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On 14 December 2023, the UK government introduced legislation to sanction further goods, technology, and funding sources that could support Russia’s war against Ukraine. These include import, export and financial sanctions.
This new package of sanctions builds on the established sanctions. It bans the export of a range of goods that carry a risk of military or industrial usage, as well as items that Ukraine has found on the battlefield, including machine parts and electronics.
Minister Ghani stated: “Given the low levels of UK-Russia trade, these sanctions will ensure we can continue depriving Russia of products it could use in its war. In essence, only low-risk, humanitarian, food, and health exports will remain unsanctioned after this”.
Russian Metals Sanctions: Overview
Notice To Importers 2953: Russia Import Sanctions https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/nti-2953-russia-import-sanctions
On 14th December 2023, Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 was amended. This amendment prohibits the import of metals and the acquisition, supply and delivery, directly or indirectly, of these goods.
These measures took effect on December 15th, 2023. However, the prohibition does not apply for goods already consigned from Russia before the 15th of December and imported into the United Kingdom before the 14th of January.
Regulation 46IF defines metals as anything specified in Schedule 3BA.
Regulations 46IG, 46IH and 46II prohibit the import, acquisition, supply and delivery of metals. These regulations cover goods consigned from, located in, or originating in Russia, as applicable under the relevant regulation.
This means that the prohibition may still apply even if the immediate place the goods were shipped from was not Russia.
A list of commodity codes listed in Schedule 3B can be accessed here…
Diamonds and Diamond Jewellery
Additionally, on 14th December 2023, Russia's (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023 was amended. This amendment prohibits the import of diamonds and diamond jewellery and the acquisition, supply and delivery, directly or indirectly, of these goods into the UK.
These measures also prohibit the provision of technical assistance, financial services and funds, and brokering services relating to these goods.
These measures took effect on 1st January 2024
A licence may be issued for the import, acquisition, or supply and delivery, directly or indirectly, of diamonds and diamond jewellery if it relates to:
- the execution of obligations arising from contracts concluded before 15th December 2023
A licence may be issued for the provision of technical assistance, financial services and funds, or brokering services relating to diamonds or diamond jewellery if it relates to:
- the execution of obligations arising from contracts concluded before 15th December 2023
https://www.legislation.gov.uk/uksi/2023/1367/regulation/3/made
Further to notice to exporters 2023/07, a tranche of new trade sanctions on Russia entered into force on 15th December 2023.
New measures prohibit the export, supply, and delivery of newly sanctioned items and related ancillary services and make them unavailable to or for use in Russia.
The newly sanctioned items have been added to existing schedules in the 2019 Regulations, namely 2A (critical-industry goods and critical-industry technology), 3A (luxury goods) and 3E (G7 dependency and further goods).
The new measures also included amendments to Schedule 3C (defence and security goods and defence and security technology). The new measures also amend some codes in Schedule 3I (Russia’s vulnerable goods).
Appropriate licences can continue to be sought for prohibited activity.
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:
Latest Developments in Russian Sanctions Impacting Import and Export for UK Traders
Join Steve Berry, Director of Export & Import & Niamh O'Connor, Customs Advisor & Head of Communications, as they focus on implementing sanctions and how these changes will affect the supply of your goods to Russia and importing certain goods into the UK - with the new third-country processing requirements.
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: 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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