This guidance assists people in implementing and complying with The Russia (Sanctions) (EU Exit) Regulations 2019. It covers the prohibitions and requirements imposed by the regulations. It also provides guidance on best practice for:
complying with the prohibitions and requirements
enforcing them
circumstances where they do not apply
This guidance should be read alongside more detailed sanctions guidance published by departments including the Department for Business and Trade (DBT), Department for Transport (DfT), Home Office and HM Treasury, through the Office of Financial Sanctions Implementation (OFSI).
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 OFSIs ability to gather intelligence on industrys compliance with financial sanctions, strengthen OFSIs 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.
