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.above.
1. Russia Sanctions
- OFSI amends general licence for payments by designated persons to Companies House: On February 23, 2024, OFSI amended General Licence INT/2023/3626884 to permit the payment of inter alia fees owed by or due from a designated person to Companies House for the administrative restoration of an entity previously incorporated in the UK which was struck off and dissolved by the Registrar of Companies at Companies House Administrative Restoration Fees. (Publication_Notice_-_Companies_House_General_licence_INT20233626884_Amended_23.02.2024.pdf (publishing.service.gov.uk))
- UK Government adds more than 50 entries to the UK sanctions list under the Russia and Belarus regimes: On February 22, 2024, the UK Government designated more than 50 individuals and businesses in connection with Russia's invasion of Ukraine. These sanctions target key sources of Russian revenue such as metals, diamonds, and energy trade, as well as parties that Russia with munitions. The new targets include munitions manufacturers, electronics companies, diamond and oil traders, and oil and gas companies (such as Arctic LNG 2, one if its directors and six directors of PJSC Novatek, majority owner of Arctic LNG 2). (Notice_Russia_220224.pdf (publishing.service.gov.uk); Notice_Belarus_220224.pdf (publishing.service.gov.uk); https://www.gov.uk/government/news/new-uk-sanctions-mark-two-years-since-russias-illegal-invasion-of-ukraine)
- UK Government amends one entry on the UK sanctions list under the Russia regime: On February 23, 2024, the UK Government amended the entry for Ilya Borisovich Brodskiy under the Russia sanctions regime. This individual remains subject to an asset freeze and trust services sanctions, and is not subject to transport sanctions. (Notice_Russia_230224.pdf (publishing.service.gov.uk))
- UK Government expands Common High Priority Items list: On February 22, 2024, the UK Government, in collaboration with its international partners, expanded the Common High Priority List, a list that includes Western items critical to Russian weapons systems and its military development. In particular, the list was expanded to include 5 new codes related to Computer Numerical Control (CNC) machines which are crucial to the manufacture and maintenance of vital military equipment. (Russia Sanctions – Common High Priority Items List - GOV.UK (www.gov.uk))
- OFSI updates guidance on reporting requirements under the Russia regime: On February 20, 2024, the UK Government updated its Russia guidance to add FAQ 56, which relates to reporting obligations under Regulation 70A(5). Regulation 70A(5) requires a designated person to report changes in their financial circumstances to OFSI as soon as practicable. The FAQ provides that a designated person must report to OFSI (a) when the value of their funds or economic resources, when taken together, has changed by an amount exceeding £10,000 compared with the previous report filed with OFSI, or (b) if there has been a change to the nature or location of funds or economic resources where those funds or economic resources exceed £10,000 in value. (Russia_Guidance_February_2024.pdf (publishing.service.gov.uk))
Human Rights Sanctions
- UK Government adds six entries to the sanctions list under the Human Rights regime: On February 21, 2024, the UK Government designated six individuals under the Global Human Rights Sanctions Regulations 2020. These individuals are reportedly in charge of the Artic penal colony where Russian opposition figure Alexie Navalny died on February 16, 2024, after years of mistreatment by the Russian authorities. Those designated are (i) Aleksandr Vladimirovich Golyakov; (ii) Vadim Konstantinovich Kalinin; (iii) Sergey Nikolaevich Korzhov; (iv) Aleksandr Valerievich Obraztov; (v) Vladimir Ivanovich Pilipchik; and (vi) Vasiliy Alexandrovich Vydrin, all of whom are now subject to an asset freeze and travel ban. (Notice_Global_Human_Rights_210224.pdf (publishing.service.gov.uk); UK sanctions heads of Arctic penal colony where Alexei Navalny was killed - GOV.UK (www.gov.uk))
Central African Republic Sanctions
- UK Government amends one entry on the UK sanctions list under the CAR regime: On February 23, 2024, the UK Government amended the entry for Konstantin Aleksendrovitch Pikalov under the CAR sanctions regime. This individual remains subject to an asset freeze and travel ban. (Notice_Central_African_Republic_230224.pdf (publishing.service.gov.uk))
Democratic Republic of Congo Sanctions
- UK Government amends three entries on the UK sanctions list under the DRC regime: On February 23, 2024, the UK Government amended the entries for Willy Ngoma, Apollinaire Hakizimana and William Amuri Yakutumba, each of whom remain subject to an asset freeze and travel ban. (Notice_Democratic_Republic_of_the_Congo_230224.pdf (publishing.service.gov.uk))
- UK Government adds six entries to the UK sanctions list under the DRC regime: On February 21, 2024, the UK Government designated six individuals under the DRC Sanctions Regime affiliated with inter alia alleged human rights abuse, interference with democracy and the use of explosive devices in the DRC. These individuals are (i) Apollinaire Hakizimana; (ii) Ahmad Mahmood Hassan; (iii) Willy Ngoma; (iv) Mohamed Ali Nkalubo; (v) Michel Rukunda; and (vi) William Amuri Yakutumba, all of whom are now subject to an asset freeze and travel ban. (Notice_Democratic_Republic_of_the_Congo_210224.pdf (publishing.service.gov.uk); Security Council 1533 Sanctions Committee Adds Six Entries to Its Sanctions List | Meetings Coverage and Press Releases)
ISIL (Da'esh) and Al-Qaida Sanctions
- UK Government amends one entry on the UK sanctions list under ISIL (Da'esh) and Al-Qaida regime: On February 23, 2024, the UK Government amended the entry for Abd Al-Rahman Muhammad Mustafa Al-Qaduli under the ISIL (Da'esh) and Al-Qaida sanctions regime. This individual remains subject to an asset freeze, arms embargo and travel ban. (Notice_ISIL__Da_esh__and_Al-Qaida_230224.pdf (publishing.service.gov.uk))
Other Sanctions
- Mayer Brown releases podcast on sanctions: On February 23, 2024, Mayer Brown released a 13-minute podcast featuring London-based partner Jason Hungerford, as part of its Tools of the Trade podcast series on 'How It Works: Sanctions". (Tools of the Trade | Mayer Brown)
- UK Government releases first ever sanctions strategy: On February 22, 2024, the UK Government released its first sanctions strategy, which sets out its approach to using sanctions to address global threats, promote international norms and protect the UK. The strategy, which comes two years after Russia's invasion of Ukraine, states that "the UK deploys sanctions to deter future or continued malign activity; to disrupt current malign activity; and to demonstrate our readiness to defend international norms." (Deter, disrupt and demonstrate – UK sanctions in a contested world: UK sanctions strategy - GOV.UK (www.gov.uk)).
Originally published by 26 February, 2024
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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.
