In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team.

1. Russia Sanctions

  • OFSI updates oil price cap guidance: On February 16, 2024, OFSI published updated guidance for the Maritime Services Ban and Oil Price Cap, to provide additional clarity and detail on the following:
    1. Attestations: The changes to the attestation model announced on 20 December 2023 will come into effect on 19 February 2024. The updated model requires 1) attestation forms to be provided on a per-voyage basis, and 2) itemised ancillary costs to be recorded by Tier 1 entities and provided to Tier 2 and Tier 3A contractual counterparties upon request. The tier system has been amended and Tier 3 has been split into Tier 3A and Tier 3B.
    2. Attestation and cost information deadlines: The deadline for providing additional attestations or itemised ancillary costs has been reduced from 30 days to 28 days.
    3. Ceasing doing business: The requirement to cease doing business with actors who refuse or fail to provide information has been clarified as being contract-specific and only applying to policies relating to the seaborne transportation of Russian oil and oil products. (OFSI OPC Guidance - February 2024.docx (
  • OFSI issues new oil price cap general licence: On February 16, 2024, OFSI issued General Licence – Oil Price Cap INT/2024/4423849 to replace General Licence INT/2022/2469656 with effect from February 19, 2024. The General Licence permits activity that would otherwise breach the Maritime Services Ban including, inter alia:
    1. The supply or delivery of Russian oil by ship from a place in Russia to a third country or from one third country to another, provided that the unit price of the Russian oil concerned is at or below the Price Cap.
    2. A service provider may provide relevant services to any person provided that the unit price of the Russian oil being supplied or delivered by ship from a place in Russia to a third country or from one third country to another third country, is at or below the Price Cap. (OPC_GL_-_19_Feb_2024.pdf ( (Oil_Price_Cap_General_Licence_Publication_Notice_-_19_Feb_2024.pdf (
  • UK Government amends one entry on the sanctions list under the Russia regime: On February 12, 2024, the UK Government made one variation to the entry for Vladimir Olegovich Potanin under the Russia sanctions regime. This individual remains subject to an asset freeze, travel ban, transport sanctions, prohibition of technical assistance related to aircraft and trust services sanctions. (Notice_Russia_120224.pdf (
  • OFSI publishes new blog on reporting requirements under the Russia regime: On February 12, 2024, the UK Government published a blog in respect of new reporting requirements for designated persons under the Russia regime. Two new reporting measures came into force in December 2023, through the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023. These measures have been introduced to strengthen transparency of frozen assets in the UK and to assist HM Treasury in monitoring compliance with, and detecting evasion of, financial sanctions. The blog post states that (i) "relevant firms" are now required to inform OFSI of any funds or economic resources they hold for the Central Bank of Russia, Russian Ministry of Finance, or Russian National Wealth Fund and (ii) persons designated under the Russia regime are required to proactively provide details of their UK assets to OFSI (or their worldwide assets if they are UK persons). (New reporting requirements for Designated Persons under the Russia Regime - Office of Financial Sanctions Implementation (

2. Human Rights Sanctions

3. Other Sanctions

  • OFSI to host webinar on financial sanctions licensing: On February 29, 2024, OFSI will be hosting a webinar titled "Introduction to Financial Sanctions Licensing". Registration is open at:
  • Law Society updates sanctions guidance: On February 16, 2024, the UK Law Society updated its guide to the UK sanctions regime, which provides summary of key topics relating to the UK sanctions regime, as well as steps on how to firms can comply with their obligations under the UK sanctions regime. (UK sanctions regime | The Law Society)
  • OFSI updates General Licence for payments to UK insurance companies: On February 15, 2024, OFSI amended General licence: Permitted Payments to UK Insurance Companies - INT/2022/2009156 to clarify that certain payments authorised under the general licence can be made by persons acting on behalf of a designated person, and that certain payments can be returned to a designated person. This General Licence applies across all UK autonomous sanctions regimes, which are listed in the licence. (GL_INT-2022-2009156.pdf (
  • OFSI publishes blog on changes to OFSI guidance in 2024: On February 13, 2024, OFSI posted a blog stating that OFSI will be transitioning to a new Sanctions Digital Guidance format throughout 2024, replacing the previous PDF guidance. The changes are expected to, inter alia, (i) provide new information faster and more efficiently; (ii) improve accessibility, ensuring OFSI guidance is inclusive; (iii) improve compatibility meaning people can access OFSI guidance from any device. (Changes coming to OFSI guidance in 2024 - Office of Financial Sanctions Implementation (
  • Russia adds 18 British nationals to entry ban list: On February 12, 2024, Russia's Ministry of Foreign Affairs announced that it had added 18 British military, political, and academic figures to its entry ban list for "fabricating anti-Russia narratives to reduce Moscow's influence in the international arena". Those added to the list include James Cartlidge (Minister of State for Defense Procurement), Roland Walker (Deputy Chief of the Defense Staff), Sarah Macintosh (Deputy National Security Adviser) and Simon Asquith (Royal Navy Director of Submarines). (Moscow Bans 18 U.K. Nationals From Entering Russia - The Moscow Times) (

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.