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
- OFSI legal services general licence to expire; new general licence to come into effect: On October 25, 2024, OFSI published new General Licence INT/2024/5334756, which comes into effect on 29 October 2024. This general licence authorises certain activities relating to the provision of legal services to designated persons under the Russia and Belarus sanctions regimes and will replace General Licence INT/2024/4671884, which expires on October 29, 2024. Under the new General Licence, OFSI has (i) increased the fee and expenses caps; (ii) introduced a restricted permission to pay into non-UK bank accounts; and (iii) clarified the position relating to caps applicable and in-house lawyers and directly instructed Counsel. (INT.2024.5334756_GL.pdf; https://assets.publishing.service.gov.uk/media/671bae6d956d9b52e8c6d2b7/INT.2024.5334756_PN.pdf ).
- OFSI moves NSD General Licence to expired licences page: On October 23, 2024, the Office of Financial Sanctions Implementation (OFSI) moved the General Licence INT/2024/4919848, which expired on October 12, 2024, to the expired licences page. This General Licence authorised until October 12, 2024, certain activities relating to the sale, divestment and transfer of financial instruments held by the Russian National Settlement Depository (NSD) and payment of safe keeping fees to the NSD. (https://www.gov.uk/government/collections/expired-general-licences)
- Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors Issued: On October 22, 2024, the Price Cap Coalition, which includes the G7, the EU, Australia and New Zealand, updated its Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors. The Advisory, initially published in October 2023, has been updated to provide stakeholders with new recommendations on meeting international obligations, enhancing due diligence around tanker sales, avoiding interactions with sanctioned counterparties, and raising internal awareness. (20241021_price_cap_advisory.pdf)
2. Counter Terrorism regime
- UK adds guidance on director disqualification to Counter-Terrorism Sanctions guidance: On October 21, 2024, the UK added guidance on director disqualification to its guidance on the Counter-Terrorism sanctions regime, reflecting measures that have been in force in the UK since 5 June 2024. (Counter-Terrorism sanctions: guidance - GOV.UK).
- UK updates licensing delegation framework for Counter Terrorism regime: On October 21, 2024, the UK updates its delegation framework for the Counter Terrorism regime. Among other things, the framework elaborates on circumstances that do not constitute a 'significant change' for new licences or amendments to existing licences, and can therefore be delegated to a senior civil servant for review and approval. The framework also outlines the current process for issuing breach letters under the Counter Terrorism regime. (https://www.gov.uk/government/publications/financial-sanctions-licensing/licensing-delegation-framework-counter-terrorism-branch).
3. Other sanctions
- UK updates OGEL relating to Joint Strike Fighter (F-35 Lightening II): On October 24, 2024, the ECJU updated its Open General Export Licence relating to Exports in Support of Joint Strike Fighter (F-35 Lightening II). The updated licence: (i) Removes Turkey from the list of Partner Nations, (ii) adds Belgium, Czech Republic, Finland, Germany, Singapore, and Switzerland as Export Customers, (iii) adds Luxembourg, New Zealand, Spain, and Sweden as Countries which may develop, produce, trial, or test or use items, and (iv) provides revised contact details for the Ministry of Defence (MOD) Defence Equipment and Support Principal Security Adviser. (https://www.gov.uk/government/publications/notice-to-exporters-202427-updates-to-2-open-general-export-licences/nte-202427-updates-to-2-open-general-export-licences; https://assets.publishing.service.gov.uk/media/67175273d100972c0f4c9b55/Open-General-Export-Licence-Exports-in-Support-of-Joint-Strike-Fighter-_F-35-Lightning-II__OCT_24.pdf)
- UK updates OGEL relating to Exports or Transfers in support of UK Government Defence Contracts: On October 24, 2024, the ECJU updated its Open General Export Licence relating to Exports of Transfers in support of UK Government Defence Contracts. The updated licence: (i) provides amended wording on the interpretation of "eligible" in section 5(7) of the OGEL, and (ii) provides revised contact details for the ECJU MOD, and MOD Defence Equipment and Support Principal Security Adviser. (https://www.gov.uk/government/publications/notice-to-exporters-202427-updates-to-2-open-general-export-licences/nte-202427-updates-to-2-open-general-export-licences; https://www.gov.uk/government/publications/open-general-export-licence-exports-or-transfers-in-support-of-uk-government-defence-contracts)
- UK updates licensing delegation framework: On October 21, 2024, OFSI updated its licensing delegation framework. This framework is used by OFSI caseworkers in their assessment as to whether a decision on whether a licensing decision is contentious and therefore must be escalated for ministerial review (Licensing Delegation Framework - GOV.UK).
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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.
