UK Weekly Sanctions Update - Week of January 15, 2024 | Insights

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 Department for International Trade revises general licence for vessels: On January 18, 2024, the UK’s Department for International Trade revoked and replaced General Trade Licence Russia Sanctions – Vessels. Per Notice NTE 2024/02, the General Licence has been revised to include with its scope regulations relating to the import, supply and delivery of Schedule 3DA revenue generating goods as well as related services. (General Trade Licence Russia Sanctions - Vessels (publishing.service.gov.uk)).

UK Government amends one entry on the UK sanctions list under the Russia regime: On January 15, 2024, the UK Government amended one entry on the Russia sanctions list relating to Svyatoslav Evgenievich Ostrovsky. This individual remains subject to an asset freeze and trust services sanctions. (https://assets.publishing.service.gov.uk/media/65a504fb7eb42e0013ceb7ce/Notice_Russia_150124.pdf).
UK court rejects Graham Phillips’ Sanctions Act challenge: On January 12, 2024, the Administrative Court gave judgment in England’s first ever case to consider the relationship between financial sanctions and freedom of expression. Graham Phillips was sanctioned by the United Kingdom in July 2022 for producing propaganda videos from the Donbas region in Ukraine which were in favour of Russia and their invasion of Ukraine. Graham Phillips had challenged the UK’s decision to designate him on the grounds that (i) the UK Government did not have the power to impose financial sanctions on a person on account of their political views, and (ii) his designation was a disproportionate restriction on his right to freedom of expression. The challenge was rejected. Among other things, the Court founds that (i) Mr Phillips’ video content was propaganda in favour of the Russian invasion of Ukraine; (ii) the UK Government has the power to impose sanctions on an individual who supports or promotes policies or actions which destabilise Ukraine or undermine its territorial integrity, sovereignty and independence, including through acts of “expression”, and (iii) the financial sanctions imposed on Phillips were proportionate. (Graham William Phillips v The Secretary of State for Foreign, Commonwealth and Development Affairs - Find case law - The National Archives).

2. Belarus Sanctions

UK Government amends one entry on the UK sanctions list under Belarus regime: On January 15, 2024, the UK Government amended one entry on the Belarus sanctions list relating to Petr Aleksandrovich Orlov. This individual remains subject to an asset freeze. (https://assets.publishing.service.gov.uk/media/65a5048e74ae66000d738aa3/Notice_Belarus_150124.pdf).

3. Other Sanctions

ECJU updates permitted destinations on 13 open general licences: On January 19, 2024, the UK’s Export Control Joint Unit within the Department for International Trade updated 13 open general licences to remove countries as permissible destinations. The countries removed from the various OGLs include Burkina Faso, Haiti, Mali and Niger. (https://www.gov.uk/government/publications/notice-to-exporters-202403-changes-to-permitted-destinations-on-13-open-general-licences/nte-202403-changes-to-permitted-destinations-on-13-open-general-licences).
UK Government amends four entries on the UK sanctions list under ISIL (Da'esh) and Al-Qaeda regime: On January 15, 2024, the UK Government made administrative amendments to four entries under the Isil (Da'esh) and Al-Qaeda sanctions regime. The amended entries were in respect of: (i) Tayeb Nail; (ii) Saifi Ammar; (iii) Said Arif; and (iv) Habib Ben Ahmed Al-Loubiri. These individuals remain subject to an asset freeze, arms embargo, and travel ban. (https://assets.publishing.service.gov.uk/media/65a5041874ae66000d738aa2/Notice_ISIL__Da_esh__and_Al-Qaida_150124.pdf).
UK Government adds one entry to UK sanctions list under Bosnia and Herzegovina regime: On January 15, 2024, the UK Government designated one entity, Mania D.O.O., under the Bosnia and Herzegovina sanctions regime. According to the FCDO, Mania D.O.O. aided in undermining peace and security in the region via its involvement in celebrations of Republika Srspka Day in direct contravention of the country’s constitution and court rulings. (Notice_Bosnia_and_Herzegovina_150124.pdf (publishing.service.gov.uk)).