UK Weekly Sanctions Update - Week of November 11, 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 amends four entries on and removes one entry from the UK sanctions list under the Russia regime: On November 15, 2024, OFSI updated four entries on the UK sanctions list, namely the entries relating to Anatoly Ilyich Bibilov, Juhang Aviation Technology (Shenzhen) Co., Limited, Konstantin Yurievich Mirzayants, and Virmavia Ou.  At the same time, the UK Government removed Didier Casimiro, former Vice President of Rosneft, from the UK sanctions list. (Notice_Russia_151124.pdf).
• OFSI publishes FAQ relating to Russian Decree 840:  On November 11, 2024, OFSI published FAQ 124, which acknowledges the Russian Decree 840 has moved equities held at the Russian National Settlement Depository to local registrars.  In the FAQ, OFSI cautions that many Russian registrars may be captured by other existing designations, and notes that the UK government is exploring options to further clarify the current position. (UK Financial Sanctions FAQs - GOV.UK).

2. Sudan Sanctions

• UK Government adds two entries to the UK sanctions list under the Sudan regime: On November 11, 2024, OFSI added Abdel Rahman Juma Barkalla and Osman Mohamed Hamid Mohamed to the UK sanctions list under the Sudan regime. (https://assets.publishing.service.gov.uk/media/67321be02cccb48648badb71/Notice_Sudan_111124.pdf).

3. Other Sanctions

• UK Government introduces amendments across certain UK sanctions regimes: On November 14, 2024, the UK laid down the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024, which introduces a number of changes across the UK sanctions regime. Most of these changes come into effect on December 5, 2024.  Among other things, the new statutory instrument: (i) changes the existing requirements on "relevant firms" and "involved persons" to report suspected offences to a requirement to report suspected breaches of sanctions regulations; (ii) creates a new insolvency licensing purpose under certain UK sanctions regimes; (iii) introduces new civil monetary penalty powers for breaches in relation to Russia land prohibitions; and (iv) with effect from May 14, 2025, expands the definition of "relevant firms" subject to financial sanctions reporting obligations to cover additional sectors – high value dealers, art market participants, insolvency practitioners and letting agencies. (https://www.legislation.gov.uk/uksi/2024/1157/contents/made; https://ofsi.blog.gov.uk/2024/11/14/changes-to-sanctions-legislation-introduced-through-the-sanctions-eu-exit-miscellaneous-amendments-no-2-regulations-2024/).
• OFSI publishes new FAQs relating to the regulatory payments exception: On November 14, 2024, OFSI added several new FAQs relating to the regulatory payments exception, which will come into force on December 5, 2024.  Among other things, the FAQs make clear that this exception does not apply to payments that are owed by UN designated persons. (UK Financial Sanctions FAQs - GOV.UK).
• OFSI publishes new financial sanctions guidance for insolvency practitioners, letting agents and art market participants: On November 14, 2024, OFSI published new guidance for Insolvency Practitioners, Letting Agents and High Value Dealers and Art Market participants.  The new guidance will support market participants in those sectors understand their obligations under UK sanctions and to identify sanctions red flag typologies (including in relation to sanctions evasion). (UK financial sanctions general guidance - GOV.UK; Reporting information to OFSI – what to do - GOV.UK; Financial sanctions guidance for Insolvency Practitioners - GOV.UK; Financial sanctions guidance for letting agents - GOV.UK; High Value Dealers & Art Market Participants guidance - GOV.UK).