UK Weekly Sanctions Update - Week of February 26, 2024 | Insights

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 Government issues General Trade Licence relating to Russian diamonds and updates related guidance: On March 1, 2024, the UK Government issued a General Trade Licence relating to dealings in certain diamonds processed outside of Russia prior to 1 March 2024. At the same time, the UK Government updated its guidance on third country processed Russian diamond measures noting inter alia that (i) traders should be prepared to provide documentation evidencing the weight of the diamonds, the country of origin, the date the diamonds left their country of origin, and the country and facility where processing took place; and (ii) individual licences may be granted by the Department for Business and Trade for the import of certain Russian diamonds if it relates to the execution of obligations arising from contracts concluded before 1 March 2024. (https://www.gov.uk/government/publications/general-trade-licence-for-sanctioned-russian-diamonds-processed-in-third-countries/general-trade-licence-for-sanctioned-russian-diamonds-processed-in-third-countries; https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/guidance-on-third-country-processed-russian-diamonds-measures)

UK Government amends one entry on the UK sanctions list under the Russia regime: On March 1, 2024, the UK Government made a correction to the entry for Vladimir Vladimirovich Mikheychik under the Russia sanctions regime. This individual remains subject to an asset freeze and trust services sanctions. (Notice_Russia_01032024.pdf (publishing.service.gov.uk))
UK Government amends one entry on the UK sanctions list under the Russia regime: On February 28, 2024, the UK Government made one administrative amendment to the entry for Ilya Borisovich Brodskiy under the Russia sanctions regime. This individual remains subject to an asset freeze, travel ban, trust services sanctions, and transport sanctions. (https://www.gov.uk/government/publications/the-uk-sanctions-list)
UK Court of Appeal rejects appeal on de-listing challenges: On February 27, 2024, the UK Court of Appeal rejected appeals against the judgments in Dalston Projects Ltd and Eugene Shvidler v FCDO ([2024] EWCA Civ 172). This was the first Court of Appeal judgment to consider the proper approach to sanctions challenges in the UK, in particular on the grounds of proportionality. . The Court upheld the rejection of Eugene Shvidler’s challenge to his sanctions designation and the challenge by Sergei Naumenko and Dalston Projects Ltd to the detention of superyacht Phi under the UK’s Russia sanctions regulations. (Dalston Projects Lt & Ors v Secretary of State for Transport [2024] EWCA Civ 172 (27 February 2024) (bailii.org))
UK Government amends general licence for Russian iron and steel imports: On February 26, 2024, the UK Government amended the General Trade Licence for sanctioned iron and steel to permit the import of Russian iron and steel products manufactured or produced before 23 June 2023 (this date was previously 21 April 2023). (General Trade Licence for sanctioned iron and steel - GOV.UK (www.gov.uk))

2. Democratic Republic of the Congo Sanctions

UK Government amends one entry to the UK sanctions list under the DRC regime: On February 28, 2024, the UK Government made one administrative amendment to the entry for Ahmad Mahmood Hassan under the Democratic Republic of the Congo sanctions regime. This individual remains subject to an asset freeze and travel ban. (https://www.gov.uk/government/publications/the-uk-sanctions-list)

3. Iran Sanctions

UK Government adds five entries to the UK sanctions list under the Iran regime: On February 27, 2024, the UK Government, in a coordinated effort with the US, sanctioned two individuals and three organisations under the Iran sanctions regime for their role in providing financial or military support to the Houthis and undermining regional stability. The sanctioned parties are: (i) Mohammad Reza Fallahzadeh; (ii) Sa'id Al-Jamal; (iii) Islamic Revolutionary Guard Corps Quds Force (IRGC-QF) Unit 190; (iv) Islamic Revolutionary Guard Corps Quds Force (IRGC-QF) Unit 6000; and (v) Islamic Revolutionary Guard Corps Quds Force (IRGC-QF) Unit 340. (Notice_Iran_270224.pdf (publishing.service.gov.uk))

4. ISIL (Da'esh) and Al-Qaida Sanctions

UK Government adds one entry to the UK sanctions list under the ISIL (Da'esh) and Al-Qaida regime: On March 1, 2024, the UK Government made a correction to the entry for KHATIBA AL-TAWHID WAL-JIHAD (KTJ) under the ISIL (Da'esh) and Al-Qaida regime. This individual remains subject to an asset freeze and trust services sanctions. (Notice_ISIL__Da_esh__and_Al-Qaida_010324.pdf (publishing.service.gov.uk))

5. Yemen Sanctions

UK Government adds one entry to the UK sanctions list under the Yemen regime: On February 27, 2024, the UK Government sanctioned Ali Hussein Badr Al Din Al-Houthi, a Houthi security minister under the Yemen Regime, for threatening the peace, security and stability of Yemen by supporting attacks against shipping in the Red Sea. (Notice_Yemen_270224.pdf (publishing.service.gov.uk))

6. Other Sanctions

OFSI issues general licence for Court Funds Office payments: On February 29, 2024, OFSI issued General Licence INT/2024/4398024 authorising the payment of monies owned to designated persons into any civil court in the UK pursuant to a court order, subject to certain reporting and record-keeping obligations. (INT-2024-4398024_PN.pdf (publishing.service.gov.uk)) (INT-2024-4398024.pdf (publishing.service.gov.uk))
OFSI amends general licence relating to payments to energy companies: On February 29, 2024, OFSI amended General Licence INT/2022/2300292 relating to payments to energy companies. Among other things, payments for gas and electricity meter installation, certification, validation, monitoring, replacement and removal have been added to the list of payments permitted under the general licence, subject to the terms therein (https://assets.publishing.service.gov.uk/media/65e08cfd3f69450011035fdb/Gas_and_Electric_INT.2022.2300292_29.02.24_PN.pdf; https://assets.publishing.service.gov.uk/media/65e08cf02f2b3b001c7cd78b/Gas_and_Electric_INT.2022.2300292_GL.pdf)
OFSI updates its maritime shipping guidance: On February 28, 2024, OFSI published updated guidance for the maritime shipping sector. Among other things, the guidance provides information on: (i) due diligence; (ii) common evasion practices; (iii) high-risk countries and territories; and (iv) maritime insurance. The updated guidance covers new tactics used by illicit actors to evade UK financial sanctions and offers recommendations for implementing additional due diligence practices. (OFSI refreshes its guidance for the maritime sector - Office of Financial Sanctions Implementation (blog.gov.uk))
OFSI publishes guidance on licensing principles and delegation frameworks: On February 27, 2024, OFSI published a blog post providing information on how OFSI makes licensing decisions. Among other things, OFSI outlined its licensing process and published certain licensing principles that relate to licence applications relating to designated individuals under all UK financial sanctions regimes. (An update on OFSI's licensing process and policies - Office of Financial Sanctions Implementation (blog.gov.uk)) (UK financial sanctions guidance - GOV.UK (www.gov.uk))
HM Treasury updates money laundering advisory notice: On February 26, 2024, HM Treasury updated its Money Laundering Advisory Notice: High Risk Third Countries, which provides guidance on the risks posed by jurisdictions with unsatisfactory money laundering and terrorist financing controls. The advisory notice was updated to reflect changes to the countries in scope of high risk third countries, as defined in the Money Laundering Regulations, following updates to the lists of the Financial Action Task Force at its plenary meeting in February 2024. (Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK (www.gov.uk))