Russia sanctions: guidance

Question 1

1. Prohibitions and requirements imposed by the Russia (Sanctions) (EU Exit) Regulations 2019

Accepted Answer

The regulations impose financial, director disqualification, trade, aircraft, shipping and immigration sanctions for the purposes of encouraging Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.

In order to achieve the stated purposes, the regulations impose a number of prohibitions and requirements. In order to enforce these, the regulations establish penalties and offences, which are set out in detail in the corresponding report under section 18 of the Sanctions Act in relation to criminal offences.

The prohibitions and requirements imposed by the regulations apply within the territory of the United Kingdom (UK) (including Northern Ireland) and in relation to the conduct of all UK persons wherever they are in the world. UK persons include British nationals, as well as all bodies incorporated or constituted under the law of any part of the UK.

Accordingly, the prohibitions and requirements imposed by the regulations apply to all companies established in any part of the UK, and they also apply to branches of UK companies operating overseas.

The maritime enforcement powers contained in Part 10 of the regulations apply in relation to British ships in international or foreign waters, ships without nationality in international waters and foreign ships in international waters.

It is prohibited to intentionally participate in any activities if you know that the object or effect of them is directly or indirectly to circumvent the prohibitions imposed by the regulations or to enable or facilitate the contravention of those prohibitions.

If you are unclear about any aspect of the regulations, in particular about whether action you are considering taking could contravene the regulations, you are advised to seek independent legal advice.

Prohibitions and requirements for the financial, director disqualification, trade, aircraft, shipping and immigration sanctions contained in the regulations are set out below.

1.1 Non-government controlled territory of Ukraine

The territorial scope of certain measures in the regulations is ‘non-government controlled Ukrainian territory’. This is defined in regulation 2 as ‘Crimea and non-government controlled areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts’.

‘Crimea’ is further defined as the Autonomous Republic of Crimea and the City of Sevastopol.

1.2 Designation of persons

The regulations provide that the Secretary of State may designate persons by name for the purposes of the financial and/or director disqualification and/or immigration and/or aircraft and/or shipping and/or internet services sanctions if they are, or have been, involved in a relevant activity (as defined in regulation 6 of the Russia (Sanctions) (EU Exit) Regulations 2019 (as amended)).

The regulations also make provision for the Secretary of State to provide that persons of a specified description are designated persons for the purposes of the financial and/or immigration and/or aircraft and/or shipping and/or internet services sanctions.

The UK Sanctions List provides details of the people designated under the regulations, and details of the sanctions in respect of which they have been designated.

1.3 Specification of ships

The regulations provide that the Secretary of State may specify a ship for the purposes of shipping sanctions if the ship is, has been, or is likely to be, involved in a relevant activity (as defined in regulation 57F of the Russia (Sanctions) (EU Exit) Regulations 2019 (as amended)).

The regulations also provide that the Secretary of State must specify a ship by its International Maritime Organization number or, where it is not reasonably practicable to identify it by that number, by any other means that the Secretary of State considers appropriate.

The UK Sanctions List [WH1] provides details of the ships specified under the regulations, and details of the sanctions in respect of which they have been specified.

1.4 Financial sanctions

Asset freeze and making available provisions

The regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly. These prohibitions also apply in relation to entities owned or controlled by a designated person.

More information on financial sanctions can be found in the OFSI guidance.

OFSI is the authority for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK. Further information on how OFSI implements financial sanctions can be found on the OFSI pages of GOV.UK.

Other financial and investment restrictions

The regulations prohibit a person from directly or indirectly dealing with a transferable security or money market instrument if it has a maturity exceeding 30 days, and was issued after 1 August 2014 by:

Sberbank, VTB bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank (as listed in Schedule 2)
an entity incorporated or constituted in a country other than the UK which is owned by one or more of the 5 banks listed above
an entity acting on behalf of or at the direction of those 5 banks named above or an entity incorporated or constituted in a country other than the UK which is owned by one or more of those 5 banks

It is also prohibited for a person to directly or indirectly deal with a transferable security or money market instrument if it has a maturity exceeding 30 days, and was issued after 12 September 2014 by:

OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft or Gazprom Neft (as listed in Schedule 2)
an entity incorporated or constituted in a country other than the UK which is owned by one or more of the 6 entities listed above
an entity acting on behalf of or at the direction of those 6 entities named above or an entity incorporated or constituted in a country other than the UK which is owned by one or more of those 6 entities

It is prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued on or after 1 March 2022 by:

an entity incorporated or constituted under the law of the UK and owned by one or more of the entities listed in Schedule 2
an entity acting on behalf or at the direction of the above

It is prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued on or after 1 March 2022 by:

a person connected with Russia (this is defined in regulation 19A(2), and is subject to the exclusions in regulation 16(4D)(a))
an entity owned by such persons
an entity acting on behalf or at the direction of any of the above

It is prohibited for a person to directly or indirectly deal with a transferable security or money market instrument if it was issued:

on or after 15 December 2022
by a relevant entity (i.e. a person who is not a person connected with Russia)
for the purposes of making an investment in relation to Russia (see below)

It is also prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument which was issued on or after 1 March 2022 by the Government of Russia (as defined in regulation 6).

Loan and credit arrangements

The regulations prohibit a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit, with a maturity exceeding 30 days to:

the entities listed in Schedule 2
an entity which is incorporated or constituted under the law of a non-UK country and owned by one or more of the entities listed in Schedule 2, or an entity acting on behalf of or at the direction of either that entity or an entity listed in Schedule 2
an entity which is incorporated or constituted under the law of the UK and owned by an entity listed in Schedule 2, on or after 1 March 2022
a person connected with Russia (this is defined in regulation 19A(2), and is subject to the exclusions in regulation 17(5))

The regulations prohibit granting a new loan or credit arrangement to a relevant entity for the purposes of making an investment in relation to Russia.

The regulations prohibit a person from providing funds to a relevant entity where the purpose of making those funds or economic resources available is to enable a relevant entity to grant a loan that is otherwise prohibited under regulation 17.

The regulations also prohibit a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit to the Government of Russia (as defined in regulation 6), on or after 1 March 2022.

Correspondent banking relationships and sterling payments

The regulations prohibit a UK credit or financial institution from establishing or continuing a correspondent banking relationship with a designated person (or a credit or financial institution which is owned or controlled by such a designated person). In this context, a “designated person” is a person designated for the purposes of regulation 17A.

The regulations also prohibit a UK credit or financial institution from processing a payment (in any currency) to, from or via, a designated person, or a credit or financial institution owned or controlled by a designated person.

The regulations make clear that, for the purposes of the prohibition in regulation 17A(2), processing does not include the initial crediting of a payment to an account which is in the name of a UK credit or financial institution (and not in the name of a customer).

Investments in relation to non-government controlled Ukrainian territory

The regulations prohibit:

directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in land located in non-government controlled Ukrainian territory
directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in an entity which has a place of business located in non-government controlled Ukrainian territory (“a relevant entity”)
directly or indirectly granting any loan or credit, entering into any arrangement to grant a loan or credit or otherwise provide funds, including equity capital, to a relevant entity or for the purpose of financing the relevant entity
directly or indirectly establishing any joint venture in non-government controlled Ukrainian territory or with a relevant entity
providing investment services directly related to the activities referred to in the 4 bullet points above

Provision of financial services for the purpose of foreign exchange reserve and asset management

The regulations prohibit a UK individual or entity from providing financial services for the purpose of foreign exchange reserve and asset management to:

the Central Bank of the Russian Federation
the National Wealth Fund of the Russian Federation
the Ministry of Finance of the Russian Federation
a person owned or controlled directly or indirectly by any of the persons above; or
a person acting on behalf of or at the direction of any of the persons above

“Foreign exchange reserve and asset management” means activities relating to the reserves or assets of the persons listed above. Such reserves or assets include money market instruments (including cheques, bills and certificates of deposit); foreign exchange; derivative products (including futures and options); exchange rate and interest rate instruments (including products such as swaps and forward rate agreements); transferable securities; other negotiable instruments and financial assets (including bullion, such as gold); and special drawing rights. For example, it is prohibited to provide financial services to carry out transactions with the Central Bank of the Russian Federation involving its gold.

Investments in relation to Russia

The regulations prohibit:

direct acquisition of any ownership interest in Russian land and persons connected with Russia
indirect acquisition of any ownership interest in Russian land and persons connected with Russia for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia
direct or indirect acquisition of any ownership interest in entities (which are not persons connected with Russia) for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia
establishing joint ventures with a person connected with Russia
opening representative offices and establishing branches and subsidiaries in Russia; or
the provision of investment services directly related to all activities above

Trust Services

The regulations prohibit:

the provision of trust services to or for the benefit of persons designated for the purposes of this measure, and
the provision of trust services to or for the benefit of persons connected with Russia unless those services were provided immediately prior to the day the regulations come into force pursuant to an arrangement that has effect at that time

“Trust services” means:

the creation of a trust or similar arrangement
the provision of a registered office, business address, correspondence address or administrative address for a trust or similar arrangement
the operation or management of a trust or similar arrangement
acting or arranging for another person to act as trustee of a trust or similar arrangement
acting as a nominee shareholder

Trust services are provided “for the benefit of” where the person (“P”):

is a beneficiary of a trust or similar arrangement,
is a potential beneficiary in a document from the settlor relating to a trust or similar arrangement (such as a letter of wishes), or
having regard to all the circumstances, P might reasonably be expected to obtain, or be able to obtain, a significant financial benefit from the trust or similar arrangement.

