UK Weekly Sanctions Update - Week of January 22, 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 adds Russian-based cyber hacker under Cyber regime: On January 23, 2024, the UK Government, in a coordinated effort with Australia and the US, designated a Russian-based cyber hacker under the Cyber (Sanctions) (EU Exit) Regulations 2020 Regime, for their involvement in the compromise of Medibank that resulted in the subsequent leak of sensitive medical records. Aleksandr Gennadievich Ermakov is now subject to an asset freeze and travel ban. (https://assets.publishing.service.gov.uk/media/65af98598bbe95000e5eb27d/Notice_Cyber_230124.pdf; UK and allies sanctions Russian cyber hacker - GOV.UK (www.gov.uk)).

2. Yemen Sanctions

• UK Government adds four entries to UK sanctions list under Yemen regime: On January 25, 2024, the UK Government designated 4 individuals affiliated with ongoing efforts to disrupt international shipping in the Red Sea, under the Yemen Sanctions Regime. The individuals are: (i) Mohamed Nasser Al-Atifi; (ii) Muhammad Ahmad al-Talibi; (iii) Muhammad Ali Al-Qadari; and (iv) Muhammad Fadl Abd Al-Nabi, all of who are now subject to an asset freeze, targeted arms embargo, and travel ban. (Notice_Yemen_250124.pdf (publishing.service.gov.uk)) (UK and US sanction key Houthi figures to protect maritime security in the Red Sea - GOV.UK (www.gov.uk)).

3. Counter Terrorism Sanctions

• UK Government designates six parties affiliated with Hamas under Counter Terrorism regime: On January 22, 2024, the UK Government, as part of a coordinated effort with the United States and Australia, announced new sanctions on six key parties associated with Hamas and Palestinian Islamic Jihad (PIJ).  The parties were: (i) Zuheir Shamlakh; (ii) Ahmed Sharif Abdallah Odeh; (iii) Ismail Barhoum; (iv) Hassan Al-Wardian; (v) Jamil Yusuf Ahmad Aliyan, and (vi) Al Mutahadun for Exchange. (UK, US and Australia sanction key figures in Hamas’s financial network - GOV.UK (www.gov.uk)).

4. Other Sanctions

• UK SRA publishes sanctions risk assessment guidance for law firms: On January 23, 2024, the Solicitors Regulation Authority (SRA) published guidance for law firms on their legal and regulatory obligations in relation to sanctions.  The guidance is aimed to help firms assess their exposure to risks associated with the UK's sanctions regimes and sets out inter alia: (i) who is at risk of becoming involved in sanctions breaches; (ii) why it is important to have a firm wide risk assessment; (iii) what a sanctions risk assessment should look like; and (iv) tips for completing a risk assessment. (SRA | Sanctions regime - firm-wide risk assessments | Solicitors Regulation Authority).
• UK NCA issues amber alert on sanctions evasion risks through the art storage sector: On 23 January 2024, the UK National Crime Agency issued an amber alert highlighting the sanctions evasion risks presented to UK industries linked to the art storage sector. The alert highlights how criminals are using the art market to engage in criminal activity and describes inter alia key indicators and useful questions in respect of changes in client circumstances, such as attempts to transfer artwork to an intermediary and to sell artwork quickly or move it to another jurisdiction. The alert also sets out a number of case studies to illustrate these risks in practice. (Microsoft Word - 0735-NECC Amber Alert Sanctions Evasion Money Laundering in the Art Sector FINAL_DRAFT_JAN24 (nationalcrimeagency.gov.uk)).
• UK updates definition of high risk third countries under Anti-Money Laundering and Terrorist Financing legislation: On January 22, 2024, the UK Government updated the definition of high risk third countries under the UK’s Money Laundering Regulations pursuant to the Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2024.  The updated definition – i.e. a country named on either FATF’s High-Risk Jurisdictions subject to a Call for Sanction or Jurisdictions under Increased Monitoring – will reduced the time taken for the UK to implement updates to the corresponding FATF lists (https://assets.publishing.service.gov.uk/media/65ae378f82fee9000d6f5fbd/Money_Laundering_Advisory_Notice_-_High_Risk_Third_Countries.pdf).
• UK proscribes Hizb ut-Tahrir as terrorist organisation: On January 19, 2024, the UK Government proscribed Hizb ut-Tahrir as a terrorist organisation, after Parliament approved a draft order laid before Parliament on January 15.  This order makes it a criminal offence, among other things, to belong to Hizb ut-Tahrir, to invite support for the group and/or to  express an opinion or belief that is supportive of the organisation.  An offence can be punished by imprisonment for up to 14 years and/or a fine. (Hizb ut-Tahrir proscribed as terrorist organisation - GOV.UK (www.gov.uk)).