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Does the UK's eighth sanctions package against Russia prohibit your commodities' exports?

The UK has issued the eighth amendment to its sanctions on Russia. What decision was taken, and how will it affect businesses?


The United Kingdom has imposed fresh sanctions on Russia: Quantum computing, oil refining and other high-tech goods are now illegal for export, supply, or transfer to, or use in, Russia. Imports of certain iron and steel goods originating in or consigned from Russia are also prohibited. Financial sanctions are also in place against Russia.


Sanctions are not something businesses should take lightly; they can disrupt business operations and cause companies financial losses in the long run if not carefully prepared for and addressed. To learn more about how businesses can protect themselves against sanctions, check out our guide on how to prepare your business against sanctions here!


Why The U.K. Just Passed Sanctions Against Russia Again

For decades, the relationship between the United Kingdom and Russia has been volatile. Though relations have been mainly amicable since the Soviet Union's demise in 1990, Russia's recent armed action against Ukraine has resulted in an increase in hostile attitude against Russia and its people.


When Russia's government unjustly grabbed Crimea and continued to destabilise Ukraine, the UK imposed sanctions in March 2014. Since then, the UK has steadily escalated sanctions against Russia in response to its egregious behaviour, including:

  • the country's military engagement in Syria

  • the use of a nerve agent in the streets of the United Kingdom

  • cyber-attacks on the UK's electrical grids

These sanctions are intended to compel Russia to modify its behaviour. They are also intended to prevent UK firms from profiting from Russian acts that endanger our national security and international standards. This is why the UK has prohibited sensitive products exports to Russia's defence and intelligence industries, as well as restricted access to financial markets for Russian state-owned banks, energy businesses, and defence firms.


These sanctions have also hurt the British economy, but politicians say that they are necessary since the alternative is an escalated conflict. Since 2022, the UK has issued a broad range of sanctions in the form of changes to The Russia (Sanctions) (EU Exit) Regulations 2019, which was changed more than five times in 2022.


UK economic sanctions (8th amendment) in a Nutshell

A fresh round of trade restrictions against Russia was imposed on April 14, 2022.




Quantum computing

They are now illegal for export, supply, or transfer to, or use in, Russia or a person linked with Russia, as well as the provision of relevant technical support, financial services, and brokerage services.


Oil refining goods and technology

They are now illegal for export, supply, or transfer to, or use in, Russia or a person linked with Russia, as well as the provision of relevant technical support, financial services, and brokerage services.


Sophisticated materials goods and technology

They are now illegal for export, supply, or transfer to, or use in, Russia or a person linked with Russia, as well as the provision of relevant technical support, financial services, and brokerage services.


Luxury Items

Certain luxury products are also now illegal for export, supply, or transfer to, or use in, Russia or to a person in Russia.


Iron and Steel Imports

Import, acquisition, supply, and delivery of certain iron and steel goods originating in or consigned from Russia are also prohibited.


Exceptions

There are several exceptions to these limitations, which are detailed in the statute, and licences can only be given in extremely specific circumstances.


OFSI

Financial sanctions are also in place against Russia.


How can businesses stay on the right side of the law?

With all these changes, there is a very real risk that businesses in the United Kingdom may be caught off guard by new fines and find themselves in violation of the law.


So, at Customs Manager, our experts are keen to provide actions that businesses may take to protect themselves from violating sanctions — as well as what they should do if they believe they have done so.


Already in August 2018, the UK government issued a warning to businesses about the danger of violating Russian sanctions. The Department for International Trade (DIT) stated that it had written to over 600 businesses around the country to advise them on what they needed to do to be on the right side of the law.


Businesses need to consider many aspects, here are just two top tips from our sanctions experts:


What kinds of goods or services do you offer? If they require an export or trade licence, or if they are subject to embargoed regimes such as those placed on Russia (but also, for example, North Korea or Syria) you must have the necessary licences in place before making any transactions. If you do not get the necessary licences, your company may face criminal charges from both customs and the Department of International Trade.


Where does your product/service originate? What is the story behind it? It's critical to understand where a product came from and whether any components were made elsewhere. Sanctions law considers the origin of commodities rather than their location at the moment of export. If your items contain more than 10% Russian-derived materials (even if those elements were initially supplied elsewhere).


How we can help

Customs Manager Ltd assists you in effectively navigating sanctions. We provide guidance on the most recent legislation and how it affects you. We assist in the establishment of internal compliance programmes and screen for prohibited parties on your behalf. We provide sanctions training to ensure that you are up-to-date on the current laws and regulations. You can also participate in our online sanctions training. Get in contact if you want to know more


Export Control Training


  • Our EU Export Controls Training Programme offers a comprehensive understanding of the laws, regulations, and practices of export controls in the European Union. The blended learning programme combines online and faces to face training with the aim to deliver a deeper understanding of the complex subject. Find out more

  • Access a complete training programme on the United States Export Control Regulation that explains the impact of US extraterritorial export restrictions on the activities of non-US firms. Learn about suggested best practices for risk mitigation and adherence to stringent US export control EAR regulations. Find out more


More Reading


Check out our more detailed legal analysis of the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022. In this exclusive study, we detail the additional limitations, which augment the penalties imposed in 2014, as well as what firms should do immediately to avoid falling foul of these new measures.


Sanctions make it hard for businesses to trade in certain countries and certain people. Read from your dedicated Global Trade Professionals about the steps companies can take to avoid trading with sanctioned persons.


Countries impose sanctions requiring companies to freeze certain assets from individuals, entities and businesses. But how? Your sanctions specialist explains


The UK applies independent sanctions laws. Your dedicated expert explains why this matters and what businesses can do to avoid the risk of non-compliance


Legislation

The Russia (Sanctions) (EU Exit) Regulations 2019 came fully into force on 31 December 2020. And:


Sources

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