UK Weekly Sanctions Update - Week of April 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

• OFSI issues new Legal Services General Licence under the Russia Regulations: On April 26, 2024, OFSI issued General Licence INT/2024/4671884, replacing General Licence INT/2023/3744968, with effect from April 29, 2024.  At the same time, OFSI also issued 37 FAQs in connection with the General Licence.  The General Licence authorises certain payments connected with the provision of legal services to a designated person subject to certain conditions.  The general licence expires on October 28, 2024. (Legal_services_INT.2024.4671884_PN.pdf (publishing.service.gov.uk); https://assets.publishing.service.gov.uk/media/662ba57d6963baceeb2252b3/Legal_services_INT.2024.4671884_PN.pdf).
• HMRC issues compound settlement offers to six UK exporters: On April 25, 2024, the ECJU issued a notice to exporters reporting that, between January and March 2024, HMRC issued settlement offers to six UK companies.  These settlements were in relation to: a breach of licence conditions in relation to the export of military goods; the unlicensed exports of military goods controlled by The Export Control Order 2008; and the unlicenced exports of dual use goods controlled by Retained Regulation 428/2009.  HMRC has seen an increase over the last 12 months in the number of voluntary disclosures relating to: unlicenced exports; incorrect licence usage; and breach of licence conditions. (Notice to exporters 2024/08: breaches of strategic export compound settlement issued - GOV.UK (www.gov.uk)).
• HMRC issues compound settlement of over £1 million relating to export of goods in breach of Russia sanctions: On April 25, 2024, the ECJU published Notice to Exporters 2024/07 announcing a compound settlement issued in March 2024 worth £1,058,781.79 in relation to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.  Over £20 billion of UK-Russia bilateral trade (2021 figures) is now under full or partial sanction. There has been a 94% fall in Russian imports into the UK and a 74% fall in UK exports to Russia. (NTE 2024/07: Russian sanctions compound settlement issued - GOV.UK (www.gov.uk)).
• UK Supreme Court upholds UK Court of appeal decision to grant an anti-suit injunction against Russian company’s proceedings against UniCredit: On April 23, 2024, in UniCredit Bank GmbH v RusChemAlliance LLC (RCA), the UK Supreme Court held that an anti-suit injunction against proceedings brought by RCA against UniCredit should be upheld.  The declarations and injunctive relief granted by the Court of Appeal on January 29, 2024, will remain in force.  RCA wished to bring proceedings on the basis of non-payment by UniCredit under bonds issued to RCA.  UniCredit was prohibited from making payment because of EU Russia sanctions.  There were parallel proceedings in the Arbitrazh Court of the St Petersburg and Leningrad region which were adjourned pending the UK Supreme Court’s consideration of the appeal. (Watch Decision in the matter of UniCredit Bank GmbH (Respondent) v RusChemAlliance LLC (Appellant) - The Supreme Court).

2. Iran Sanctions

• UK Government adds six entries to the UK sanctions list under the Iran regime: On April 25, 2024, the UK Government added two individuals (Abbas Abdi Asjerd and Seyed Mohsen Vahabzadeh) and four entities (Alvand Motorbuilding Industries Company, Bonyan Danesh Shargh Private Company, Moj Gostar Aseman Parvaz Company and Pishro Sanat Aseman Sharif Company) to the UK sanctions list under the Iran regime.  They are each believed to be or have been involved in hostile activity by the Government of Iran by carrying on business in the Iranian defence sector. (Notice_Iran_250424.pdf (publishing.service.gov.uk)).

3. Other Sanctions

• UK proscribes Terrorgram as terrorist organisation: On April 26, 2024, the UK Government proscribed Terrorgram as a terrorist organisation, making it a criminal offence to belong to the group or invite support for it.  According to the UK Home Office, the Terrorgram collective is “an online network of neo-fascist terrorists who produce and disseminate violent propaganda to encourage those who consume its content to engage in terrorist activity”. (https://www.gov.uk/government/news/terrorgram-added-to-list-of-proscribed-terrorist-organisations; https://www.gov.uk/government/news/terrorgram-collective-now-proscribed-as-terrorist-organisation).
• UK Charity Commission investigates companies for funding pro-Hamas news agency controlled by designated person: On April 19, 2024, The Charity Commission issued a press release stating that it has launched a statutory inquiry to investigate funds raised for charitable purposes by and on behalf of Aozma Sultana, a sanctioned individual. She is the sole director of two companies which appear to have partnered with Gaza Now, a news agency that promotes Hamas and Palestinian Islamic Jihad, to provide humanitarian support to people in Gaza.  The Charity Commission is concerned that funds raised may have been misappropriated and used to financially support Gaza Now. (Regulator investigates fundraising activity over links to pro-Hamas media outlet - GOV.UK (www.gov.uk)).