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Jemima Ford

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Introduction During September 2023, the US, UK, and EU, and Japan, updated their Common High Priority Items Lists (“the List(s)”), with seven new Harmonized System (“HS”) codes. These coordinated Lists are composed of items identified as critical to Russia’s war effort, weapons systems and military development. The Lists highlight to businesses that there is a particularly high risk these sanctioned items may be the target of sanctions circumvention and possible diversion to Russia. Companies can…

Following reports in August (see blog post here), on 6 September, the UK government formally announced the proscription of the Wagner Group.  Parliament has passed an order, presented by the Home Secretary, to proscribe the Wagner Group under the Terrorism Act 2000. On 15 September, the order came into force, making it a criminal offence to belong to, encourage support for, assist or use the logo of the Wagner Group. Furthermore, the Wagner Group’s assets…

On 22 August, it was reported that the UK Government is considering the proscription of the Wagner group as a terrorist organisation under the Terrorism Act 2000. The Wagner group is a collection of individuals and entities globally making up the ‘Wagner Network’, which is engaged in military, economic, political, and influencing operations. They are known for being a private military company. Proscribing Wagner as a terrorist organisation would put it in the same legal…