UK Sanctions Weekly Update – Week of September 25, 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 and EU Russia-connected iron and steel ban comes into force: On September 30, 2023, the Russia-connected iron and steel bans announced by the UK and EU came into force prohibiting the import of iron and steel products from third countries which originate from Russia or are processed from Russian iron and steel. Companies are also required to provide evidence that this is not the case. UK Department for Business & Trade and Department for International Trade published guidance on the measures earlier this month, providing examples of what would/would not be prohibited. (Guidance on third country processed iron and steel measures - GOV.UK (www.gov.uk))
• OFSI issues correspondent banking general licence: On September 29, 2023, OFSI issued a general licence authorising a Credit or Financial Institution to return a “Relevant Payment” subject to certain conditions.  The general licence appears to be addressing a scenario where a DP bank is not a direct counterparty to a UK financial institution, but further upstream in the payment chain. (https://assets.publishing.service.gov.uk/media/6516eed66dfda6000d8e3906/Correspondent_Banking_General_Licence.pdf)
• UK adds 11 entries to sanctions list: On September 29, 2023, the UK imposed sanctions on 10 individuals and one entity for their involvement in sham elections in the Ukrainian oblasts of Kherson, Zaporizhzhia, Donetsk and Luhansk, and in illegally annexed Crimea. (https://assets.publishing.service.gov.uk/media/65168ec97c2c4a001395e227/Notice_Russia_290923.pdf; https://www.gov.uk/government/news/uk-announces-new-sanctions-in-response-to-russian-sham-elections-in-ukraine)
• OFSI amends one UK sanctions designation: On September 27, 2023, OFSI amended one entry in the UK Sanctions List. The entry for Alexei Kozlov was updated, and he remains subject to an asset freeze and trust services sanctions. (Notice_Russia_270923.pdf (publishing.service.gov.uk))
• UK, along with E5 nations, issues joint guidance on countering Russia evasion of export controls: On September 26, 2023, the E5 issued joint guidance to industry and academia identifying high priority items critical to Russian weapons systems and urging specific actions to prevent diversion of these items to Russia through third countries. The guidance provides a list of 45 prioritised Harmonised System (HS) codes containing items Russia needs for its weapons systems. The guidance then identifies patterns associated with importers in non-GECC (Global Export Control Coalition) countries that may raise (i) diversion concerns, (ii) due diligence tips for screening such parties, and (iii) red flag indicators that may be relevant to exporters to assist in determining whether an activity may be connected to export control and/or sanctions evasion. (Microsoft Word - 2023.09.22_BIS Press Release_Quint Seal_EE.OCPA_CLEAN+AJB-osb.docx) (Russia-Belarus (doc.gov))