“beneficiary”, “potential beneficiary” and “settlor”, in relation to an arrangement similar to a trust, means those individuals who hold equivalent or similar positions to those described in the sub-paragraphs above in respect of a trust.

Suspension of Banking Act 2009 requirement to recognise third-country resolution actions

The regulations disapply the Bank of England’s statutory duty under section 89H(2) of the Banking Act 2009 to make a decision in respect of recognition notifications from third-country resolution authorities where:

the resolved bank or financial institution is a designated person subject to an asset freeze; or
the resolved bank or financial institution is owned or controlled directly or indirectly by such a designated person.

This means that the Bank of England will not make a decision under section 89(H)(2), that is to recognise, partially recognise or refuse to recognise a third-country resolution action, for as long as the resolved institution in question is designated as subject to an asset freeze or is owned or controlled directly or indirectly by a person who is designated as subject to an asset freeze under the Russia Regulations.

1.5 Director disqualification sanctions

Where a person is designated under regulation 5 for the purpose of director disqualification sanctions under regulation 19B, this means that they are subject to the provisions of section 11A of the Company Directors Disqualification Act 1986 (CDDA) and Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 (CDD(NI)O).

The effect of the provision is to disqualify persons designated for this purpose under regulation 5 from being a director of a UK company or directly or indirectly taking part in or being concerned in the promotion, formation or management of a company.

Under section 11A of CDDA (and, in Northern Ireland, under the equivalent Article 15A of CDD(NI)O), it will be an offence for a person subject to ‘director disqualification sanctions’ as set out in section 3A of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) to act as a director of a company or directly or indirectly to take part in or be concerned in the promotion, formation or management of a company, unless a licence has been issued by virtue of the powers granted in section 15(4A) of SAMLA and set out in regulation 64A.

Companies House and the Department for the Economy (Northern Ireland) are responsible for recording information about director disqualification sanctions in their respective Disqualified Director Registers. Companies House is responsible for annotating the Companies Register and preventing registration of a disqualified director’s appointments. The Insolvency Service will assess and grant or refuse licence applications on behalf of the Secretary of State. The Insolvency Service also has the power to bring prosecutions for breaches of the legislation, and, where appropriate, to refer cases to other law enforcement agencies for potential prosecution.

1.6 Trade sanctions

The regulations impose trade prohibitions relating to:

military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
anything which falls within Chapter 93 of the Goods Classification Table[^1], other than military goods
defence and security goods and defence and security technology (as specified in Schedule 3C) and including interception and monitoring goods and interception and monitoring technology)
dual-use goods and technology (as specified in Annex I to Council Regulation 428/2009 as retained by the European Union (Withdrawal) Act 2018 (‘the Dual-Use Regulation’))
special materials and related equipment and materials processing (as specified in Parts 1A and 1B of Schedule 2A to the Regulations)
critical-industry goods and technology (as specified in Schedule 2A to the Regulations)
quantum computing and advanced materials goods and technology (as specified in Schedule 2E to the Regulations)
aviation and space goods and technology (as specified in Schedule 2C to the Regulations)
jet fuel and fuel additives (as specified in Part 8 of Schedule 2A to the Regulations)
maritime goods and maritime technology (defined by reference to Chapter 4 (Navigation Equipment) and Chapter 5 (Radio-Communication Equipment) of Annex 1 of Merchant Shipping Notice 1874(a))
infrastructure-related goods (as specified in Part 3 of Schedule 3 to the Regulations)
energy-related goods (as specified in Part 2 of Schedule 3 to the Regulations) and energy-related services
oil refining goods and technology (as specified in Schedule 2D to the Regulations)
luxury goods (as specified in Schedule 3A to the Regulations)
G7 dependency and further goods (as specified in Schedule 3E to the Regulations)
goods originating in non-government controlled Ukrainian territory
iron and steel products (as specified in Schedule 3B to the Regulations) and associated ancillary services
iron and steel products processed in a third country (as specified in Part 1, 2 and 3 of Schedule 3B to the Regulations) and associated ancillary services, from 30 September 2023
metals (as specified in Schedule 3BA to the Regulations)
oil and oil products (as specified in Schedule 3F to the Regulations)
the supply or delivery by ship of oil and oil products under the commodity codes 2709 and 2710 from Russia to and between third countries and related services
coal and coal products (as specified in Schedule 3H to the Regulations)
liquefied natural gas (as specified in Chapter 4L to the Regulations)
gold, gold jewellery and products related to gold (as specified in Schedule 3G to the Regulations)
banknotes denominated in sterling and any official currency of the European Union
goods which generate significant revenues for Russia (as specified in Schedule 3D and Schedule 3DA to the Regulations)
diamonds and diamond jewellery (as specified in Schedule 3GA to the Regulations)
certain diamonds processed in third country
Russia’s vulnerable goods (as specified in Schedule 3I to the Regulations)
provision of technical assistance, armed personnel, financial services or funds, or associated brokering services where such provision enables or facilitates the conduct of certain military activities
services relating to a relevant infrastructure sector in non-government controlled Ukrainian territory
services relating to tourism in non-government controlled Ukrainian territory
internet services
professional and business services (as specified in Chapter 6B to the Regulations)

Technical Guidance on interception and monitoring

There are circumstances (set out in the relevant lists of controlled items) in which certain items are not controlled, for example when body armour or a helmet is accompanying a person for that person’s own protection. Please check the relevant lists as applicable.

Energy-related goods, infrastructure-related goods, aviation and space goods, oil refining goods, G7 dependency and further goods, luxury goods, iron and steel products, metals, revenue generating goods, Russia’s vulnerable goods, coal and coal products, oil and oil products, gold and diamonds are identified by reference to commodity codes in the Goods Classification Table. The UK Tariff sets out a system for the classification of goods for importers to ascertain the applicable rate of import duty for their goods. It is this system of classification that is used in the regulations in order to determine whether these goods are within scope of the prohibitions.

This means that where commodity codes are used in the regulations, the relevant goods are those which would be classified under the relevant commodity code (applying the rules in the UK Tariff) if the goods were being imported to the UK.

Some of the listings of commodity codes in the regulations have an “ex” before the code. Where this “ex” appears before a commodity code this means the prohibitions in the regulations do not apply to all of the items under that commodity code. The prohibitions will only apply to those items that (1) would be classified under the commodity code and (2) match the description given next to the relevant “ex” code entry in the regulations.

European Union sanctions measures as pertain to the import and export of goods automatically apply in Northern Ireland. Traders should refer to the UK Integrated online Tariff and the Northern Ireland Integrated Online Tariff to confirm what import duties apply in Northern Ireland. EU import and export restrictions on goods are detailed in Council Regulations (EU) No 833/2014 as amended from time to time. Be sure to consider the most updated version of that regulation.

Further detail on these trade prohibitions, including key terminology used, is explained below. Please have regard to the relevant legislation which contains full definitions of terms used herein.

Export of goods

The concept of ‘export’ is set out in customs legislation, but is further detailed in Paragraph 32 of Schedule 1 to the Sanctions Act, which clarifies that “export” means export from the UK, but does not capture where goods are removed to the Isle of Man from the UK. For the purposes of Chapter 4JA (gold jewellery and relevant processed gold), the concept of ‘export’ refers to export from Russia, which is defined within the chapter itself.

The export prohibitions at regulation 22 (restricted goods) prohibit the export of certain goods to Russia as well as exports that are for use in Russia. This means that, even if the immediate destination is not Russia, the prohibition may still apply.

Regulation 30B prohibits the export of relevant restricted goods to non-government controlled Ukrainian territory.

Regulation 40 prohibits the export of energy-related goods to, or for use in, Russia.

Regulation 46B prohibits the export of luxury goods to, or for use in, Russia. According to Part 2 of Schedule 3A (Luxury Goods), “sales price! threshold means the sales price of the item or quantity specified excluding value added taxes but including freight/transport costs.

Regulation 46M prohibits the export, supply or delivery and making available of sterling or European Union denominated banknotes to, or for use in, Russia or to a person connected with Russia.

Regulation 46N prohibits the export of jet fuel and fuel additives to, or for use in, Russia.

The export prohibitions in Chapter 5 (infrastructure-related goods) prohibit certain exports to and for use in non-government controlled Ukrainian territory. This means that, even if the immediate destination is not non-government controlled Ukrainian territory, the prohibition may still apply.

Regulation 46Y prohibits the export, supply or delivery, and making available of G7 dependency and further goods to, or for use in, Russia.

Regulation 46Z30 prohibits the export of Russia’s vulnerable goods to, or for use in Russia. This measure came into force on 1 January 2023.

Exporters should check the ultimate end use of goods and may apply for a licence or contact the Export Control Joint Unit (ECJU) if they know or think the items may be used in Russia or in non-government controlled Ukrainian territory.

A sanctions licence is not required for exports of non-military goods covered by the regulations from Northern Ireland to an EU Member State where the final destination is Russia or non-government controlled Ukrainian territory (as applicable). You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to Russia or non-government controlled Ukrainian territory. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.

Import of goods

The concept of ‘import’ is set out in customs legislation but is further detailed in Paragraph 33 of Schedule 1 to the Sanctions Act. This clarifies in particular that goods removed to the UK from the Isle of Man are not to be regarded as imported. Paragraph 34 details limited exceptions to this.

