UK Weekly Sanctions Update - Week of October 28, 2024

1. Russia Sanctions

• UK Government updates licensing grounds described in Russia trade sanctions guidance: On October 31, 2024, the UK Government removed the following licensing ground from its trade sanctions guidance in relation to the provision of professional and business services to Russia: services to a person connected with Russia by a UK parent company or UK subsidiary of that parent company. (https://www.gov.uk/guidance/apply-for-a-licence-to-provide-sanctioned-trade-services#licensing-grounds; Russia sanctions: guidance - GOV.UK)
• UK Government adds six new entries to the UK sanctions list under the Russia regime: On October 28, 2024, the UK Government added Ilya Andreevich Gambashidze, Andrey Naumovich Perla, Nikolai Aleksandrovich Tupikin, Ano Dialog, Social Design Agency, and Structura National Technologies to the UK Sanctions List under the Russia Regime.  According to the UK Government, these persons have been involved in seeking to undermine and destabilise Ukraine and its democracy. (https://assets.publishing.service.gov.uk/media/671f8af0a85de589558d5db9/Notice_Russia_281024.pdf; https://www.gov.uk/government/news/uk-sanctions-putins-interference-actors)

2. Myanmar Sanctions

• UK Government adds six entries to the UK sanctions list under the Myanmar regime: On October 29, 2024, the UK Government added six entities to the UK sanctions list under the Myanmar regime in partnership with the EU and Canada.  These sanctions target the Myanmar military’s access to military materiel, equipment and funds and, in particular, will help to constrain the Myanmar military’s ability to conduct airstrikes on civilians, which, according to the UK government, amount to gross human rights violations. (https://assets.publishing.service.gov.uk/media/6720cb4c10b0d582ee8c47bb/Notice_Myanmar_29102024.pdf)

3. Other

• SRA publishes annual AML report covering law firm compliance with financial sanctions:  On October 30, 2024, the UK’s Solicitors Regulation Authority (SRA) published its annual report on anti-money laundering, which includes a review of law firms’ compliance with financial sanctions in 2023-24.  Across 55 sanctions inspections conducted by the SRA, 40 firms were compliant, 6 were partially compliance, and 9 were referred for investigation over non-compliance. (https://www.sra.org.uk/sra/research-publications/aml-annual-report-2023-24/)
• UK Government publishes reminder of 2024 Frozen Asset Reporting deadline: On October 29, 2024, the Office of Financial Sanctions Implementation (OFSI) published a reminder that all persons that hold or control funds of economic resources belonging to, owned, held or controlled by a designated person much report by November 11, 2024, such frozen assets and their value as at 30 September 2024. (Annual frozen asset review and reporting form - GOV.UK; https://www.linkedin.com/posts/office-of-financial-sanctions-implementation_every-year-hm-treasury-carries-out-a-review-activity-7256974922617352192-rQre/)
• UK Government amends General Licence relating to payments to energy companies: On October 29, 2024, the UK Government amended General Licence INT/2022/2300292, which authorises certain payments to energy companies for gas and/or electricity under the UK’s autonomous sanctions regimes.  Among other things, the amendments to the General Licence: (i) clarify that the definition of "Designated Persons" includes entities owned or controlled by a designated individual or entity and excludes those designated for the purposes of compliance with the United Nations obligations; (ii) update the definition of "Permitted Payments"; and (iii) update the schedule of UK autonomous sanctions regimes to which the General Licence applies. (OFSI_Gas_and_Electricty_GL_-_INT-2022-2300292_-_Publication_Notice_-_October_2024.pdf)