Regulatory Outlook

Sanctions and export control | UK Regulatory Outlook July 2023

Published on 26th Jul 2023

New Russia sanctions on legal advisory services | OFAC/OFSI publishes humanitarian assistance factsheet in relation to Russia sanctions | OFSI updates incomplete licensing applications process | Russia sanctions research briefing

New Russia sanctions on legal advisory services

On 29 June 2023, the government introduced a new law that will prevent UK legal advisory services being provided, directly or indirectly  to "advance the interests of Russia".

The intention is to prevent UK persons (wherever located) and persons in the UK providing legal advisory services in relation to financial or trade activity already prohibited under the UK sanctions regime. This is of particular concern given that English law is often chosen as the law governing international commercial activities.

The grace period for contractual obligations in place before 30 June 2023 in relation to legal advisory services will expire on 29 September 2023.

The Foreign, Commonwealth & Development Office has updated its professional and business services sanctions guidance following the addition of the new legal advisory services sanction. An explanatory memorandum to the Russia Sanctions Regulations can also be found here.

OFAC/OFSI publishes humanitarian assistance factsheet in relation to Russia sanctions

On 28 June 2023, the Office of Foreign Assets Control (OFAC) and the Office of Financial Sanctions Implementation (OFSI) published a joint humanitarian assistance factsheet to address humanitarian concerns associated with UK and US sanctions.

The guide is aimed at helping humanitarian actors, non-governmental organisations (NGOs), financial institutions and companies engaged in agricultural trade or the provision of medical supplies and assistance who engage in transactions that may be impacted by sanctions.

OFSI updates incomplete licensing applications process

On 12 July 2023, OFSI published a blog on its licensing process on incomplete applications.

OFSI previously introduced a temporary measure of engagement with licence applicants until sufficient details and evidence were received to make a licence decision.

OFSI will now resume returning applications which are not complete at the time of receipt for re-submission. However, OFSI stresses that these submissions will be treated as a new application and will not be prioritised simply because it has been resubmitted.

Some of the key pieces of information that applicants need to provide are:

  • which sanctions regime the application relates to;
  • the UK nexus;
  • the applicable licensing purpose relied upon and why it applies to the applicant's case; and
  • evidence that the conditions of the licence relied upon have been met.

An introductory guide to licensing to  can be found on OFSI's website here.

Russia sanctions research briefing

On 5 July 2023, the House of Commons Library published a research briefing on the sanctions package imposed against Russia in response to the invasion of Ukraine.

The briefing provides a helpful timeline and summary of the sanctions the UK has imposed so far, listing high-profile individuals and banks subject to targeted sanctions, as well as key financial and trade sanctions imposed in coordination with UK's allies.

Call to action

As part of checking that you have effective sanctions screening and controls in place, make sure consideration is given to compliance with any "gold standard" clauses in banking facilities and other contractual commitments (that is, those that go beyond a basic requirement to comply with applicable sanctions).



* 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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