The import prohibitions in regulation 23 (arms and related materiel), regulations 46D and 46IB (iron and steel products), 46IG (metals) regulations 46S and 46XB (Schedules 3D and 3DA revenue generating goods), regulation 46Z4 (oil and oil products), regulation 46Z18 (coal and coal products), 46Z16K (diamonds and diamond jewellery) and 46Z25 (liquefied natural gas) cover goods that are consigned from Russia and goods that originated in Russia. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

The import prohibitions in regulation 47 cover imports of goods which originated in non-government controlled Ukrainian territory. This means that even if the immediate place the goods were shipped from was not non-government controlled Ukrainian territory, the prohibition may still apply.

The import prohibition in regulation 46Z11 (Chapter 4J) covers gold (Part 2 of Schedule 3G) that originates in Russia, where this is exported from Russia on or after 21 July 2022. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply if the Russian origin gold was exported from Russia on, or after, 21 July 2022.

The import prohibition in regulation 46Z16B (Chapter 4JA) covers gold jewellery (Part 3 of Schedule 3G) that originates in Russia, where this is exported from Russia on or after 29 October 2022. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply if the Russian origin gold jewellery was exported from Russia on or after 29 October 2022.

The import prohibition in regulation 46Z16C (Chapter 4JA) covers relevant processed gold, defined as gold (Part 2 of Schedule 3G) that has been processed in a third country and incorporates gold that, on or after 21 July 2022, originated in and has been exported from Russia. This means that even if the immediate place the goods were shipped from or processed in was not Russia, the prohibition may still apply if the goods incorporate gold that originated in and has been exported from Russia on or after 21 July 2022.

Therefore, importers should check the original place goods were consigned or exported from and apply for a licence or contact DBT’s Import Controls Team if they think the items may have originated in or have been consigned from Russia or non-government controlled Ukrainian territory.

A sanctions licence is not required for imports from an EU Member State into Northern Ireland of non-military goods covered by the regulations which originate in or are consigned from Russia or non-government controlled Ukrainian territory (as applicable). You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the original import into the customs territory of the EU. You will also have to comply with any other licensing requirements under UK import control legislation as applicable.

The import prohibition in regulation 46IA and 46IB (Chapter 4CA) on relevant iron and steel products processed in third countries which incorporate relevant iron and steel products of Russian origin applied from 30 September 2023. Please refer to the Notice for Importers for specific guidance on the scope of the measure, and how businesses can demonstrate compliance.

The import prohibition in regulation 46Z16R (Chapter 4JC) on certain diamonds processed in third countries and of Russian origin applies from 1 March 2024 for diamonds larger than or equal to 1 carat or 0.2 grams (or equivalent) in weight. From 1 September 2024 it applies to certain diamonds larger than or equal to 0.5 carats or 0.1 grams (or equivalent) in weight. Please refer to the Notice for Importers for specific guidance on the scope of the measure and how business can demonstrate compliance.

Supply and delivery of goods

Supply and delivery prohibitions in the regulations prohibit a person from directly or indirectly supplying or delivering certain goods from a third country to a place in Russia (or to non-government controlled Ukrainian territory in respect of Chapter 5, infrastructure-related goods) or from a place in Russia to a third country and between third countries.

Regulation 24 (restricted goods), regulation 41 (energy related goods), regulation 46B (luxury goods), regulation 46N (jet fuel and fuel additives), regulation 46Y (G7 dependency and further goods), and 46Z30 (Russia’s vulnerable list) prohibit the direct or indirect supply or delivery from a third country to a place in Russia.

Regulation 30C prohibits the direct or indirect supply or delivery of relevant restricted goods from a third country to a place in non-government controlled Ukrainian territory.

Regulation 46F (iron and steel products) prohibits the direct or indirect supply or delivery of certain iron and steel products from a place in Russia to a third country.

Regulation 46II (metals) prohibits the direct or indirect supply or delivery of metals from a place in Russia to a third country.

Regulation 46M (banknotes) prohibits the direct or indirect supply or delivery or making available of sterling banknotes or any banknotes denominated in any official currency of the European Union to a person connected with Russia. It also prohibits making available such banknotes for use in Russia.

Regulation 46XD (Schedule 3DA revenue generating goods) prohibits the direct or indirect supply or delivery of revenue generating goods listed in Schedule 3DA from a place in Russia to a third country.

Regulation 46Z9B (Maritime transportation of certain oil and oil products to and between third countries) prohibits the direct or indirect supply or delivery by ship of oil and oil products under the commodity codes 2709 and 2710 from a place in Russia to a third country or between third countries.

Regulation 46Z16M (diamonds and diamond jewellery) prohibits the direct or indirect supply and delivery of diamonds and diamond jewellery from a place in Russia to a third country.

Regulations 24(4) and 41(4) specify that for the purposes of those prohibitions a “third country” is a country that is not the UK, Isle of Man or Russia. Regulation 49(4) specifies that for the purposes of that prohibition a “third country” is a country that is not the UK, Isle of Man or non-government controlled Ukrainian territory.

Making available or acquiring goods and technology

Prohibitions in the regulations (aside from those in Chapter 5) on making certain goods or technology available (e.g. through a sale) include directly or indirectly making them available for use in Russia or to a “person connected with Russia”. Some of the prohibitions also prohibit directly or indirectly acquiring certain goods or technology which originate in Russia or which are located in Russia or from a person connected with Russia.

For Schedule 3D revenue generating goods (regulation 46T), oil and oil products (regulation 46Z5), coal and coal products (regulation 46Z19), and liquefied natural gas (regulation 46Z26), the direct and indirect acquisition of those goods, which originate in or are located in Russia, with the intention of those goods entering the United Kingdom is prohibited.

For gold (regulation 46Z12) and gold jewellery (regulation 46Z16D) the direct and indirect acquisition of those goods, which originate in and which are located in, or (in the case of gold jewellery) have been exported after 29 October 2022 from Russia, with the intention of those goods entering the United Kingdom is prohibited.

For iron and steel products (regulation 46E), metals (regulation 46IH), Schedule 3DA revenue generating goods (regulation 46XC), and diamonds and diamond jewellery (regulation 46Z16L), the direct and indirect acquisition of those goods, which originate in Russia or are located in Russia is prohibited regardless of whether the person acquiring them intends to bring the goods into the United Kingdom.

Regulation 42 prohibits making energy related goods available for use in Russia or to a person connected with Russia.

Prohibitions in Chapter 5 on making infrastructure-related goods available include directly or indirectly making them available for use in non-government controlled Ukrainian territory or to a “person connected with non-government controlled Ukrainian territory”.

Regulation 21 sets out when a person is to be regarded as “connected with” Russia and when a person is to be regarded as “connected with” non-government controlled Ukrainian territory (and this applies where these terms are used in other trade prohibitions in this part of the regulations).

Transfer of technology

Prohibitions in the regulations on the transfer of certain technology include transfer to a place in Russia or a person connected with Russia.

Regulation 26 (restricted technology) also prohibits transfer to persons outside the UK or to a place outside the UK, where the transfer is from a place in Russia.

The term ‘transfer’ is defined in Paragraph 37 of Schedule 1 to the Sanctions Act, which states that it ‘means a transfer by any means (or combination of means), including oral communication and that transfer of goods on which the technology is recorded or from which it can be derived, other than the export of such goods.’

Where restricted technology is contained within a good, that good would be classified, respectively, as a restricted good under the accompanying goods-related provisions. This includes information contained on USB memory devices, laptops, tablets and the like.

Technical assistance

The term “technical assistance” in relation to goods or technology is defined in regulation 21, which states that it means:

technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or
any other technical service relating to the goods or technology

Prohibitions apply where the technical assistance relates to certain specified goods or technology.

The prohibitions apply to the direct or indirect provision of such technical assistance in relation to goods covered by an export prohibition (1) to persons “connected with Russia” or (2) for use in Russia, except those in Chapter 5 which apply where the provision applies (1) to persons “connected with non-government controlled Ukrainian territory” or (2) for use in non-government controlled Ukrainian territory.

This means that, even if the person to whom you are providing the relevant technical assistance is not in or “connected with Russia” (or non-government controlled Ukrainian territory, for Chapters 2A and 5), the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Russia (or non-government controlled Ukrainian territory, for Chapters 2A and 5). Therefore, if you are providing technical assistance, you should check whether the goods or technology may be used in Russia or non-government controlled Ukrainian territory, as appropriate, and apply for a licence or contact ECJU if so.

Regulation 46A prohibits the direct or indirect provision of technical assistance to or for the benefit of persons designated for the purpose of this regulation, where that assistance relates to an aircraft or ship. The persons designated for the purposes of this provision are set out in the UK Sanctions List under ‘sanctions imposed’.

The prohibition applies in relation to any aircraft or ship. You should carry out your own checks to determine to whom, or for whose benefit, you are providing technical assistance related to aircraft or ships.

In relation to goods covered by prohibitions on import, [supply and delivery or acquisition], the measures apply to the direct or indirect provision of technical assistance relating to the import, [supply and delivery] or acquisition of the prohibited goods.

