UK Sanctions Weekly Update – Week of September 11, 2023

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 proscribes Wagner Group as terrorist organization: On September 15, 2023, the UK Government proscribed the Wagner Group as a terrorist organisation. Actively supporting and/or belonging to the Wagner Group is now a criminal offence that could be punished by imprisonment of up to 14 years and/or a fine. (https://www.gov.uk/government/news/wagner-group-proscribed)
• The UK and US extend Sakhalin-2 Project sanctions exemption: On September 14, 2023, the UK Government amended General Licence INT/2022/2470156 to extend the exemption of oil originating in or consigned from Sakhalin-2 from the oil price cap until 28 June 2024. The relevant part of the General License authorises the supply or delivery of Russian oil (and the provision of related services) originating in or consigned from Sakhalin-2 from a place in Russia to a place in Japan. (Oil_Price_Cap_General_Licence_Publication_Notice.pdf (publishing.service.gov.uk) (General Licence INT/2022/247/0156)
• UK Lords committee calls for evidence on UK-EU cooperation on sanctions for inquiry: On September 12, 2023, the UK House of Lords European Affairs Committee launched an inquiry into the long-term implications for the UK of the EU’s foreign and security policy response to the Russian invasion of Ukraine, including UK-EU cooperation on sanctions, and their enforcement and effectiveness. The Committee has issued a call for evidence, inviting interested individuals and organisations to submit written evidence to the inquiry by 27 October 2023. The Committee is encourages anyone with expertise in or experience of the matters under consideration in its inquiry to submit written evidence. (Implications of Russia’s invasion of Ukraine for UK-EU relations - Committees - UK Parliament) (Call for Evidence - Committees - UK Parliament)
• UK government provides guidance on Russian iron and steel processed in third countries: On 8 September, 2023, the UK Government published guidance on the scope of the measures related to Russian iron and steel processed in third countries (which will come into force on 30 September 2023). The notice sets out inter alia: (i) what evidence traders need to provide to demonstrate compliance; (ii) what constitutes an “iron and steel” product; (iii) examples of how the rules may be applied in practice; and (iv) corresponding licensing provisions. (Guidance on third country processed iron and steel measures - GOV.UK (www.gov.uk))

2.  Iran Sanctions

• The UK Government has sanctioned 5 individuals under the Iran Sanctions Regime: On September 15, 2023, the UK announced the addition of 5 Iranian individuals to the sanctions list for serious human rights violations or abuses. The individuals sanctioned are: (i) Saeed Montazer Al-Mahdi, (ii) Arvan Cloud, (iii) Mohammad Mehdi Esmaili, (iv) Mohammad Hashemi and (v) Alireza Zakani. (‘I commend their bravery’: Foreign Secretary recognises bravery of Iranian people on anniversary of Mahsa Amini death - GOV.UK (www.gov.uk)) (Notice_Iran__Human_Rights__150923.pdf (publishing.service.gov.uk))
• The UK government is to bring UN sanctions on Iran into UK law: On September 14, 2023, the UK government announced that, along with France and Germany, it will transfer UN sanctions on Iran into its domestic regime and maintain existing UK sanctions beyond the October deadline included in nuclear deal. The UK, France and Germany have stated that this is a ‘legitimate and proportionate’ action in response to the Iranian regime breaching commitments under the nuclear deal and advancing its nuclear programme beyond all credible civilian justification, and is an important step in their commitment to prevent Iran from developing nuclear weapons. Under the Joint Comprehensive Plan of Action (JCPoA), a range of UN, EU and UK sanctions were due to be lifted on October 18th. These include sanctions on individuals and entities involved in Iran’s missile, nuclear, and other weapons programs. (UK to bring UN sanctions on Iran into UK law - GOV.UK (www.gov.uk))