UK Weekly Sanctions Update - Week of June 17, 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 updates Maritime Services Ban and Oil Price Cap Guidance: On June 21, 2024, OFSI upgraded the UK Maritime Services Ban and Oil Price Cap Industry Guidance into its new digital guidance format. (UK Maritime Services Ban and Oil Price Cap Industry Guidance - GOV.UK (www.gov.uk)).
• UK translates ‘Russia Sanctions – Common High Priority Items List’ into Russian and Turkish: On June 19, 2024, the UK made available versions of its ‘Russia Sanctions – Common High Priority Items List’ in Russian and Turkish. (Russia Sanctions – Common High Priority Items List - GOV.UK (www.gov.uk)).

2. Iran Sanctions

• UK Court of Appeal refuses application to strike out Iran sanctions claim: On June 17, 2024, the UK Court of Appeal dismissed Standard Chartered plc’s (“SC”) appeal against a 2023 High Court decision relating to a long-standing case that SC had violated US sanctions in a more widespread way that previously admitted. More than 200 investors are suing SC for allegedly untrue statements concerning its sanctions non-compliance between 2007 and 2019. In 2019, the London-based bank agreed to pay $1.1 billion to US and UK authorities over transactions which breached sanctions against Iran and other countries. However, the investors allege "industrial-scale sanctions non-compliance" by SC beyond what the bank admitted to regulators. (StanChart loses bid to cut US sanctions breach claims from UK lawsuit | Reuters; https://www.bailii.org/ew/cases/EWCA/Civ/2024/674.html).

3. Libya Sanctions

• UK updates financial sanctions guidance for Libya: On June 21, 2024, OFSI upgraded its financial sanctions guidance for Libya into its new digital guidance format. (Financial sanctions guidance for Libya - GOV.UK (www.gov.uk)).

4. Other sanctions

• UK Government publishes notice to exporters noting temporary issues with customs declaration service (CDS): On June 21, 2024, the UK Government published a notice to exporters noting that HMRC are aware of some temporary issues with licence data flows between CDS and the Department for Business and Trade electronic licensing systems (SPIRE/LITE), namely when a CDS exports declaration contains errors which impacts the licence. The notice provides guidance on how to respond to this issue.  (https://www.gov.uk/government/publications/notice-to-exporters-202414-customs-declaration-service-cds-exhaustion-in-error-guidance/nte-202414-customs-declaration-service-cds-exhaustion-in-error-guidance).
• UK updates financial sanctions guidance for charities and NGOs: On June 21, 2024, OFSI upgraded its financial sanctions guidance for charities and NGOs into its new digital guidance format. (Financial sanctions guidance for charities and non-governmental organisations (NGOs) - GOV.UK (www.gov.uk)).
• UK updates financial sanctions guidance for importers and exporters: On June 21, 2024, OFSI upgraded its financial sanctions guidance for importers and exporters into its new digital guidance format. (Financial sanctions guidance for importers and exporters - GOV.UK (www.gov.uk)).
• OFSI issues General Licence authorising certain payments to the FCA: On June 20, 2024, OFSI issued General Licence INT/2024/4836676 to authorise payments to the FCA from, or on behalf of, a designated person subject to certain terms and conditions. (Payments_to_the_FCA_GL.pdf (publishing.service.gov.uk)).