on December 10, 2023. (UK and allies sanction human rights abusers - GOV.UK (www.gov.uk))

Originally published 11 December 2023.

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.