Notice

NTE 2024/21: update on Russia sanctions legal services and revocation of legal advisory services general trade licence

Published 6 September 2024

Introduction

The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2024 came into force on 6 September 2024 and amends the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). In particular, the exception set out in regulation 60DB of the Russia Regulations has been amended to make it clear that the provision of legal advisory services, which may otherwise be restricted by regulation 54D of the Russia Regulations, are permitted on or in connection with compliance with global sanctions, Russian counter-sanctions and global criminal law.

The amendment also clarifies that legal advisory services are permitted in relation to the application of punitive measures, as well as in relation to compliance with UK statutory or regulatory obligations.

The amending legislation can be read at The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2024 The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (legislation.gov.uk)

As a result of this amendment the Legal Advisory Services General Trade Licence, which was put in place to facilitate licensing of certain legal services, is no longer required. It was revoked on 6 September 2024, at the point at which the amending regulations came into force.

While the Legal Advisory Services General Trade Licence has been revoked, the provisions of Regulation 76 (General trade licences: records) of the Regulations continue to apply to any act carried out under the authority of this licence.

This means that the records required by this Licence must continue to be kept for a period of 4 years beyond the end of the calendar year in which the record was created and the Provider must permit them to be inspected and copied by any person authorised by the Secretary of State or the Commissioners.

Further guidance and support

Guidance on the scope of sanctions against Russia, including the circumstances in which licences can be granted can be found on the Russia sanctions: guidance page.

For further information on import related sanctions, contact DBT’s Import Licensing Branch, email: importcontrols@businessandtrade.gov.uk.

The Export Support Service is ready to help with any other enquiries about exporting or trading with Russia or Ukraine that are not specific to the requirement for export licences.

Contact Ministry of Justice (MoJ)

General queries about this update Email: ESSCQ@justice.gov.uk

Contact Export Control Joint Unit (ECJU)

General queries about strategic export licensing

Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Email exportcontrol.help@businessandtrade.gov.uk

Telephone 020 7215 4594

Contact Office of Financial Sanctions Implementation (OFSI)

Office of Financial Sanctions Implementation

Office of Financial Sanctions Implementation
HM Treasury
1 Horse Guards Road
London
SW1A 2HQ

Email ofsi@hmtreasury.gov.uk

General enquiries 020 7270 5454

Enquiries relating to asset freezing or other financial sanctions should be submitted to the Office of Financial Sanctions Implementation.

Enquiries relating to the Oil Price Cap on Russian oil should be submitted to oilpricecap.ofsi@hmtreasury.gov.uk

Contact Office of Trade Sanctions Implementation (OTSI)

Office of Trade Sanctions Implementation (OTSI)

Office of Trade Sanctions Implementation (OTSI)
Old Admiralty Building, Admiralty Place
London
SW1A 2DY

Email DBT-OTSI@businessandtrade.gov.uk

If you have an enquiry relating to the establishment of the Office of Trade Sanctions Implementation (OTSI), please contact us.

Otherwise, please continue to use existing channels in government for all other trade sanctions enquiries.

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