UK Weekly Sanctions Update - Week of March 4, 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 Government increases the deadline for providing certain information in relation to the Maritime Services Ban and Oil Price Cap Exception: On March 8, 2024, the UK Government increased the deadline for providing additional attestations or itemised ancillary costs from 28 days to 30 days.  The UK’s industry guidance on oil price cap, oil price cap general licence and related reporting forms have been updated to reflect this.. (Russian Oil Services ban - GOV.UK (www.gov.uk)).
• UK Government revokes one entry on the UK sanctions list under the Russia Regime: On March 5, 2024, the UK Government revoked Igor Viktorovich Makarov entry on the UK sanctions list.  Mr Makarov is no longer subject to an asset freeze, travel ban, transport sanctions, or trust services sanctions. (Notice_Russia_050324.pdf (publishing.service.gov.uk)).

2. Iran Sanctions

• UK Government publishes guidance for UK businesses on doing business in Iran: On March 4, 2024, the UK published guidance for UK businesses on doing business in Iran.  Among other things, the guide declares the UK government’s support of sanctions-compliant trade with Iran and lists the certain sectors where there are export opportunities for UK businesses in Iran (including agriculture, healthcare, food and drink).  (Doing business in Iran: trade and export guide - GOV.UK (www.gov.uk)).

3. Other Sanctions

• Upcoming OFSI webinars on maritime-related sanctions: At 3pm GMT on March 14, 2024, and March 21, 2024, respectively, OFSI will hold webinars on the UK’s maritime-related sanctions covering inter alia due diligence and common evasion practices. (https://www.eventbrite.co.uk/e/ofsi-the-maritime-sector-tickets-828453826697?aff=ebdsoporgprofile; https://www.eventbrite.co.uk/e/ofsi-the-maritime-sector-tickets-828459874787?aff=ebdsoporgprofile).
• Post-Legislative Scrutiny Memorandum: Sanctions and Anti-Money Laundering Act 2018: On March 4, 2024, the UK Government published a memorandum that provides a summary and preliminary assessment of the provisions and implementation of the Sanctions and Anti-Money Laundering Act 2018.  In respect of UK sanctions targeting Russia, the memorandum notes that the UK has amended the Russia (Sanctions (EU Exit) Regulations 2019 more than 20 times since Russian’s full-scale invasion of Ukraine, increasing the number of UK Russia designations to more than 1900 as well as introducing new sanctions measures in key sectors such as finance, energy and professional services. (Post_Legislative_Scrutiny_Memorandum_Sanctions_and_Anti_Money_Laundering_Act_2018 (publishing.service.gov.uk)).
• UK Treasury Committee launches a new inquiry into the effectiveness of Russia sanctions: On February 29, 2024, the UK Treasury Committee announced the launch of a new inquiry into whether the UK’s programme of economic sanctions is achieving its goal of impeding Putin’s ability to fund Russian armed forces. The committee will scrutinise the work of OFSI, while MPs will be assessing the extent to which it is possible to seize frozen Russian assets and investigate questions such as whether sanctions should be broadened to include any entities buying Russian oil and gas. The deadline for submissions is March 28, 2024. (New Treasury Committee inquiry launch: are the UK’s financial sanctions on Russia working? - Committees - UK Parliament)