The following regulations prohibit the direct or indirect provision of technical assistance to specific arrangements:

Regulation 27 (relating to restricted goods and restricted technology)
Regulation 30F (relating to relevant restricted goods and relevant restricted technology in relation to non-government controlled Ukraine)
Regulation 43 (relating to energy-related goods)
Regulation 46A (relating to aircraft and ships)
Regulation 46BA (relating to luxury goods)
Regulations 46G and 46IC (relating to iron and steel products)
Regulation 46O (relating to jet fuel and fuel additives)
Regulation 46V (relating to Schedule 3D revenue generating goods)
Regulation 46XE (relating to Schedule 3DA revenue generating goods)
Regulation 46Z (relating to G7 dependency and further goods)
Regulation 46Z7 (relating to oil and oil products)
Regulation 46Z14 (relating to gold)
Regulation 46Z16E (relating to gold jewellery)
Regulation 46Z16F (relating to relevant processed gold)
Regulation 46Z16N (relating to diamonds and diamond jewellery)
Regulation 46Z16S (relating to certain diamonds processed in a third country)
Regulation 46Z21 (relating to coal and coal products)
Regulation 46Z27 (relating to liquefied natural gas)
Regulation 46Z31 (relating to Russia’s vulnerable goods)
Regulation 51 (relating to infrastructure-related goods in relation to non-government controlled Ukraine)

‘Financial services’ refer to any services of a financial nature in many different forms including insurance and banking. Financial services include payment and money transmission services. The full definition of ‘financial services’ can be found in Section 61 of the Sanctions Act.

‘Funds’ means financial assets and benefits of every kind, including cash, securities and interest. The full definition of ‘funds’ can be found in Section 60 of the Sanctions Act.

Trade sanctions prohibitions on the provision of financial services and funds apply where they relate to certain specified goods or technology.

The prohibitions in the regulations apply to the direct or indirect provision of financial services, and the direct or indirect making available of funds to persons connected with Russia (or non-government controlled Ukrainian territory, in respect of Chapters 2A and 5).

These prohibitions also prohibit the direct or indirect provision of financial services or funds in pursuance of or in connection with specific arrangements involving Russia (or non-government controlled Ukrainian territory in respect of Chapters 2A and 5).

The following regulations prohibit the direct or indirect provision of financial services to specific arrangements:

Regulation 28 (relating to restricted goods and restricted technology)
Regulation 30G (relating to relevant restricted goods and relevant restricted technology in relation to non-government controlled Ukraine)
Regulation 44 (relating to energy-related goods)
Regulation 46BB (relating to luxury goods)
Regulations 46H and 46ID (relating to iron and steel products)
Regulation 46P (relating to jet fuel and fuel additives)
Regulation 46W (relating to Schedule 3D revenue generating goods)
Regulation 46XF (relating to Schedule 3DA revenue generating goods)
Regulation 46Z1 (relating to G7 dependency and further goods)
Regulation 46Z8 (relating to oil and oil products)
Regulation 46Z9C (relating to maritime transportation of certain oil and oil products)
Regulation 46Z15 (relating to gold)
Regulation 46Z16G (relating to gold jewellery)
Regulation 46Z16H (relating to relevant processed gold)
Regulation 46Z16O (relating to diamonds and diamond jewellery)
Regulation 46Z16T (relating to certain diamonds processed in a third country)
Regulation 46Z22 (relating to coal and coal products)
Regulation 46Z28 (relating to liquefied natural gas)
Regulation 46Z32 (relating to Russia’s vulnerable goods)
Regulation 52 (relating to infrastructure-related goods in relation to non-government controlled Ukraine)

Brokering services

The definition of ‘brokering services’ is set out in regulation 21, which states that it means any service to secure, or otherwise in relation to, an arrangement, including (but not limited to):

the selection or introduction of persons as parties or potential parties to the arrangement
the negotiation of the arrangement
the facilitation of anything that enables the arrangement to be entered into, and
the provision of any assistance that in any way promotes or facilitates the arrangement

The regulations prohibit the direct or indirect provision of brokering services where they relate to specific arrangements. Those arrangements are set out in:

Regulation 29 (non-UK activity relating to restricted goods and restricted technology)
Regulation 30H (non-UK activity relating to the non-government controlled Ukrainian territory limited goods and non-government controlled Ukrainian territory limited technology)
Regulation 45 (non-UK activity relating to energy-related goods and energy-related technology)
Regulation 46BC (relating to luxury goods)
Regulations 46I and 46IE (relating to iron and steel products)
Regulation 46Q (relating to jet fuel and fuel additives)
Regulation 46X (relating to revenue generating goods)
Regulation 46XG (relating to Schedule 3DA revenue generating goods)
Regulation 46Z2 (relating to G7 dependency and further goods)
Regulation 46Z9 (relating to oil and oil products)
Regulation 46Z9D (relating to maritime transportation of certain oil and oil products)
Regulation 46Z16 (relating to gold)
Regulation 46Z16I (relating to gold jewellery and relevant processed gold)
Regulation 46Z16P (relating to diamonds and diamond jewellery)
Regulation 46Z16U (relating to certain diamonds processed in a third country)
Regulation 46Z23 (relating to coal and coal products)
Regulation 46Z29 (relating to liquefied natural gas)
Regulation 46Z33 (relating to Russia’s vulnerable goods)
Regulation 53 (non-UK activity relating to infrastructure-related goods and goods from non-government controlled Ukrainian territory)

Other service provisions

Certain other services are prohibited in the regulations. These include the provision of certain services which enable or facilitate certain military activities, insurance and reinsurance services, energy-related services, infrastructure-related services, tourism-related services, internet services, other professional and business services, which in the regulations refers to accounting, advertising, architectural, auditing, business and management consulting, engineering, IT consultancy and design, public relations services, and legal advisory services.

As set out in regulation 30, the direct or indirect provision of the following services is prohibited where such provision enables or facilitates the conduct of military activities carried on or proposed to be carried on by the Russian military or any other military end-user who is a person connected with Russia:

a) technical assistance

b) armed personnel

c) financial services or funds, or

d) brokering services in relation to an arrangement whose object or effect is to provide, in a non-UK country any of the services mentioned in paragraphs (a) - (c)

Provisions on insurance and reinsurance services are set out in regulation 29A and prohibit the direct or indirect provision of insurance and reinsurance services where it relates to aviation and space goods and aviation and space technology.

The prohibitions apply to the direct or indirect provision of insurance and reinsurance services (1) to persons “connected with Russia” or (2) for use in Russia. This means that, even if the person to whom you are providing the relevant insurance or reinsurance service is not in or “connected with Russia” (as defined in regulation 21), the prohibition may still apply if the goods or technology to which the service relates are for use in Russia.

It would not apply where the insurance is for the benefit of the non-Russian owner of the items, rather than their user or operator. Nor does it apply where the items either remain in Russia as the result of the termination of a lease and against the lessor’s will; or are being flown out of Russia in the process of returning them to their owner.

The provision of insurance and reinsurance services in respect of a satellite where the only nexus with Russia is that it is orbiting over Russia, or broadcasting to Russia (and where the insurance and reinsurance services will not be provided to a person connected with Russia), would likewise not come within the scope of these prohibitions.

Therefore, if you are providing insurance or reinsurance services you should check whether the goods or technology may be used in Russia, and apply for a licence or contact ECJU if so.

Provisions on energy-related services are set out in regulation 46 and prohibit the direct or indirect provision of “relevant energy services”, defined as certain “specified services” necessary for an “oil or gas exploration or production project” in Russia. The specified services being drilling, well testing, logging and completion services, and the supply of specialised floating vehicles.

Provisions on infrastructure-related services and tourism-related services are set out in regulation 54 and prohibit the provision of services relating to certain specified infrastructure sectors or services relating to tourism in non-government controlled Ukrainian territory.

Provisions on internet services are set out in regulation 54A and require social media companies, and internet service providers, to take reasonable steps to prevent their users from encountering or accessing services or content online directly generated, shared or uploaded by a designated person. Application store providers must also take reasonable steps to prevent users from using their services to download or access internet services provided by a designated person. Designations for the purposes of these measures will be made by the Secretary of State and published on the UK Sanctions List.

Therefore, if you are an internet service provider, or provide a social media service or application store for internet service applications, then you should check whether an entity has been designated by the UK Government for this purpose and take the necessary action to ensure compliance with the prohibitions.

Regulation 46K prohibits the provision of interception and monitoring services to, or for the benefit of, the Government of Russia (as defined in regulation 6).

Technical guidance on interception and monitoring

Prohibitions on the provision of professional and business services (accounting, advertising, architectural, auditing, business and management consulting, engineering, IT consultancy and design, and public relations services) are set out in regulation 54C. These prohibit the direct or indirect provision of such services to persons connected with Russia.

The provision of legal advisory services is restricted under the regulations, including by the circumvention measures in regulations 19 and 55.

Regulation 54D supplements these general restrictions and specifically prohibits legal advisory services to a non-UK person, where the object or effect of those services is to enable or facilitate certain financial or trade activity which would be prohibited under the UK sanctions regime if the activity was done by a UK person or taking place within the UK.

Regulation 60DB provides for exceptions in relation to the prohibition on the provision of legal advisory services.

Provision of services via any or all of modes of service supply 1, 2, 3, or 4, as defined under the World Trade Organization’s General Agreement on Trade in Services (GATS), to any person connected with Russia is covered by the prohibitions. This would include the cross-border supply of such services by a UK services provider to another company incorporated under Russian law and the provision of services to Russian residents who are temporarily located in another country, including the UK.

