UK Weekly Sanctions Update - Week of January 6, 2025

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.

Russia Sanctions

• UK Government adds two Russian oil companies to the UK sanctions list under the Russia regime: On January 10, 2025, OFSI added PJSC Surgutneftegas and Gazprom Neft to the UK sanctions list under the Russia regime.  According to the UK Government, these sanctions target entities involved in supporting the Government of Russia by carrying on business in a sector of strategic and economic significance to the Government of Russia, namely the Russian energy sector. The entities are large Russian oil companies which are involved in oil exploration, production, and development. (Notice_Russia_100125.pdf; Support for Ukraine is unwavering as UK announces new sanctions on Russian oil giants - GOV.UK).
• OFSI issues General Licence relating to Russian oil exempt projects: On January 10, 2025, OFSI issued General Licence INT/2025/5635700, which authorises the continuation of business operations with certain Russian energy companies in connection Sakhalin-2, subject to certain terms and conditions. (INT.2025.5635700_PN.pdf; INT.2025.5635700_GL.pdf).
• OFSI issues wind down General Licence relating to Gazprom Neft and PJSC Surgutneftegas: On January 10, 2025, OFSI issued General Licence INT/2025/5635701, which authorises the wind down or divestment of positions involving Gazprom Neft, PJSC Surgutneftegas and/or any entity owned or controlled by Gazprom Neft and PJSC Surgutneftegas, subject to certain terms and conditions. The general licence expires on February 27, 2025. (INT.2025.5635701_PN.pdf; INT.2025.5635701_GL.pdf).
• OFSI amends General Licence relating to VTB Capital plc: On January 8, 2025, OFSI amended General Licence INT/2022/1280876 to add Permission 5.3A, which states inter alia that no distributions on VTB Bank PJSC’s  claim should be made without first deducting from the distributions the value of any VTB Capital plc assets which have been or are subject to VTB Bank PJSC enforcement action.  The General Licence expires on 3 April 2030. (INT.2022.1280876_GL_08.01.2025.pdf).
• UK Government amends two entries on the UK sanctions list under the Russia regime: On January 8, 2025, the UK Government updated the entries for Zapchasttrade LLP and Vyacheslav Vladimirovich Ruksha on the UK sanctions list under the Russia regime.  Each remains subject to an asset freeze.  (https://assets.publishing.service.gov.uk/media/677fa9ec99c93b7286a3983b/Notice_Russia_090125.pdf).
• OTSI publishes Russian sanctions circumvention and “no Russia clause” guidance:  On January 7, 2025, the UK Government published new guidance for exporters on countering Russian sanctions evasion.  The guidance includes: information on the range of goods at heightened risk of being diverted to Russia; red flag indicators of potential sanctions evasion via circumvention; suggestions for compliance best practice and enhanced due diligence procedures; and additional resources to aid businesses in managing their risk and meeting their compliance obligations. The UK Government also published “No-Russia clause” guidance, which aims to support businesses in tailoring due diligence within exporter contracts and support those wishing to insert a “no re-export to Russia” clause. (https://www.gov.uk/government/publications/countering-russian-sanctions-evasion-and-circumvention/countering-russian-sanctions-evasion-guidance-for-exporters; https://www.gov.uk/government/publications/no-russia-clause/no-russia-clause-guidance).

Libya Sanctions

• UK Government removes one entry from the UK sanctions list under the Libya sanctions regime: On January 2, 2025, the UK Government removed Abdelhafiz Zlitni, a Libyan Government official, from the UK sanctions list under the Libya sanctions regime.  Abdelhafiz Zlitni is no longer subject to an asset freeze.  (Notice_Libya_020125.pdf).

Venezuela Sanctions

• UK Government adds 15 entries to the UK sanctions list under the Venezuela sanctions regime: On January 10, 2025, OFSI added 15 entries to the UK sanctions list under the Venezuela sanctions regime.  The new designations target individuals associated with Nicolás Maduro’s contested regime and include judges on the Supreme Tribunal of Justice, members of the security forces and military officials.  According to the UK Government, these individuals are “responsible for undermining democracy, the rule of law, and human rights violations.” (UK announces new sanctions targeting Nicolás Maduro’s regime in Venezuela - GOV.UK; Notice_Venezuela_100125.pdf).

Counter-Terrorism (Domestic) Sanctions

• UK Government adds one entry to the UK sanctions list under the Counter-Terrorism (Domestic) regime: On January 8, 2025, OFSI added Blood and Honour to the UK sanctions list under the Counter-Terrorism (Domestic) regime.  According to the UK Government, Blood and Honour are suspected as "being involved in terrorist activities through promoting and encouraging terrorism, seeking to recruit people for that purpose and making funds available for the purposes of its terrorist activities".  This designation marks the first use of the UK Government's Domestic Counter-Terrorism sanctions regime to target extreme right-wing terrorism. (Notice_Counter_Terrorism__Domestic__080125.pdf; Extreme Right Wing group sanctioned by HM Treasury under Domestic Counter-Terrorism Regulations - GOV.UK).

Other sanctions

• OFSI amends General Licence relating to payments for Statutory Audits: On January 10, 2025, OFSI amended paragraph 4 of General Licence INT/2024/4888228 to clarify that Statutory Auditors may receive Permitted Payments (as defined in the General Licence) made by UK designated persons or persons acting on behalf of designated persons. (INT.2024.4888228_GL_Amended.pdf).
• UK Government announces plans for new migration sanctions regime:  On January 8, 2025, the UK Government announced plans to launch a new migration sanctions regime in 2025.  According to the UK Government, the new regime will be designed to crack down on people smuggling ringleaders and their networks and forms part of a wider policy of deterring criminal syndicates from exploiting vulnerable people.  (UK to launch world first sanctions regime to snare people smugglers travelling upstream - GOV.UK).
• OFSI announces webinars to support high value dealers and art market participants: On January 6, 2025, OFSI announced two upcoming webinars and Q&A sessions for the High Value Dealer and Art Market sector.  The sessions will provide an overview of OFSI’s sector-specific guidance that was published in November 2024, as well as related reporting requirements. The webinars will take place on January 16 and January 23 (registration pages linked). (https://www.gov.uk/government/publications/high-value-dealers-art-market-participants-guidance/financial-sanctions-guidance-for-high-value-dealers-art-market-participants).