UK Weekly Sanctions Update - Week of September 9, 2024

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 specifies ten ships under the Russia sanctions regime:  On September 11, 2024, the UK Government specified ten ships under the Russia sanctions regime.  According to the FCDO, these sanctions target Russia's "shadow fleet", which use illicit practices to avoid sanctions targeting Russian oil. These ships are now barred from entering UK ports and will be refused access to the UK Ship Register. (The UK Sanctions List - GOV.UK (www.gov.uk)).
• UK Government adds three entries to the UK sanctions list and specifies five ships under the Russia regime:  On September 10, 2024, the UK Government added three entities, namely 924^th State Center for Unmanned Aviation, Command of the Military Transport Aviation and Russian Aerospace Forces, to the UK Sanctions List under the Russia regime.  The UK Government also specified five ships.  According to the FCDO, those designated and specified are involved in Iran’s military support to Russia, including parties involved in ballistic missile and drone supply chains. (Notice_Russia_100924.pdf (publishing.service.gov.uk)).

2. Iran Sanctions

• UK Government updates Iran sanctions regime: On September 13, 2024, the Iran (Sanctions) (Amendment) Regulations 2024 came into force. These regulations amended the UK’s Iran sanctions regime inter alia to expand prohibitions that target unmanned aerial vehicles to cover goods and technology of strategic concern (as defined within the updated regulations). (https://www.legislation.gov.uk/uksi/2024/944/made).
• UK Government adds seven entries to the UK sanctions list under the Iran regime:  On September 10, 2024, the UK Government added three individuals, namely Seyed Ghalandari, Ali Jafarabadi and Majid Mousavi, and four entities, namely Baharestan Kish Company, Chekad Sanat Faraz Asia, Saad Sazeh Faraz Sharif and The Anzali Free Trade Industrial Zone Organisation, to the UK sanctions list under the Iran regime. According to the FCDO, those designated and specified are involved in Iran’s military support to Russia, including parties involved in ballistic missile and drone supply chains. (Notice Iran 100924.pdf (publishing.service.gov.uk)).

3. Mali and Counter-Terrorism Sanctions

• UK Government updates Mali and Counter-Terrorism sanctions regime: On September 12, 2024, the UK Government laid before Parliament the Mali (Sanctions) (EU Exit) (Amendment) and Sanctions (Miscellaneous Amendments) Regulations 2024 (Regulations).  Among other things, these Regulations include additional purposes for which the Secretary of State considers the Mali regime to be appropriate, expand the designation criteria under the Mali regime, and provide for director disqualification licensing.  The latter licensing provision will also be added to the UK’s Counter-Terrorism sanctions regime. The Regulations come into force on October 3, 2024. (https://www.legislation.gov.uk/uksi/2024/946/made).

4. Other Sanctions

• UK Government publishes civil monetary penalty guidance in relation to UK transport sanctions: On September 13, 2024, the UK’s Department for Transport (DfT) published civil monetary penalty guidance in relation to UK transport sanctions.  DfT acquired the power to issue civil monetary penalties in relation to breaches of shipping and aircraft sanctions under the Trade Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024.  The guidance sets out inter alia DfT’s approach to case assessment and enforcement. (Transport sanctions: civil monetary penalties - GOV.UK (www.gov.uk)).
• UK Government launches Office of Trade Sanctions Implementation (OTSI):  On September 12, 2024, the UK Government published the regulatory framework providing the scope and powers of the (OTSI), the authority responsible for the implementation and enforcement of certain trade sanctions in the United Kingdom.  Pursuant to the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, which comes into force on 10 October 2024, OTSI will be empowered to impose civil monetary penalties and require information disclosure, similar to OFSI.  Certain persons in the financial, legal, shipping and aviation sectors will also be subject to reporting obligations (https://www.mayerbrown.com/en/insights/publications/2024/09/uk-government-launches-office-of-trade-sanctions-implementation-to-enforce-uk-trade-sanctions;  Trade sanctions: civil enforcement - GOV.UK (www.gov.uk; https://www.legislation.gov.uk/uksi/2024/948/contents/made).
• UK Government issues compound settlements totalling in excess of £348,000 during Q2 of 2024: On September 11, 2024, the UK Government issued a Notice to Exporters reporting that HM Revenue and Customs had issued compound settlement offers to two UK exporters totalling in excess of £348,000 during Q2 of 2024.  The settlements related to the unlicensed transfer of dual-use goods and the unlicensed export of military goods respectively. (https://www.gov.uk/government/publications/notice-to-exporters-202422-second-quarter-compound-settlements/nte-202422-second-quarter-compound-settlement).
• UK Government publishes 2024 Frozen Asset Reporting notice: On September 11, 2024, the Office of Financial Sanctions Implementation (OFSI) published a notice requesting that all persons that hold or control funds of economic resources belonging to, owned, held or controlled by a designated person to report by November 11, 2024, such frozen assets and their value as at 30 September 2024. (Financial_Sanctions_Notice__2024_.pdf (publishing.service.gov.uk); https://www.gov.uk/government/publications/annual-frozen-asset-review-and-reporting-form).
• ECJU Annual Symposium to take place on October 15, 2024: On September 6, 2024, the Export Control Joint Unit (ECJU) announced that it will host its annual symposium in London on October 15, 2024. Registration is open for this annual event. (https://www.gov.uk/government/publications/export-control-training-bulletin/export-control-training).