Please refer to Schedule 3J in the regulations for the definitions of prohibited services. Several of these definitions are presented as references to Central Product Classification (CPC) codes. Where they are presented in this way, it is recommended that you review your activity against the correct version (for example: Provisional, 1.0, 1.1, 2, or 2.1) and individual code numbers (for example, “CPC 8671 – Architectural services”) that correspond to each prohibition. This information will enable you to navigate to the relevant definitions at the following link: CPC Codes.

Though the accounting and auditing services definitions are based on CPC codes, they are defined in Schedule 3J for clarity, given the differences in exceptions and licensing which apply to these 2 sectors. The definition of accounting services is based on the Provisional CPC Codes 1991 and includes CPC 86212 Accounting Review Services, CPC 86213 Compilation of Financial Statements services, CPC 86219 Other Accounting Services and CPC 86220 Bookkeeping Services, except tax returns. The definition of auditing services is also based on the Provisional CPC Code 1991, CPC 86211 Financial Auditing Services.

The definitions of business and management consulting and public relations services are not based on CPC codes, but instead on Extended Balance of Payments Services classification (EBOPS) 2010 and includes EBOPS 10.2.1.3 - (Business and management consulting and public relations services includes advisory, guidance and operational assistance services provided to businesses for business policy and strategy, and the overall planning, structuring and control of an organization.)

DBT contact details

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out. If you want to carry out activity which falls under the remit of more than one licensing body, you will need to submit separate licence applications to each one.

For further information on licensing, compliance and enforcement for trade sanctions relating to standalone services, contact the Office of Trade Sanctions Implementation (OTSI).

For further information on export controls and trade sanctions relating to the export of goods and provision of ancillary services, contact ECJU.

For further information on import controls, contact DBT’s Import Licensing Branch at importcontrols@businessandtrade.gov.uk

1.7 Transport sanctions

The regulations impose transport prohibitions relating to aircraft and shipping.

Shipping sanctions

The regulations prohibit Russian ships, and other ships specified by the Secretary of State, from entering ports in the United Kingdom. The regulations also confer powers on the Secretary of State and harbour authorities to issue port barring directions to the master or pilot of a specified ship. The regulations provide the Secretary of State with a power to control the movement of Russian ships or specified ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are.

The regulations prohibit the registration of ships owned, controlled, chartered or operated by designated persons or persons connected with Russia on the UK Ship Register and confer powers on the Secretary of State to direct the UK Ship Registrar to terminate the registration of such ships.

The regulations also confer powers on the Secretary of State and harbour authorities to detain Russian ships or specified ships at ports or anchorages.

‘Russian ship’ is not a term used in the regulations. However, it is used in this shipping section of the guidance to aid understanding and readability. It means a ship which is:

owned, controlled, chartered or operated by a designated person
owned, controlled, chartered or operated by persons connected with Russia
registered in Russia, or
flying the flag of Russia

These sanctions do not apply to other ships originating from or destined for Russian ports; ships carrying cargo to or from Russia are not within scope of the transport sanctions unless they fall within the definition of a Russian ship or specified ship as above. These regulations do not apply to ships (that are not otherwise included in the regulations) with Russian crews or Masters, unless they are a designated person.

The regulations also provide the Secretary of State with the power to issue directions in relation to the movement of British cruise ships, preventing them from entering any ports located in Crimea, or in the non-government controlled areas of the Donetsk, Luhansk, Kherson, and Zaporizhzhia oblasts. Such a direction can be given to any master or pilot of a British ship which is a cruise ship (defined as a ship which is providing cruise services).

Aircraft sanctions

The regulations prohibit a Russian aircraft which is owned, chartered or operated by persons connected with Russia or designated persons from overflying the United Kingdom or landing in the United Kingdom.

In addition, they provide a power for the Civil Aviation Authority (CAA) to refuse to register an aircraft or for the Secretary of State to direct the CAA to terminate the registration of an aircraft that is owned or operated by a designated person or chartered by a designated person.

They confer direction making powers for the Secretary of State, air traffic control and airport operators regarding aircraft movements in United Kingdom airspace and at United Kingdom airports. The regulations also provide a power for the Secretary of State to direct an airport operator to secure the detention of a Russian aircraft at an airport or to secure the movement of a Russian aircraft to a specified airport.

Russian aircraft is defined as an aircraft:

owned, chartered or operated by a designated person, or a person connected with Russia, or
registered in Russia

DfT is ultimately responsible for the implementation of these transport restrictions, some of which are enforced through the Maritime and Coastguard Agency, harbour authorities, National Air Traffic Services Limited (NATS), CAA and airport operators.

1.8 Immigration sanctions

The effect of the regulations is to impose a travel ban on persons designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. Such persons are excluded persons for the purposes of Section 8B of the Immigration Act 1971.

Designated individuals will be refused leave to enter or remain in the UK. Any application they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban under the regulations, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK.

If you are the subject of an immigration sanction and try to travel to the UK, carriers are required to deny you boarding.

Further information on how the Home Office deals with those who are subject to a travel ban can be found on the Home Office pages of GOV.UK.

1.9 Information and record keeping

Part 8 of the regulations places obligations on relevant firms (the definition of which is set out in the regulations) to report information to HM Treasury about known or suspected designated persons or about persons who may have breached a prohibition or failed to comply with an obligation under specified provisions of the Regulations.

Part 8 places further obligations on relevant firms to report to HM Treasury the nature and amount or quantity of any funds or economic resources that it knows or suspects that it holds for the Central Bank of Russia, Russian Ministry of Finance, Russian National Wealth Fund, persons owned or controlled directly or indirectly by these entities or persons acting on behalf of or at the direction of these entities.

It also grants powers to HM Treasury to request information from, amongst others, a designated person, including powers to request the production of documents. It also establishes offences for failing to comply with these requests (including for providing false information).

Part 8 of the regulations places an obligation on persons designated under the Russia regime to report the nature, value and location of their assets.

Part 8 also establishes information powers and record-keeping responsibilities in relation to the trade sanctions contained in the regulations. It provides for offences for failing to comply with any of those requirements or intentionally obstructing an official in the exercise of those powers.

If you have obligations or responsibilities under Part 8 of the regulations, it is important that you familiarise yourself with them. If you are unclear of your obligations or responsibilities, you are advised to seek independent legal advice.

Question 2

2. How will these sanctions measures be enforced?

Accepted Answer

The regulations make it a criminal offence to contravene the trade, aircraft, shipping and financial sanctions, as well as to enable or facilitate a contravention of, or to circumvent, any of the prohibitions in the regulations. They also prescribe the mode of trial and penalties that apply to such offences. In some cases, offences related to contraventions of prohibitions in the regulations are contained within other legislation, such as the Customs and Excise Management Act 1979 (CEMA).

In addition to the below, further details on offences and penalties can be found in the corresponding report under section 18 of the Sanctions Act.

2.1 Financial sanctions

Breaches of financial sanctions (as set out in the Regulations and as listed at 1.4 above) are a serious criminal offence. Any breach of the main financial prohibitions in the regulations is an offence that is triable either way and carries a maximum sentence on indictment of 7 years’ imprisonment or a fine (or both).

Offences under regulations 70(6), 70A(6) and 74 (information offences in connection with financial sanctions under the regulations) are summary offences only and carry a maximum sentence of 6 months’ imprisonment or a fine (which in Scotland or Northern Ireland may not exceed level 5 on the standard scale) or both.

OFSI is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose monetary penalties for breaches of financial sanctions and to refer cases to law enforcement agencies for investigation and potential prosecution.

OFSI works with other parts of government, supervisory bodies and regulators to consider all cases reported to it, sharing relevant information accordingly.

If you find out that a person or organisation you are dealing with is subject to the financial sanctions detailed in the regulations, you must immediately:

stop dealing with them
freeze any assets you are holding for them
inform OFSI as soon as possible by either emailing ofsi@hmtreasury.gov.uk or by calling their general enquiries line: +44 (0)20 7270 5454

More detailed information on OFSI’s approach to compliance and enforcement can be found in OFSI’s guidance

2.2 Director disqualification sanctions

Breach of disqualified director sanctions is an offence under CDDA and CDD(NI)O. The Insolvency Service is responsible for monitoring compliance with disqualified director sanctions and for assessing suspected breaches of the main prohibitions and the licensing prohibitions. It also has the power to bring prosecutions for breaches under section 11A CDDA and refer cases to other law enforcement agencies for potential prosecution.

Under section 13 of CDDA (and in Northern Ireland, under Article 18 of CDD(NI)O), a person guilty of acting in contravention of the new section 11A (in Northern Ireland, Article 15A of CDD(NI)O) will be liable (a) on conviction on indictment, to imprisonment for not more than 2 years or a fine, or both; and (b) on summary conviction, to imprisonment for not more than 6 months or a fine not exceeding the statutory maximum, or both.

2.3 Trade sanctions

Any breach of the trade sanctions prohibitions in the regulations is triable either way and carries a maximum sentence on indictment of 10 years’ imprisonment or a fine (or both). Any breach of the trade licensing provisions is also triable either way and carries a maximum sentence on indictment of 2 years’ imprisonment or a fine (or both).

The prohibitions and requirements imposed by UK sanctions regulations apply within the United Kingdom, including Northern Ireland and in relation to the conduct of all UK individuals wherever they are in the world. They also apply to UK companies incorporated or established in the UK, and to branches of UK companies overseas.

