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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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If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:
Beginners Guide to Export Licensing Controls
Whether at the start of your learning pathway or as a standalone training session, this course will begin your journey to understand export licensing controls and how they work. Covering essential elements gives delegates an excellent springboard to understand what goods, technology or software could be controlled and review business-relevant areas in more detail.
Applying for and Using UK Export Licences
A practical session to explain the information needed to apply for individual licences and how to understand when an open licence is appropriate for a particular movement or transfer of controlled items. This workshop is designed to teach delegates how to use the export licensing system in the UK.
Focus On: Dual Use Export Compliance - The Dual-Use Exporter
This full-day session focuses on a topic relevant to many industry sectors: dual-use regulations. With licences now required for dual-use items moving between the UK and EU, the need to understand this topic has grown significantly. The controls are based on an item’s inherent capability, type of materials or technical ability, affecting many industry sectors, including chemical, metals, high-tech products, oil and gas industries, etc.
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