The UK Government announced a new dedicated unit to address non-compliance with Russian sanctions.

BY:

Gail Leeson
12 December 2023

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The UK Government announced a new dedicated unit to address non-compliance with Russian sanctions. On the 11th of December 2023, the UK Government announced a new unit to clamp down on companies evading sanctions; The Office of Trade Sanctions Implementation (OTSI) will launch in early 2024, once the latest legal requirements are in place, and will reinforce existing work the government does to ensure UK trade sanctions are adhered to. 


  • Minister Ghani announces new Office of Trade Sanctions Implementation (OTSI) to strengthen enforcement and clamp down on companies dodging Russian sanctions 
  • The unit will increase power to issue penalties for trade sanctions breaches and refer cases for criminal enforcement to HMRC 
  • Goods imports from Russia are already down 94% in the year following the full-scale invasion of Ukraine


Companies that circumvent the strict trade sanctions, including those imposed since the war in Ukraine, will face harsher penalties with the creation of the new Office of Trade Sanctions Implementation (OTSI). 


The OTSI will be responsible for the civil enforcement of trade sanctions, including those against Russia. The unit will help businesses comply with sanctions and investigate potential breaches, issuing civil penalties and referring cases to HMRC for criminal enforcement. 


Its remit will involve activity by companies who may be avoiding sanctions by sending products through other countries. 


The news comes as the UK is expected to announce fresh sanctions targeting the latest items Ukraine has found on the battlefield, such as machine parts and electronics, as well as products that raise revenue to fund Russia’s war against Ukraine. 

 

Industry and Economic Security Minister Nusrat Ghani said:

“Our package of sanctions, the most severe ever imposed on a major economy, is working – goods imports from Russia to the UK have already plummeted by 94%. 


But we are leaving no stone unturned in our commitment to stopping Putin’s war machine. That means clamping down on sanctions evaders and starving Russia of the technologies and revenues it needs to continue its illegal invasion. 


Today’s announcement will help us do that and send a clear message to those breaking the rules that there is nowhere to hide.


The UK and our international partners have implemented the most severe sanctions ever imposed on a major economy, with an unprecedented £20 billion worth of UK-Russia goods trade now sanctioned. The evidence shows the sanctions are working, with UK-Russia trade falling to historic lows.”

 

Sanctions Minister Anne-Marie Trevelyan said:

“Today’s announcement will further strengthen the UK’s sanctions system and allow us to maximise trade sanctions' impact on those who continue to flout the global rules. 


Without international sanctions, we estimate Russia would have over $400 billion more to fund the war, enough to fund the invasion for a further four years. We are hitting Russia where it hurts and starving Putin of the resources he needs to fund his illegal war on Ukraine.”


Department for Business and TradeOffice of Trade Sanctions ImplementationForeign, Commonwealth & Development Office, and Nusrat Ghani MP


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:

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.

Register Here

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 dference 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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