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Foreign Secretary, The Rt Hon James Cleverly MP, announced 22 new sanctions on August 8th, 2023. This includes two businesses based in Turkey, Turkik Union and Azu International and a business in Dubai, Aeromotus Unmanned Aerial Vehicles Trading LLC. The Turkish businesses had a role in exporting microelectronics to Russia. The company based in Dubai were involved in supplying Drone and Drone Components to Russia.
These two sanctions emphasise the importance of due diligence and checking the end user, end-use, and potentially the ultimate end user. The ultimate end user is the entity that will use the product or higher-level assembly into which the supplied goods are provided. This could be a different entity to the end user. Sanctions will apply directly or indirectly, so checking on end use and investigating further than the consignee is essential.
In addition to business sanctions, a Slovakian National has been sanctioned for his involvement in an attempted arms deal, and a Swiss National for his role concerning Russian financial services.
Another type of service, legal advice, now has a licence that can be obtained via SPIRE for the provision of certain activities. The “General Trade Licence Russian Sanctions – Legal Advisory Services” was issued on 11th August 2023.
Chapter 6B – Professional and Business Services, contains Regulation 54D - Legal Advisory Services in The General Licence permits the direct or indirect provision of legal advisory services that would otherwise be prohibited under Regulation 54D.
Subject to the licensee being able to comply with the conditions of the licence, registration on SPIRE must be made within 30 days of the first use of the licence.
This Trade Licence can be found in the “OGL/GEA/EU GEA” drop-down menu, together with the other relevant licences that have been created; General Trade Licence Russia Sanctions, as well as General Trade Licences relating to Aviation Insurance, Financial Services and Funds related to Fertilisers and the “General Trade Licence – Vessels” which relates to specific activities and goods for vessels and aircraft parts as detailed in the document.
Companies and individuals from these two countries have also been sanctioned in relation to the Iranian and Belarusian support of Russian military activities. The UK has also sanctioned 3 Russian companies who operate in the electronic sector for their role in procuring “UK-sanctioned western microelectronics” for end-use in Russia.
By signing up for Gov. uk Notice to Exporters updates, you will receive new announcements relating to UK export controls as soon as they are published. Click the “Get emails about this page” link to create the alert.
The Foreign Commonwealth and Development Office, also known as the FCDO, publish the UK Sanctions List, and it is possible to subscribe to their updates via their page and the “get emails” link https://www.gov.uk/government/organisations/foreign-commonwealth-development-office
Focus On: Embargoes, Sanctions and End-Use Controls
This half-day session examines why companies and employees should be aware of embargoes and sanctions. Using the UK regulations as the primary guide, it will review the growth in sanctions on Russia, as well as current financial sanctions in place managed by OFSI. It concentrates mainly on the export of goods and includes a look at end-use, end-user and transit controls. Violating these controls can result in fines, reputation loss, and criminal charges.
Focus On: Preparing for an Export Control Audit
Export Controls increase the level of compliance for businesses whose exports require a licence. The Export Control Joint Unit is responsible for issuing export licences for strategic Goods, Software and Technology (Military and Dual Use) to countries outside the UK.
Focus On: Controlling Technology & Intangible Transfers
Even intangible transmission of controlled items needs export licences. The licensing regulations cover technology, software, and goods; the main difference is that the former can be sent to another country intangibly, e.g. by email, via a VPN, or downloaded from a website. This session will review the type of licences available, how to use them and maintain a technology log for audit purposes. It also covers the use of technology by employees while working overseas.
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