Sanctions and Export Control | UK Regulatory Outlook April 2024

UK Sanctions Perceptions Survey

The Foreign, Commonwealth & Development Office is seeking feedback from UK private sector businesses and non-governmental organisations (NGOs) on their perceptions of UK sanctions and their impact on organisations.

The study aims to identify ways in which the government can support businesses and NGOs with sanctions compliance and will contribute to ongoing work to improve and develop policy and guidance.

The government aims to conduct a follow-up survey in early 2025 to measure changes in industry perceptions as a result of the government's efforts in supporting the industry, informed by the recommendations from this survey.  Participate in the survey here.

UK and US crackdown on trade of Russian metals

The UK and US announced joint action targeting the export of prohibited Russian metal with the aim of reducing an important source of revenue supporting Russia's war effort.

In the UK, the London Metal Exchange will no longer trade new Russian-produced aluminium, copper and nickel. See the notice on the UK's Russian metals sanctions. The Department for Business and Trade general trade licence for the acquisition of metals, which was introduced in December 2023, has also been amended with effect from 12 April 2024.

OFSI issues maritime sector guidance

The Office of Financial Sanctions Implementation (OFSI) has published a blog post on how maritime businesses, including shipping companies, port operators, insurers and financial institutions can stay compliant with financial sanctions.

The tips could be applied more generally, though, and include actions such as conducting Know Your Customer (KYC) and due diligence checks to verify the identity of customers, partners and third-party intermediaries before engaging in any business transactions; implementing an appropriate compliance policy; investing in innovative technology and screening tools; organising regular training sessions; and engaging with compliance experts and other industry stakeholders.

OFSI amends Companies House general licence

OFSI has amended the Companies House general licence, which allows UK designated persons or persons acting on behalf of designated persons to make certain payments to Companies House.

The list of permitted payments has been expanded to include:

• the payment of fees owed by or due from UK designated persons to Companies House for filing an overseas entity update statement in respect of entities on the Register of Overseas Entities; and
• the payment of penalty fees owed by or due from UK designated persons to Companies House as a result of failure to register entities on the Register of Overseas Entities, or failure to provide an overseas entity update statement.

Updated guidance on reporting export control breaches

The UK government has updated its guidance on licensing requirements, restrictions for trade control, and export controls for military goods, software and technology.

The guidance clarifies that where exporters identify irregularities during a compliance audit, including those conducted by the Export Control Joint Unit, it should be reported to HM Revenue and Customs as soon as possible.

Where exporters have exported strategic/sanctioned goods, transferred controlled technology without an export licence or imported goods subject to sanctions, a voluntary disclosure should also be made to HM Revenue and Customs.