On 14 April 2022, the UK government published the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 (“Amendment“), introducing further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (“Regulations“). The Amendment provides for new trade restrictions in relation to:

  • oil refining goods, software and technology;
  • quantum computing and advanced materials goods, software and technology;
  • luxury goods; and
  • the import of iron and steel goods.

We have outlined below the newly introduced sanctions in greater detail. The relevant lists of controlled items are broadly aligned with those under EU sanctions relating to Russia.

New export and related restrictions on oil refining goods and technology and quantum computing and advanced materials goods and technology

The Amendment applies existing measures on ‘Restricted Goods’ and ‘Restricted Technology’ to oil refining goods and technology listed in Schedule 2D and quantum computing and advanced materials goods and technology listed in Schedule 2E, prohibiting the export, supply and delivery, making available and transfer of such items to, or for use in, Russia. This includes the provision of related technical assistance, financial services, funds and brokering services.

New export and related restrictions on luxury goods

The UK has now prohibited the export, supply and delivery, making available and transfer of luxury products listed in Schedule 3A to, or for use in, Russia, or to a person connected with Russia. This also includes the supply or delivery of luxury goods from a third country to a place in Russia, but does not include the typical controls on related technical assistance, financial services, funds and brokering services.

New import restrictions on iron and steel products originating in or consigned from Russia

The Amendment also introduces a new prohibition on the import, acquisition, supply and delivery of iron and steel products listed in Schedule 3B originating in or consigned from Russia.

There are a number of exceptions available from these measures, as well as licensing and enforcement provisions. 

The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022

Additionally, the UK government published the Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022 (“Order“) on the same day. The Order makes the necessary amendments to the Russia (Sanctions) (Overseas Territories) Order 2020 in order to give effect in the relevant British overseas territories (which is all of them apart from Bermuda and Gibraltar) to the changes made to the Russia sanctions regime by the various recent amending regulations.

To read our other posts related to UK-imposed sanctions, click here.

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