OTSI, in DBT, is responsible for monitoring compliance with trade sanctions and investigating suspected breaches in relation to: 

providing or procuring sanctioned services
moving, making available, or acquiring sanctioned goods outside the UK 
transferring, making available or acquiring sanctioned technology outside the UK 
providing ancillary services to the movement, making available or acquisition of sanctioned goods outside the UK 
providing ancillary services to the transfer, making available or acquisition of sanctioned technology outside the UK

OTSI can issue warnings and use their powers to publish information about breaches, impose civil monetary penalties and refer cases to HM Revenue and Customs (HMRC) for criminal investigation. OTSI can also report individuals and businesses to their regulator, if they have one, and share information with organisations such as Companies House or the Insolvency Service. 

Trade sanctions apply to: 

all individuals or businesses within the territory and territorial sea of the UK 
all UK nationals or UK businesses established under UK law, wherever they are in the world

This means OTSI can investigate suspected breaches committed by: 

individuals and legal entities who are within, or undertake activities within, the UK’s territory 
UK individuals and legal entities established under UK law, regardless of where in the world the breach takes place

HMRC is responsible for the enforcement of trade sanctions that fall within its remit as the UK’s customs authority and for the enforcement of trade sanctions measures that relate to strategic goods and technology.

HMRC has a range of enforcement options available such as education, warning letters, issuing compound settlements, seizures / disruptions and in the most serious of cases, referral to the Crown Prosecution Service for consideration for prosecution.

If you discover that there may have been a breach of any of the trade prohibitions or licensing provisions, you should report the irregularity to the appropriate authority as soon as possible:

If the irregularity was found on an ECJU compliance audit, the compliance inspector will have informed HMRC, and you are strongly advised to do the same. Guidance is available on how to make a voluntary disclosure.

Ofcom is responsible for monitoring compliance with trade sanctions in relation to internet services, and for assessing suspected breaches. It has the power to impose monetary penalties for breaches of these sanctions.

Where appropriate and where permitted by law, Ofcom may share relevant information with parts of government, supervisory bodies and regulators.

By exception within trade sanctions, OFSI enforces civil penalties relating to the supply or delivery by ship of oil and oil products under the commodity codes 2709 and 2710 from Russia to and between third countries and services associated with that supply or delivery (such as financial services and brokering). OFSI can be contacted by emailing oilpricecap.ofsi@hmtreasury.gov.uk. Full guidance on the Russian Oil Services ban can be found on the OFSI website.

2.4 Transport sanctions

A breach of the transport sanctions relating to prohibition on port entry, failing to comply with a port barring direction or a port entry or movement direction is an offence that is triable either way and carries a maximum sentence of 7 years’ imprisonment or a fine (or both).

The offence of failing to comply with a detention direction in relation to a ship is triable either way and carries a sentence or a fine.

A breach of the transport sanctions relating to the movement of aircraft includes:

the failure of an operator or pilot of a Russian aircraft to comply with the prohibition on overflying the United Kingdom or landing in the United Kingdom
the failure of an airport operator, without reasonable excuse, to comply with a direction given by the Secretary of State
the failure of an operator or pilot in command of a Russian aircraft to comply with a direction given by air traffic control or an airport operator

All of which are offences that are triable either way and carry a maximum sentence of 7 years’ imprisonment or a fine (or both).

The Secretary of State may notify a person that the existence or content of a port barring, entry or movement direction and any direction relating to the movement of aircraft, or anything done under such directions, is to be treated as confidential. Disclosure of confidential information carries a maximum sentence of 6 months’ imprisonment on summary conviction or a fine (or both).

DfT is ultimately responsible for the implementation of transport sanctions. The enforcement of these sanctions will be supported by the CAA, NATS and airport operators.

If you become aware that a breach of the transport sanctions detailed in the regulations has taken or will take place, then you must report it as soon as possible by calling DfT on 020 7944 5999 and by emailing transportsanctions@dft.gov.uk.

Question 3

3. Are there circumstances when I can get an authorisation or licence for a sanctioned activity?

Accepted Answer

Licensing and exception provisions are contained in Part 7 of the regulations.

3.1 Exceptions

The regulations set out exceptions to some of the sanctions prohibitions which apply within certain defined circumstances. An exception applies automatically, and does not require you to obtain a licence issued in accordance with the regulations.

The regulations establish exceptions relating to financial sanctions including for the crediting of a frozen account by a relevant institution (any such interest or other earnings will be frozen in accordance with the relevant legislation underpinning the asset freeze). An exception also exists from the prohibition on making funds available to a designated person, when funds are transferred to a frozen account in discharge (or partial discharge) of an obligation which arose before the recipient became a designated person.

A further exception permits certain required payments to be made by, or on behalf of, designated persons to various specified UK public bodies.

There are exceptions relating to prohibitions of loans and credit arrangements. The exception for relevant loans consisting of a drawdown or disbursement applies to arrangements entered into before 15 September 2014, where the loan has been made or granted to a person listed in Schedule 2, entities owned by them and incorporated or constituted under the law of a non-UK country, or entities acting on behalf or at the direction of either of the above.

Where such a loan has been made or granted to an entity incorporated or constituted under the law of the UK and owned by a person listed in Schedule 2, or a person connected with Russia, or the Government of Russia, the exception generally applies to arrangements entered into before 1 March 2022. For certain loans not prohibited prior to 29 October 2022, the exception relates to arrangements entered into before 29 October 2022.

There are exceptions relating to prohibitions on correspondent banking relationships (59A). The exception relating to aviation enables the payment of any fee or charge required to permit an aircraft to overfly Russia or to land in or take off from Russia.

The exception relating to compliance with regulation 17A(2) enables the transfer of funds by the UK credit or financial institution where those funds are not placed in an account in the name of a customer, remain in the UK and the transfer is made in order to comply with regulation 17A(2).

There are exceptions relating to investments in Russia and in relation to non-government controlled Ukrainian territory.

There are also exceptions relating to trust services. These exceptions permit the provision of trust services in certain instances.

The regulations set out exceptions relating to some of the trade restrictions. Regulation 61 provides for an exception to certain trade prohibitions where the act is an act dealing with an emergency. This is defined as an act assisting with the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, infrastructure or the environment. This exception should only be relied on where there is genuinely insufficient time to apply for a licence to cover the activity of assisting in prevention or mitigation of the event. The exception can only be relied upon where satisfactory justification is received within 5 working days beginning with the day on which the act is done, and where the activity was genuinely to deal with the emergency.

Regulation 60ZA provides for certain time-limited exceptions to the trade sanctions relating to non-government controlled areas of the Donetsk and Luhansk oblasts, if related to an obligation arising from a contract concluded before 23 February 2022.

These exceptions provide that:

the prohibitions in regulation 47 (imports from non-government controlled Ukrainian territory) or regulation 52(3)(a) (financial services and funds in relation to imports from non-government controlled Ukrainian territory) are not contravened if the action carried out under these contracts, or ancillary contracts necessary for their execution, is carried out by 24 May 2022 and is notified to the Secretary of State at least 10 days beforehand
the prohibitions in regulation 48 to 51, 52(1), (2) or (3)(b) to (e), or 53 (trade in relation to non-government controlled Ukrainian territory) are not contravened if the action carried out under these contracts, or ancillary contracts necessary for their execution, is carried out by 24 August 2022 and is notified to the Secretary of State at least 5 days beforehand
the prohibitions in regulation 54(1)(a) (prohibition on infrastructure-related services relating to non-government controlled Ukrainian territory) are not contravened if the action carried out under these contracts, or ancillary contracts necessary for their execution, is carried out by 24 August 2022
the prohibition in regulation 54(1)(b) (prohibition on tourism services relating to non-government controlled Ukrainian territory) is not contravened if the action carried out under these contracts, or ancillary contracts necessary for their execution, is carried out by 24 August 2022 and is notified to the Secretary of State at least 5 days beforehand

Regulation 60A provides for certain exceptions in relation to prohibitions relating to the export of goods, supply and delivery of goods, making goods and technology available for use in Russia or available to a person connected with Russia, transfer of technology, and the provision of related services. These are the restrictions set out in regulations 22, 24(1)(a), 25(1)(a) and (b), 26(1)(a) and (b), 27 to 29, 46XC, 46Y to 46Z2, 46Z10 to 46Z16B, 46Z16J to 46Z16P, 46Z30 to 46Z33 and Chapter 4B.

This provides that prohibitions are not contravened:

in relation to any critical industry goods or technology, or quantum computing and advanced materials goods and technology, which are:

the personal effects of a person travelling to or from Russia
of a non-commercial nature for the personal use of a person travelling to or from Russia and contained in that person’s luggage
necessary for the official purposes of a diplomatic mission or consular post in Russia, or of an international organisation enjoying immunities in the UK in accordance with international law

in relation to any luxury goods which are:

necessary for the official purposes of a diplomatic mission or consular post in Russia, or of an international organisation enjoying immunities in accordance with international law
the personal effects of their staff

in relation to G7 dependency and further goods which are:

necessary for the official purposes of a diplomatic mission or consular post in Russia, or an international organisation enjoying immunities in accordance with international law
the personal effects of their staff

in relation to gold and gold jewellery which is:

necessary for the official purposes of a diplomatic mission or consular post in Russia, or an international organisation enjoying immunities in accordance with international law
gold jewellery that is for personal use of and owned by the natural person importing it, or an immediate family member, travelling with them to the UK, contained in their luggage provided that the jewellery is not intended for sale.

in relation to diamond jewellery which is:

for personal use of and owned by the natural person importing it, or an immediate family member, travelling with them to the UK, contained in their luggage provided that the jewellery is not intended for sale.

in relation to Russia’s vulnerable goods which are:

necessary for the official purposes of a diplomatic mission or consular post in Russia, or an international organisation enjoying immunities in accordance with international law; or
the personal effects of their staff.

in relation to Schedule 3DA revenue generating goods which are:

necessary for the functioning of diplomatic or consular representations of the UK in Russia.

