Regulatory Outlook

Sanctions and Export Control | UK Regulatory Outlook February 2023

Published on 28th Feb 2023

OFSI issues new ransomware sanctions guidance | UK government publishes updated Russia services sanctions guidance | OFSI publishes update on oil price cap 

OFSI issues new ransomware sanctions guidance 

On 9 February 2023, the Office of Financial Sanctions Implementation (OFSI) published new guidance on sanctions in ransomware cases.

The guidance explains how making funds available to "threat actors", such as paying ransomware – and including crypto assets – is prohibited under the Cyber (Sanctions) (EU Exit) Regulations 2020. Breaches of these financial sanctions is a criminal offence and may result in a custodial sentence or a monetary penalty or both.

Organisations are encouraged to implement robust cyber security and incident management systems in order to prevent and manage serious cyber attacks. 

The government publishes a collection of guidance offering further information on the UK's cyber sanctions regime and the full UK Sanctions List, as well as updates on specific sanction action that been taken.

New Russia trade sanctions

On 24 February 2023, the UK government announced a new package of internationally co-ordinated sanctions and trade measures against Russia. 

These include sanctions on Russian individuals and entities, as well as export bans on every item Russia has been found using on the battlefield to date, including aircraft parts, radio equipment and electronic components. The UK will also ban the import of 140 goods including iron and steel products processed in third countries. 

For wider guidance in relation to sanctions and export control please see our website, and view the full UK Sanctions List here.

UK government publishes updated Russia services sanctions guidance 

On 7 February 2023, the Department for International Trade (DIT), in conjunction with the Export Control Joint Unit, published updated guidance on supplying professional and business services to a person connected with Russia. 

The guidance includes a new section detailing the professional and business services sanctions which were prohibited from 16 December 2022. These include: 

  • Advertising.
  • Architectural and engineering.
  • Auditing.
  • IT consultancy and design services. 

Illustrative examples of activities that are not in scope of the sanction – and are therefore permitted – are given, as well as guidance on applying for licences and what information to include in the cover letter for licence applications under Regulation 54C of the Russia Regulations.

OFSI publishes update on oil price cap 

The UK, in partnership with the G7 countries, Australia and the European Union, has implemented a ban on the seaborne transportation of Russian refined oil products from Russia to and between third parties, that came into effect on 5 February 2023. OFSI has issued a General Licence to implement a "price cap exception", as well as a wind-down General Licence for oil products.

The UK and coalition partners previously implemented a ban on the import of Russian crude oil that came into effect on 5 December 2022. 

Updated guidance on the Maritime Services Prohibition and the Oil Price Cap has also been released.

(Wider guidance in relation to sanctions and export control may be found on our website, and further reading on the Russian oil services ban may be found here.)


* This article is current as of the date of its publication and does not necessarily reflect the present state of the law or relevant regulation.

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