UK Weekly Sanctions Update - Week Of September 2, 2024

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 listed above.

1. Russia Sanctions

• UK Government introduces statutory instrument to amend legal advisory services ban and revokes legal services general licence: On September 6, 2024, the UK introduced The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024, which inter alia amended the legal advisory services prohibition set out in Regulation 54D of the Russia (Sanctions) (EU Exit) Regulations 2019. Among other things, The amendments introduce a knowledge requirement the legal advisory services prohibition, and clarifies that the provision of sanctions compliance advice in respect of any "relevant law" falls outside the scope of the prohibitions. At the same time, the UK Government revoked the Legal Advisory Services General Trade Licence, as the update to Regulation 54D meant that this General Trade Licence is no longer required. (https://www.legislation.gov.uk/uksi/2024/900/made/data.htm?view=plain; General trade licence Russia sanctions – legal advisory services - GOV.UK (www.gov.uk)) (NTE 2024/21: update on Russia sanctions legal services and revocation of legal advisory services general trade licence - GOV.UK (www.gov.uk)
• UK Government amends guidance on providing professional and business services to a person connected with Russia: On September 6, 2024, the UK Government amended its guidance on the professional services sanctions targeting Russia to reflect the amendment to Regulation 54D of the Russia (Sanctions) (EU Exit) Regulations 2019. This includes guidance on applying for licences and on what information to include licence application cover letters related to the professional services and legal services prohibitions. (Complying with professional and business services sanctions related to Russia - GOV.UK (www.gov.uk))
• UK Government updates its training resources for export control compliance: On September 6, 2024, the UK Government updated its export control compliance training page to provide details of a new upcoming training course and to provide links to webinar videos. (https://www.gov.uk/government/publications/export-control-training-bulletin)
• UK Government updates its guidance on the Russia regime: On September 1, 4 and 6, 2024, the UK Government updated its Russia sanctions guidance. Among other things, the guidance was updated to reflect updated licencing information of third country processed Russian diamonds (in relation to Regulation 46Z16R) and amendments to the legal services prohibition. (Russia sanctions: guidance - GOV.UK (www.gov.uk))
• UK Government updates General Trade Licence for sanctioned Russian diamonds processed in third countries: On September 1, 2024, the UK Government updated its General Trade Licence for sanctioned Russian diamonds processed in third countries In particular, the General Trade Licence has been expanded to authorise the import of relevant processed diamonds equal to or larger than 0.5 carats and smaller than 1 carat outside of Russia so long as the relevant diamond is not located in Russia anytime from September 1, 2024, as well as related services. (General Trade Licence for sanctioned Russian diamonds processed in third countries - GOV.UK (www.gov.uk))

2. Iran Sanctions

• UK Government adds four entries to the UK sanctions list under the Iran regime: On September 2, 2024, the UK Government added Abdolfatah Ahvazian, Benham Shahriyari, Hamad Fazeli and Islamic Revolutionary Guard Corps Quds Force Unit 700 to the UK sanctions list under the Iran regime. They are each believed to have been involved in hostile activity by the Government of Iran or by an armed group backed by the Government of Iran. All four entries are now subject to an asset freeze. (Notice_Iran_020924.pdf (publishing.service.gov.uk))

3. Israel Sanctions

• UK Government publishes a Notice to Exporters advising of the suspension of licences for Israel: On September 2, 2024, the UK Secretary of State for Business and Trade suspended extant export licences where the UK Government assesses the items are for use in military operations in Gaza. The UK Foreign Secretary also provided a written statement to Parliament, stating that around 30 of the approximately 350 export licences granted to Israel have been suspended. (UK policy on arms export licences to Israel: Foreign Secretary's statement - GOV.UK (www.gov.uk)) (NTE 2024/20: suspension of licences for Israel - GOV.UK (www.gov.uk))
• UK Government revokes and replaces general licences to remove Israel as a permissible destination. On September 2, 2024, the UK Government revoked and replaced a number of general licences to remove Israel as a permissible destination. The licences in question are:
  1. Open General Export Licence for exports in support of the Joint Strike Fighter (F-35 Lightning II) Programme (Open general export licence (exports in support of Joint Strike Fighter: F-35 Lightning II) - GOV.UK (www.gov.uk))
  2. Open General Export Licence for printed circuit boards and components for military goods (Open general export licence PCBs and components for military goods - GOV.UK (www.gov.uk))
  3. Open General Trade Control Licence for trade and transportation of small arms and light weapons (Open general trade control licence trade and transportation: small arms and light weapons - GOV.UK (www.gov.uk))
  4. Open General Export Licence for software and source code for military goods (Open general export licence software and source code for military goods - GOV.UK (www.gov.uk))
  5. Open General Trade Control Licence for category C goods (Open general trade control licence category C goods - GOV.UK (www.gov.uk))
  6. Open General Export Licence for technology for military goods (Open general export licence technology for military goods - GOV.UK (www.gov.uk))

4. Other Sanctions

• UK Government updates its training resources for export control compliance: On September 6, 2024, the UK Government updated its export control compliance training page to provide details of a new upcoming training course and to provide links to webinar videos. (https://www.gov.uk/government/publications/export-control-training-bulletin)

Visit us at mayerbrown.com

Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.

© Copyright 2024. The Mayer Brown Practices. All rights reserved.

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.