Regulation 60B provides for exceptions from restrictions related to the export, supply and delivery, and making available/transfer of certain luxury, G7 dependency and critical industry goods and technology which are:

consumer communication devices for civilian use
software updates for civilian use

That regulation also provides for exceptions to restrictions related to the provision of technical assistance, financial services and brokering services in relation to critical industry goods and technology which are:

consumer communication devices for civilian use
software updates for civilian use

Regulation 60C provides for certain exceptions in relation to prohibitions relating to the export of critical-industry goods and aviation and space goods in regulations 22 and 28.

This provides that certain prohibitions are not contravened by the removal of an aircraft from the UK to Russia:

if it travels under its own power, and
in the case of an aircraft, it is carrying goods or passengers, or travelling from the UK in order to undertake a return flight carrying goods or passengers; and
its removal is not for the purpose of a transfer of ownership (including any of its component parts) or a change of operator

It also provides that certain prohibitions are not contravened by the removal of any vessel to Russia:

if it is removed from the UK under its own power, and
its removal is not for the purpose of a transfer of ownership (including any of its component parts) or a change of operator

It also provides that the prohibition in regulation 27(1)(a) is not contravened by the provision of technical assistance to an aircraft owned, chartered or operated by a person connected with Russia, at a UK airport provided that the assistance is not for the purposes of facilitating a transfer of ownership of the aircraft or any of its component parts; or a change in the operator of the aircraft.

Regulation 60D provides that the prohibitions in regulation 46A on technical assistance relating to aircraft and ships are not contravened by providing technical assistance in circumstances where a failure to do so would endanger the lives of persons on board or the safety of an aircraft in flight or a ship at sea.

Regulation 60DA provides for exceptions in relation to the prohibitions on the provision of accounting, advertising, architectural, auditing, business and management consulting, engineering, IT consultancy and design, and public relations services. In some cases, these exceptions apply to all prohibitions under regulation 54C.

In other cases, they are unique and tailored to specific services prohibitions:

exception related to authorised conduct in a relevant country, such as the Channel Islands, Isle of Man, or any British overseas territory (as in Regulation 62A) – applies to all prohibitions in regulation 54C.
exception related to official purposes of a diplomatic mission or consular post in Russia or of an international organisation enjoying immunities in accordance with international law – applies to all prohibitions in regulation 54C.
exception related to the discharge or compliance with UK statutory or regulatory obligations, such obligations not arising under contract – applies to accounting, business and management consulting, engineering and public relations services prohibitions. A similar tailored exception applies to the auditing services prohibition.
exception related to services provided to a Russian subsidiary of a UK credit institution - applies to the auditing services prohibition only.
exception related to provision of ensuring the continuance and/or resumption of civilian telecommunications services and/or services incident to the exchange of communications over the internet – this applies to IT consultancy and design only.
satisfying an obligation arising from a contract or provision of services is carried out before 20 August 2022, and the provider has notified the Secretary of State no later than the day 10 working days before the day on which the act is carried out – applied to accounting, business and management consulting and public relations services prohibitions, however, this exception has now expired and has therefore been omitted from the regulations
concluded before the day on which the Amendment (No. 17) Regulations come into force, or an ancillary contract necessary for the satisfaction of such a contract, provided that the act is carried out before the end of 3 months beginning with the day on which the Amendment (No. 17) Regulations come into force, and the provider notifies the Secretary of State via email exportcontrol.help@businessandtrade.gov.uk of the provision of services; the provider can notify the intention to provide services or the actual provision of services at any time before the end of 15 March 2023. – applies to advertising, architectural, engineering, and IT consultancy and design services prohibitions
concluded before the day on which the Amendment (No. 17) Regulations come into force, or an ancillary contract necessary for the satisfaction of such a contract, provided that the act is carried out before the end of 31 May 2023, and the provider notifies the Secretary of State via email exportcontrol.help@businessandtrade.gov.uk of the provision of services; the provider can notify the intention to provide services or the actual provision of services at any time before the end of 15 March 2023 - applies to the auditing services prohibition.

Regulation 60DB provides for exceptions in relation to the prohibition on the provision of legal advisory services.

The prohibition is not contravened by any act to provide legal advisory services related to:

official purposes of a diplomatic mission or consular post in Russia or of an international organisation enjoying immunities in accordance with international law
the discharge or compliance with UK statutory or regulatory obligations
compliance with the regulations
compliance with, or the consequence of compliance with any relevant law
the discharge of obligations under the relevant law
the potential or actual application of punitive measures

Relevant law include sanctions and criminal law imposed by any jurisdiction, and any Russian counter sanctions.

Regulation 60E provides an exception in relation to prohibitions on the export of maritime goods and maritime technology for non-military use and for a non-military end-user, humanitarian assistance activity, health emergencies, the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters.

Regulation 60F provides an exception in relation to prohibitions on the export of banknotes intended for the personal use of people and their families travelling to Russia up to a value of £10,000. There is also an exception for the official purposes of diplomatic missions, consular posts and international organisations, which does not have a limit. There is also an exception for when a person either did not know, or had no reasonable cause to suspect, that an offence would be committed.

Regulation 60G provides an exception in relation to goods consigned from Russia before the prohibitions entered into force. For goods falling under Part 3 of Schedule 3B, Part 3 of Schedule 3D and Part 3 of Schedule 3DA, this is provided that the goods are consigned from Russia before 20 April 2023 and imported into the UK before 20 May 2023. For goods falling under Part 4 of Schedule 3B and Schedule 3BA, this is provided that the goods are consigned from Russia before 15 December 2023 and imported into the UK before 14 January 2024.

Regulation 60GA provides an exception to the acquisition, technical assistance, financial services and brokering services of iron and steel products, and acquisition of metals in relation to such goods located in the United Kingdom or the Isle of Man, having been lawfully imported there.

Regulation 60GAA provides an exception in relation to: the import of iron or steel products and associated ancillary services; the import of relevant processed iron or steel products and associated ancillary services; and the import of metals. This is provided that these goods were exported from Russia before the applicable prohibitions entered into force and are not released into free circulation in the United Kingdom.

Regulation 60GAB provides an exception to anything done in relation to the provision of ancillary services related to the acquisition of iron or steel products, provided these goods were exported from Russia before the applicable prohibition came into force.

Regulation 60GB provides an exception to the acquisition, technical assistance, financial services and brokering services of Schedule 3DA revenue generating goods:

where those goods are located in the United Kingdom or the Isle of Man, having been lawfully imported there
where a United Kingdom national located in Russia engages in these activities in relation to goods which are located in Russia and are for personal use of that United Kingdom national or their immediate family members.

Regulation 60GC provides an exception to the acquisition, technical assistance, financial services and brokering services of diamonds and diamond jewellery where these are located in the United Kingdom or Isle of Man having been lawfully imported there.

Regulation 60H provides for exceptions in relation to oil and oil products. The prohibitions on the import, acquisition and supply and delivery of oil and oil products are not contravened by activity where the oil or oil products originate in a country that is not Russia, are not owned by a person connected with Russia, and are only being loaded in, departing from or transiting through Russia.

Regulation 60I provides an exception in relation to the prohibitions on energy-related goods and related activities (chapter 4) where prohibitions are not contravened by:

the provision of insurance or reinsurance to a relevant person with regard to that person’s activities outside the energy sector in Russia
a relevant activity that is necessary for the purposes of a UK petroleum project

Regulation 61ZA provides an exception to certain prohibitions concerning infrastructure-related goods and related services in relation to non-government controlled Ukrainian territory for activities necessary to ensure the timely delivery of humanitarian assistance activity in non-government controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts.

Regulation 62 provides for an exception in relation to prohibitions relating to the import of goods originating in non-government controlled Ukrainian territory, and the provision of financial services or funds in pursuance of or in connection with an arrangement whose object or effect is the import of goods which originate in non-government controlled Ukrainian territory, where the goods have been satisfactorily certified by or on behalf of the Government of Ukraine as originating in Ukraine.

Regulation 62A establishes an exception to regulations 11 to 15 and 18 and Chapters 2 to 6 and Chapter 6B of Part 5 (Trade) which provides that prohibitions are not contravened if conduct is authorised by a licence which is issued under the law of the Channel Islands, Isle of Man or any British Overseas Territory for the purpose of disapplying a prohibition in that jurisdiction which corresponds to the relevant prohibition.

The regulations establish exceptions relating to some of the transport sanctions. There is an exception for the granting of access to a port where the access is needed by a ship in the case of an emergency or where a port entry or movement direction has been given in relation to the ship. Exceptions also apply in relation to the movement of aircraft in in the case of an emergency.

Regulation 63 establishes an exception in relation to any prohibition or requirement imposed by the regulations for actions which a responsible officer has determined to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere.

