Notice

NTE 2024/26: update on Russia sanctions licensing for intra-corporate services

Published 30 September 2024

© Crown copyright 2024

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This publication is available at https://www.gov.uk/government/publications/notice-to-exporters-202426-update-on-russia-sanctions-licensing-for-intra-corporate-services/nte-202426-update-on-russia-sanctions-licensing-for-intra-corporate-services

Introduction

Following a review of the professional and business services sanctions in place under Regulation 54C of the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia sanctions Regulations”), the government has decided to remove the licensing consideration which relates to the provision of such services from UK parent companies and their UK subsidiaries to their Russian subsidiaries.

From 31 October 2024, the provision of intra-corporate services will no longer be listed in the Statutory Guidance as a licensing consideration that is likely to be consistent with the aims of the sanctions regime.

The Secretary of State maintains the discretion to grant licences even where no licensing consideration exists, as per Regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019. This means that any company that wishes to provide intra-corporate services to their Russian subsidiary must explicitly demonstrate how the provision of any ongoing services aligns with the overarching purposes of the sanctions, as set out in Regulation 4 of the Russia sanctions Regulations.

Businesses will be able to apply for a licence using the licensing considerations for activities listed in the guidance.

Licensing applications submitted before 31 October 2024 will not be affected by this Notice.

Further guidance and support

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

Please note that from 10 October 2024, the Office of Trade Sanctions Implementation (OTSI) will take on responsibility for issuing licences for certain sanctioned activity – specifically the provision of standalone services, including professional and business services. Sanctions licensing for the export of goods and the provision of ancillary services (services related to the export of tangible goods) will remain the responsibility of the Export Control Joint Unit (ECJU).

Contact Department of Business and Trade (DBT)

For general queries about this update, please contact tradesanctions@businessandtrade.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 Trade Sanctions Implementation (OTSI)

Office of Trade Sanctions Implementation (OTSI)

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

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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