Russia sanctions: guidance

latest amendments cover new licencing Regs 46Z34 - 46Z

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These changes reflect the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 and taken together make a range of technical changes with the purpose of improving OFSI’s ability to gather intelligence on industry’s compliance with financial sanctions, strengthen OFSI’s enforcement powers, enable OFSI to conduct its licensing responsibilities more efficiently, and clarify financial sanctions legislation where there is existing uncertainty.

Lines removed to reflect the change in licensing conditions in russia sanctions regulations.

Added the Office of Trade Sanctions Implementation (OTSI) as a supporting organisation, who took over civil enforcement for sanctions in October 2024. As part of these new powers, OTSI has introduced a new service to apply for sanctions licences for the provision of services, which replaces the previous process of applying via SPIRE. Applications for goods-related exports sanctions licences remain via SPIRE.

Changes made to align with amendments to regulation 54D.

Changes made to reflect amendments to legal services prohibition as a result of SI laid by FCDO

Prohibition 46Z16R has been amended to update licencing information of third country processed Russian diamonds, including new links to guidance.

Amended to incorporate latest legislation guidance on director disqualification and ship specification in sanctions.

Information on the prohibition of metals updated to reflect amendments to the Trade Licence on the acquisition of metals.

New Chapter 4JC bans the import of diamonds processed in a third country that originate from Russia and builds on Chapter 4JB that banned the direct import of all diamonds from Russia.

Amended the date in Regulation 46IB from April 2023 to June 2023

Guidance updated to include licencing grounds relating to Schedule 3DA revenue generating goods.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023 and the Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2023.

Guidance updated to add additional licencing grounds for the purpose of divestment from Russia

Guidance updated to add a licensing ground for the restrictions on legal advisory services (Regulation 54D).

This amendment introduces guidance on the addition of the prohibition of Legal advisory services to the Russia (Sanctions) (EU Exit) Regulations 2019

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.2) Regulations 2023.

Minor changes to lines on provision of food services.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023.

Guidance updated to add a licencing ground for professional and business services for critical energy supply.

Guidance updated to clarify the application of prohibitions on the provision of technical assistance relating to, and making available or transferral of, aviation and space goods and technology or critical-industry goods and technology.

A new licensing ground related to medical goods has been added to the licensing grounds for the export of Russia's vulnerable goods.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022

Guidance updated to clarify the application of the prohibition on provision of technical assistance, financial services or funds related to G7 dependency and further goods.

Guidance updated to clarify the application of the prohibition on providing financial services and funds relating to restricted goods and G7 dependency and further goods.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022.

Guidance updated to clarify the application of the prohibition on providing insurance and reinsurance services in relation to aviation and space goods and technology.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022.

Guidance updated to clarify the application of the prohibition on providing insurance and reinsurance services in relation to aviation and space goods and technology.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022.

Updated to add Annex A and Annex B

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022.

Guidance updated to clarify that the prohibition on providing financial services for the purposes of foreign exchange reserve and asset management also applies to transactions involving gold.

Guidance updated to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022.

Guidance amended to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2022.

Guidance amended to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.2) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2022.

Updated to link to the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022.

First published.