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The DBT has issued a Notice to Exporters where they advise of an update to the Russia (Sanctions) (EU Exit Regulations) 2019, following a review of the professional and business services sanctions in place under Regulation 54C of the regulation.
The government has decided to remove the licensing consideration, which relates particularly to the provision of professional and business services from UK parent companies and their UK subsidiaries to their Russian subsidiaries.
Therefore, as of October 31st, 2024, the provision of intra-corporate services will no longer be listed as a licence consideration in the Statutory Guidance that is likely to be consistent with the aims of the sanctions regime.
Discretion remains on behalf of The Secretary of State to grant licences even where no licensing consideration exists, as per Regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019, meaning that any company that wishes to provide intra-corporate services to their Russian subsidiary must explicitly demonstrate compliance as to how the provision of any ongoing services aligns with the overarching purposes of the sanctions, as set out in Regulation 4 of the Russia sanctions Regulations.
Businesses will be able to apply for a licence using the licensing considerations for activities listed in the guidance: Link below
Russia sanctions guidance page.
Businesses are advised that this Notice will not affect licence applications submitted before October 31st, 2024.
Further information
From October 10th, 2024, the Office of Trade Sanctions Implementation (OTSI) will take on the responsibility of issuing licences for certain sanctioned activities, specifically the provision of standalone services, including professional and business services, as detailed in the Notice released on September 30th
The Export Control Joint Unit (ECJU) will remain responsible for licensing tangible goods and their ancillary services covered under the scope of the Russian Sanctions Act (services related to the export of tangible goods).
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