UK Weekly Sanctions Update - Week of November 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

• OFSI issues Correspondence Banking General Licence for 2022 payments:  On November 7, 2024, OFSI issued General Licence INT/2024/5394840, which authorises the processing by a relevant institution of certain payments that were blocked in 2022, subject to certain terms and conditions.  This General Licence expires on November 6, 2025. (INT_2024_5394840_GL.pdf; https://assets.publishing.service.gov.uk/media/672c8c2fcfb0b183cd67cac5/INT_2024_5394840_PN.pdf).

• OFSI issues new UK Financial Sanctions FAQs: On November 5 and 7, 2024, OFSI added several new FAQs to support stakeholders in interpreting and complying with UK sanctions.  Several new FAQs relate to inter alia OFSI’s legal services general licence (FAQs 49-51, 55, 61-66, 72-73, 76 and 84) and the impact of Russian Decree 840 (FAQ 123).  In respect of the latter point, OFSI has extended the 2024 Frozen Asset Reporting Date by two weeks to November 25, 2024 (UK Financial Sanctions FAQs - GOV.UK).
• HMRC agrees compound settlement with UK exporter in connection with apparent breach of Russia sanctions:  On November 4, 2024, HMRC announced that it had agreed a compound settlement offer in August 2024 pursuant to which an (unnamed) UK exporter paid £58,426.45 in connection with apparent violations of the Russia (Sanctions) (EU Exit) Regulations 2019.   The Notice to Exporters states that, since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129. (NTE 2024/29: compound settlement for breaches of Russian sanctions – August 2024 - GOV.UK)
• UK Government adds 47 entries to the UK sanctions list under the Russia sanctions regime: On November 7, 2024, OFSI added 16 individuals and 31 entities to the UK sanctions list under the Russia sanctions regime.  According to the UK Government, the new sanctions targets suppliers supporting Russia’s military production, Russian-backed mercenary groups operating in Sub-Saharan Africa and a GRU agent involved in the use of a Novichok nerve agent in Salisbury.  (Notice_Russia_071124.pdf; https://www.gov.uk/government/news/uk-strikes-at-heart-of-putins-war-machine)
• OFSI extends General Licence for Continuation of Business of Evraz Plc’s North American Subsidiaries: On November 7, 2024, OFSI extended General Licence INT/2022/1710676, which authorises certain activities relating to the continuation of business of Evraz Plc’s North American Subsidiaries. The general licence now expires on 30 September 2025. (INT.2022.1710676_Publication_Notice_extension.pdf)

2. Libya sanctions

• UK Government adds two entries to the UK sanctions list under the Libya sanctions regime: On November 7, 2024, OFSI added Africa Corps (formerly known as the Wagner Group) and Andrey Averyanov to the UK sanctions list under the Libya sanctions regime.  According to the UK Government, Averyanov is connected to private mercenary groups with links to the Kremlin. (Notice_Libya_071124.pdf; https://www.gov.uk/government/news/uk-strikes-at-heart-of-putins-war-machine)

3. Mali Sanctions

• UK Government adds one entry to the UK sanctions list under the Mali sanctions regime:  On November 7, 2024, OFSI added Marko Mining to the UK sanctions list under the Mali sanctions regime.  According to the UK Government, Marko Mining has links to the Wagner Group. (Notice_Mali_071124.pdf; https://www.gov.uk/government/news/uk-strikes-at-heart-of-putins-war-machine).

4. Central African Republic Sanctions

• UK Government adds five entries to the UK sanctions list under the Central African Republic sanctions regime: On November 7, 2024, OFSI added Yevgeny Khodotov, Evgeny Kopot, Aleksandr Kuzin, Radio Centrafricaine Lengo Sengo, and the Officers Union for International Security to the UK sanctions list under the Central African Republic sanctions regime.  According to the UK Government, these parties are connected to private mercenary groups with links to the Kremlin (including the Wagner Group). (Notice_Central_African_Republic_071124.pdf; https://www.gov.uk/government/news/uk-strikes-at-heart-of-putins-war-machine)

5. Chemical Weapons Regime

• UK Government adds one entry to the UK sanctions list under the chemical weapons regime: On November 7, 2024, the UK Government added Russian national Denis Sergeev, a senior figure in the GRU (Russia's military intelligence service), to the UK sanctions list under the chemical weapons regime. (Notice_Chemical_Weapons_071124__Amendment_.pdf)

6. Other Sanctions

• HMRC announces compound settlement offers to three UK exporters worth £1.9 million:  On November 4, 2024, HMRC announced that it had issued compound settlement offers to three UK exporters worth £1.9 million in Aug/Sept 2024.  These compound settlements relate to the unlicensed exports of military and dual-use goods in apparent violation of the Export Control Order 2008 and Retained Regulation 428/2009.  (NTE 2023/28: compound settlement for breaches of export control – August 2024 - GOV.UK)
• UK Government extends 2024 Frozen Asset Reporting deadline: On November 7, 2024, the UK Government announced that the 2024 Frozen Asset Reporting deadline has been extended by two weeks to November 25, 2024.  The extension is noted in OFSI FAQ 123. (UK Financial Sanctions FAQs - GOV.UK)