UK Sanctions Weekly Update – Week of October 23, 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 amends General Licence for continuation of business and various media services: On October 27, 2023, OFSI amended General Licence INT/2022/1875276 (Continuation of Business and Basic Needs for Telecommunications Services and News Media Services), among other things extending the licence to 30 May. (INT20221875276_General_Licence.pdf (publishing.service.gov.uk))
• OFSI frozen assets reporting – deadline 10 November: On October 27, 2023, OFSI issued a reminder that any person which holds or controls funds or economic resources belonging to, owned, held, or controlled by a designated person they are required to submit a report to HM Treasury’s OFSI by Friday 10 November 2023. The report should include the value of such assets as at 29 September 2023. (Financial_Sanctions_Notice__2023_.pdf (publishing.service.gov.uk))
• UK Government updates UK sanctions list under Russian Sanctions: On October 26, 2023, the UK Government made two administrative amendments under the Russia sanctions regime to update the listings for Veniamin Ivanovich Kondratyev and Nikolai Fyodorovna Kondratyuk. Both of these individuals remain subject to an asset freeze, travel ban, and trust services sanctions. (Notice_Russia_261023.pdf (publishing.service.gov.uk)
• UK High Court rejects Fridman’s challenge to OFSI’s licence refusals: On October 26, 2023, the UK High Court rejected Mikhail Fridman’s application to set aside OFSI’s decision to refuse to grant him three licences for his property, Athlone House, and its management company, AHL. As well as determining that OFSI had properly assessed the licence applications, the judgment inter alia confirmed that OFSI has discretion as to whether or not to grant a licence by reference to the material that was before OFSI at the time of the decision, and encouraged OFSI to consider publishing certain internal guidance. (Fridman, R (On the Application Of) v HM Treasury [2023] EWHC 2657 (Admin) (26 October 2023) (bailii.org))
• OFSI introductory webinar on 2 November 2023: OFSI is holding a one hour webinar at 10am (GMT) on Thursday 2 November 2023 in which it will explain its role and powers “to ensure that financial sanctions are properly understood, implemented and enforced in the United Kingdom”.  Register at https://www.eventbrite.co.uk/e/understanding-ofsi-an-introductory-webinar-tickets-726012401637?aff=oddtdtcreator.New OFSI General Licence for legal services coming into force: On October 25, 2023, OFSI announced that the new General Licence INT/2023/3744968, under the Russia and Belarus regulations, for Legal services will replace the current licence INT/2023/2954852 from October 29, 2023. The new licence makes several changes to rules governing the provision of legal services, most notably in respect of the expenses cap, which has been doubled in respect of professional legal fees and counsel’s fees. The licence also sets out certain requirements for the reporting of legal services. (Legal_Services_GL_INT.2023.3744968.pdf (publishing.service.gov.uk))

2.  Iran Sanctions

• UK Government UK amends Iran listings: On October 26, 2023, the UK Government amended the identification information for Farasakht Industries, Imensazan Consultant Engineers Institute, Rahab Engineering Institute, and Mehrdada Akhlaghi Ketabachi on the UK consolidated sanctions list. (Notice_Iran__Nuclear__261023.pdf (publishing.service.gov.uk))

3.  Democratic Republic of Congo (DRC) Sanctions

• UK Government adds two new sanctions listings under DRC Sanctions: On October 26, 2023, the UK Government added two new designations under the DRC sanctions regime, imposing asset freezes against Protogene Ruvugayimikore and Bernard Maheshe Byamungu. (Notice_Democratic_Republic_of_the_Congo_261023.pdf (publishing.service.gov.uk))

4.  Haiti Sanctions

• UK Government amends designation under Haiti Regime: On October 23, 2023, the UK Government made an administrative change to the entry for Jimmy Cherizier under the Haiti sanctions regime, enacting a UN decision to amend this entry. (Notice_Haiti_231023.pdf (publishing.service.gov.uk))