New package of UK Sanctions on Russia | Fieldfisher
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New package of UK Sanctions on Russia


United Kingdom

On 21 April, the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 SI 2023 No 440 came into force (with the exception of Regulation 3 on imports of Russian iron and steel processed in a third country, that comes into force on 30 September 2023). This amends The Russia (Sanctions) (EU Exit) Regulations 2019.

This instrument implements the remaining measures announced by the UK government on 24 February, the first anniversary of Russia’s invasion of Ukraine in 2022. These broadly align with similar measures implemented by the EU on 25 February in its 10th Package of sanctions against Russia (Council Regulation 2023/427 amending Regulation 833/2014).

The main new measures are as follows:

  • Exports: prohibitions on the export, supply and delivery, and making available to, or for use in Russia of a range of goods that Russia has been found using on the battlefield to date, as well as the provision of related ancillary services. This includes aircraft and vehicle parts, radio equipment and other electronic equipment, biotechnology, and 3D printing machinery. These goods have been added to existing schedules, namely 2A (critical-industry goods and critical-industry technology), 2E (quantum computing and advanced materials goods and technology), 3C (defence and security goods and defence and security technology), 3E (G7 dependency and further goods) and 3I (Russia’s vulnerable goods);
  • Imports: prohibitions on the import and acquisition of additional goods originating or consigned from Russia which generate revenue for Russia, as well as the provision of related ancillary services. These additions are made in Part 3 of Schedule 3B (iron and steel products) and Parts 3 of Schedule 3D and 3DA (revenue generating goods). This aims to further constrain Russia’s ability to raise money to fund its war effort;
  • Imports of Russian iron and steel goods from third countries: from 30th September 2023, the existing prohibitions on importing and acquiring iron and steel goods will be extended to cover the import and related ancillary services of Russian origin iron and steel goods that have been processed in third countries. This is designed to further inflict economic cost to undermine Russia's war effort;
  • Supply and delivery of Russian revenue generating goods to third countries: prohibitions on the supply and delivery of certain revenue generating goods from Russia to third countries (as listed in schedule 3DA). This aims to disrupt Russia’s exports of these goods, further constraining its ability to fund its war efforts. Revenue generating goods that have an important humanitarian or civilian use, such as certain agricultural and energy-related goods (as listed in schedule 3D) are not covered by this new prohibition on supply and delivery from Russia to third countries;
  • Exceptions: exceptions which apply to existing prohibitions, such as humanitarian assistance, will apply to the newly listed goods. As with the existing prohibitions, licenses will be assessed on a case-by-case basis and may be granted where they would be consistent with the purposes of the sanctions. 

Fieldfisher's experienced multi-disciplinary sanctions and export control team includes lawyers who have negotiated and drafted EU and UN sanctions regimes in Government and regularly sanctions advice to businesses operating around the world in a wide variety of sectors.  We work closely with US partners to provide coordinated, comprehensive and practical advice to help business understand and manage the impact of sanctions. 

For more information please contact Andrew Hood (Partner, International Trade): +44(0)330 460 6568
* The contents of this notice do not constitute legal advice and are provided for general information purposes only.

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