The UK has adopted the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 which introduces new restrictions against Russia.

The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022:

  • Introduce a new restriction against making certain loans or credit available to persons connected with Russia (i.e. an entity incorporated, constituted or domiciled in Russia); subsidiaries of persons connected with Russia; and entities owned by Russian individuals. This essentially extends the scope of the existing credit restrictions to apply to all Russian-owned companies, whether within or outside Russia. As with the previous loans/credit restrictions, there is an exception for foreign-owned Russian companies. The UK has also introduced two General Licences in relation to the above restrictions. These can be found here and here.
  • Prohibit the export, supply and delivery, and making available of goods (and related services) to / for use in Russia that are critical to the functioning of Russia’s economy, in particular the manufacturing sector. The prohibited goods will form the new Russia Vulnerable Goods list. Appropriate licences can be sought for prohibited activity, for example for humanitarian purposes.
  • Add new products to the “G7 Dependency and Further Goods” list which are subject to export prohibitions. The aim of this measure is to further align with the EU’s existing prohibitions to include oil refining technology and manufacturing products, which support strategically important sectors of the Russian economy. Appropriate licences can be sought for prohibited activity, for example for humanitarian purposes.
  • Prohibit the import of LNG which is consigned from or originates in Russia, and the acquisition of LNG (as well as related technical assistance, financial services and funds, and brokering services) which originates or is located in Russia, with the intention of the LNG entering the UK. This measure will be brought into force on 1 January 2023.
  • Expand the list of revenue generating goods included in Schedule 2E. The aim of this measure is to align with the EU to include two Russian product groups: beverages, spirits, and vinegar (including vodka); food waste products (primarily beet pulp). Appropriate licences can be sought for prohibited activity.
  • Prohibit the import of gold (and related services) which has been processed in a third country and incorporates gold that, on or after 21 July 2022, originated in Russia and has been exported from Russia. They also prohibit the import of gold jewellery (and related services) which originates in Russia, is located in Russia and has been exported from Russia (with an exception for personal use, which will also apply to the export of gold jewellery), with the intention of that gold jewellery entering the UK.

The UK has also updated its Russia Guidance to reflect the changes introduced. The updated guidance can be found here.


Tristan Grimmer is a partner in Baker McKenzie's London office and the UK Head of the International Trade Practice Group. He is also a member of the Compliance & Investigations and the International Trade and Competition practice groups. Tristan joined Baker McKenzie as a trainee in March 2004, qualifying in March 2006. He has advised on parallel investigations by authorities in the United States, Switzerland, Brazil and Japan, and has spent time working in Baker McKenzie's Chicago office. Tristan is named as a "Leading Individual" for EU And Competition: Trade, WTO Anti-Dumping and Customs in the UK Legal 500 2023 directory.


Ben Smith is a Partner in Baker McKenzie’s London office and a member of the firm’s Compliance & Investigations and International Trade practice groups. Both these practices are ranked Tier 1 by Legal 500 UK. Ben joined the London office of Baker & McKenzie in September 2007. He has also worked in Baker McKenzie's San Francisco and Brussels offices, as well as on secondment to the legal and compliance teams at three FTSE 100 UK plcs. The Legal 500 UK ranked Ben as a “Rising Star”, noting “Ben Smith is a pleasure to work with. Professional, knowledgeable and always ready to assist with practical solutions.”