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 updates General Licence for payments to water companies: On October 1, 2024, the Office of Financial Sanctions Implementation (OFSI) updated General Licence INT/2023/3179120, which inter alia authorises payments by UK designated persons and persons acting for or on their behalf to certain water companies. The updated general licence amends the definitions of "UK designated person" and "return payments" under the licence. The Genera Licence is now also of indefinite duration. (OFSI General Licence INT/2023/3179120 - GOV.UK (www.gov.uk)).
- OFSI publishes new FAQs and relating to trust services and licensing: On October 1, 2024, OFSI added two new FAQs. FAQ 121 states that internal settlements of Russian securities between two counterparties with sub-accounts held within the same non-designated bank do not engage UK sanctions, subject to certain conditions. FAQ 122 seeks to clarify the definition of "located" and "ordinarily resident" in Russia for the purposes of the UK trust services sanctions targeting Russia. (https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).
- UK to remove licensing consideration relation to provision of intra-corporate services by UK companies to their Russian subsidiaries: On September 30, 2024, the UK issued Notice to Exporters 2024/26 to provide an update on Russian sanctions licensing for intra-corporate services. In particular, the Notice states that, from October 31, 2024, the provision of intra-corporate services "will no longer be listed in the Statutory Guidance as a licensing consideration that is likely to be consistent with the aims of the sanctions regime". (https://www.gov.uk/government/publications/notice-to-exporters-202426-update-on-russia-sanctions-licensing-for-intra-corporate-services/nte-202426-update-on-russia-sanctions-licensing-for-intra-corporate-services).
2. Cyber Sanctions
- UK Government adds 16 entries to the UK sanctions list under Cyber regime: On October 1, 2024, the UK Government added 16 individuals to the UK sanctions list under the Cyber regime. According to the UK Government, these individuals are members of prolific Russian cyber-crime gang "Evil Corp", are a Russia-based cybercriminal organisation who have reportedly been involved with efforts to compromise the UK health, government and public sector institutions. (UK sanctions members of notorious 'Evil Corp' cyber-crime gang, after Lammy calls out Putin's mafia state - GOV.UK (www.gov.uk); Notice_Cyber_011024.pdf (publishing.service.gov.uk)).
3. Haiti Sanctions
- UK Government adds two entries to the UK sanctions list under the Haiti regime: On October 1, 2024, the UK Government added Luckson Elan and Prophane Victor to the UK sanctions list under the Haiti regime, following their designations by the UN Security Council. According to the Uk Government, these individuals are responsible for organising and supporting brutal gang violence and human rights abuses in Haiti. (Notice_Haiti_011024.pdf (publishing.service.gov.uk)).
4. Belarus Sanctions
- UK Government adds one entry to the UK sanctions list under the Belarus regime: On October 3, 2024, the UK Government added CJSC Alfa Bank Belarus to the UK sanctions list under the Belarus regime. According to the UK Government, this bank is or has been obtaining a benefit from or supporting the Government of Belarus by carrying on business in a sector of strategic significance to the Government of Belarus, namely the Belarusian financial services sector. (Notice_Belarus_031024.pdf (publishing.service.gov.uk)).
5. Mali Sanctions
- UK Government updates Mali Sanctions Guidance: On October 3, 2024, the UK Government added guidance on director disqualification to its Mali sanctions guidance. (Mali sanctions: guidance - GOV.UK (www.gov.uk)).
6. Other Sanctions
- FCA fines UK bank £29 million for financial crime failings related to its sanctions screening: On October 2, 2024, the Financial Conduct Authority fined Starline Bank Limited almost £29 million for financial crime failings related to its financial sanctions screening and breaches of a requirement not to open accounts for high-risk customers. (https://www.fca.org.uk/news/press-releases/fca-fines-starling-bank-failings-financial-crime-systems-and-controls#:~:text=The%20FCA%20continues%20to%20supervise%20firms%20to%20ensure%20that%20they).
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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.