If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

3.2 Licensing for financial sanctions

Where a person is designated for the purposes of the financial sanctions contained in the regulations which include asset freeze measures and making available provisions (together the “Asset Freeze etc”), OFSI may grant a licence regarding the Asset Freeze etc measures e.g. if the designated person or representative (on their behalf) applies for a licence from OFSI to use their funds or economic resources (non-monetary assets, such as property or vehicles) which are subject to the asset freeze. Part 1 of Schedule 5 to the regulations sets out the purposes pursuant to which, or for which activities, OFSI may grant an individual licence in respect of the Asset Freeze etc.

basic needs
reasonable professional fees for or reasonable expenses associated with the provision of legal services
reasonable fees or service charges arising from the routine holding or maintenance of frozen funds or economic resources
extraordinary expenses
judicial decisions etc
extraordinary situations
prior obligations
diplomatic missions and consular posts
humanitarian assistance activities
medical goods and services
production or distribution of food

The divestment and enabling others to divest licensing grounds set out in Part 1ZA of Schedule 5 and the insolvency grounds set out in Part 1ZB of Schedule 5, apply to the Asset Freeze etc prohibitions, loans and credit arrangements prohibitions, dealing with transferable securities or money market instruments prohibitions, correspondent banking relationships etc prohibitions, provision of financial services relating to foreign exchange reserve and asset management prohibitions and trust services prohibitions.

A UK entity or representative (on their behalf) may apply for a license from OFSI to allow the divestment activities set out below. Part 1ZA sets out the purposes pursuant to which, or for which activities. OFSI may grant an individual licence.

In summary, these are:

to enable a UK entity to transfer funds or economic resources located in Russia which it owns, holds or controls to a Designated Person or the Russian Government, in order for the entity to divest itself (wholly or partially) of those funds or economic resources
to enable a UK entity to acquire from a designated person or the Russian Government an interest held in that UK entity by the designated person or the Russian Government if the sole consideration for the acquisition is a transfer of funds from the UK entity to the designated person or the Russian Government and:
- such funds are credited to a frozen account; or
- an account held by a non-UK credit or financial institution in a non UK country and the law of that country provides for relevant and appropriate prohibitions, exceptions and provisions for licences to be granted which correspond to those in the regulations

To enable a UK entity to enable another person to:

transfer funds or economic resources located in Russia owned, held or controlled by that other person to a Designated Person or the Russian Government, in order for that other person to divest themselves (wholly or partially) of those funds or economic resources
acquire from a designated person or the Russian Government an interest held in that person by the designated person or the Russian Government, if the requirements set out above applying to a UK entity acquiring from a designated person or the Russian Government an interest held in that UK entity are met

The following licensing grounds, set out in Part 1A of Schedule 5, apply to loans and credit:

humanitarian assistance activities
medical goods and services
production or distribution of food
diplomatic missions and consular posts
space activities
extraordinary situations

The following licensing grounds, set out in Part 1B of Schedule 5, apply to the prohibition on correspondent banking relationships contained in regulation 17A(1):

basic needs – including for the provision of insolvency services
legal services
financial regulation
extraordinary situations

A person or representative (on their behalf) may apply for a licence from OFSI to allow the processing of payments to, from or via a designated person. Part 1C of Schedule 5 to the regulations sets out the purposes pursuant to which OFSI may grant an individual licence.

In summary, these are:

humanitarian assistance activities
medical goods and services
production or distribution of food
diplomatic missions and consular posts
space activities
other licensing purposes (i.e. where OFSI has decided to issue a licence under any of the other purposes in Schedule 5, OFSI may also issue a licence disapplying regulation 17A(2).

A person or representative (on their behalf) may apply for a licence from OFSI to allow provision of financial services for the purposes of foreign exchange reserve and asset management to the Central Bank of the Russian Federation; the National Wealth Fund of the Russian Federation or the Ministry of Finance of the Russian Federation. Part 1D of Schedule 5 to the regulations sets out the purposes pursuant to which, or for which activities, OFSI may grant an individual licence.

In summary, these are:

humanitarian assistance activity
financial regulation
financial stability
safety and soundness of a firm
extraordinary situation

Licence applications can also be made to OFSI for acts that would otherwise be prohibited under regulation 18 (investments in relation to non-government controlled Ukrainian territory) on these 3 grounds:

consular posts
medical and educational purposes
health and the environment

Licence applications can also be made to OFSI for acts that would otherwise be prohibited under regulation 18C (trust services) on these grounds:

extraordinary situations
humanitarian assistance activity
medical goods or services
food
diplomatic missions etc
safety and soundness of a firm
financial regulation
financial stability
unauthorised unit trusts

OFSI has also issued general licences under this regime. For details of the general licences that are in force, please visit OFSI’s general licence page.

Further information on exceptions and licensing grounds can be found in OFSI’s guidance.

Information on licence applications and the relevant form can be found on OFSI’s GOV.UK licensing webpage.

3.3 Licensing for director disqualification sanctions

The designated person, or their authorised representative, can make an application for a licence to the Insolvency Service. Should the Insolvency Service decide to grant a licence then the licence will specify the act/s it authorises. A licence may be subject to conditions. A licence may be varied or revoked, and any such changes will be communicated to any affected designated person or their authorised representative.

You should not assume that a licence will be granted therefore you should not act as a director of a company or directly or indirectly to take part in or be concerned in the promotion, formation or management of a company, until your licence has been granted.

3.4 Licensing for trade sanctions

Licences may also be issued for certain trade activities that would otherwise be prohibited by the regulations. DBT has overall responsibility for trade sanctions licensing. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out.

If you are carrying out activity that falls under the remit of more than one licensing body, you will need to submit separate licence applications for each one.

DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.

In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 5 of the regulations, the Secretary of State will consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.

Licences granted will not permit activity in respect of Northern Ireland that is not consistent with EU sanctions regulations as they apply via the Northern Ireland Protocol.

For some prohibitions there are some specific activities that DBT considers are likely to be consistent with the aims of the sanctions. These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions you should make this clear and explain why you believe this to be the case in your application for a licence.

You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted.

Prohibition description	Prohibition reference	Considerations for licensing
Prohibitions on the import, acquisition, export, making available, transfer, supply, or delivery of military goods or technology to, from, or for use in, Russia.	Regulations 22 to 26	A licence may be granted for the import, acquisition, transfer, supply or delivery of military goods or technology from Russia if the goods or technology relate to the execution of contracts concluded before 1 August 2014 or ancillary contracts necessary for the execution of such contracts.
		A licence may be granted for the acquisition, export, making available, transfer, supply, or delivery of spare parts for military goods or technology if the acquisition, export, making available, transfer, supply or delivery is necessary for the maintenance and safety of existing capability within the UK.
		A licence may be granted for the import of spare parts for military goods if the import is necessary for the maintenance and safety of existing capability within the UK.
		A licence may be granted for the import, acquisition, export, making available, supply, or delivery of: Hydrazine (CAS 302-01-2) in concentrations of 70% or more; or Monomethyl hydrazine (CAS 60-34-4) if it is for use in launchers operated by UK service providers, or for the use in launches by the European Space Agency or UK space programmes, or for the fuelling of satellites by UK satellites manufacturers.^{[footnote 2]}
		A licence may be granted for the import, acquisition, supply or delivery from Russia of unsymmetrical dimethyl hydrazine (CAS 57-14-7) if it is for use in launchers operated by UK launch service providers, or for the use in launches by the European Space Agency or UK space programmes, or for the fuelling of satellites by UK satellites manufacturers.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to military goods or technology	Regulations 27 to 29	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds if the technical assistance, brokering services, financial services or funds relate to the import, acquisition, transfer, supply or delivery of military goods or technology if the goods or technology relate to the execution of a contract concluded before 1 August 2014 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds if the technical assistance, brokering services, financial services or funds relate to the provision of spare parts necessary for the maintenance and safety of existing capability within the UK.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds if the technical assistance, brokering services, financial services or funds relate to the import, acquisition, export, supply and delivery, making available and transfer of: Hydrazine (CAS 302-01-2) in concentrations of 70% or more; or Monomethyl hydrazine (CAS 60-34-4) if it is for use in launchers operated by European launch service providers, or for the use in launches by space programmes of the European Space Agency or UK space programmes, or for the fuelling of satellites by UK satellites manufacturers.^{[footnote 3]}
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds if the technical assistance, brokering services financial services or funds relate to unsymmetrical dimethyl hydrazine (CAS 57-14-7) if it is for use in launchers operated by UK launch service providers, or for the use in launches by the European Space Agency or UK space programmes, or for the fuelling of satellites by UK satellites manufacturers.^{[footnote 4]}
Prohibitions on enabling or facilitating military activities	Regulation 30	A licence may be granted for the provision of technical assistance, armed personnel, brokering services, financial services or funds which enable or facilitate military activities, if the technical assistance, armed personnel, financial services or funds, or brokering services are necessary for the maintenance and safety of existing capability within the UK.
Prohibitions on the export, making available, transfer, supply, or delivery of dual-use goods or technology to a person connected with Russia, or for use in Russia.	Regulations 22, 24, 25 and 26	A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the goods or technology relate to the execution of obligations arising from contracts concluded before 1 March 2022, (or 29 October 2022 for goods introduced by the 15th amendment (SRAMs)) or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 1 May 2022 (or 31 December 2022 for goods introduced by the 15th amendment) If this contract relates to the export, making available, transfer, supply, or delivery of dual-use goods or technology for a military end-use or a military end-user, the licence will only be granted to facilitate the execution of obligations arising of contracts concluded before 1 August 2014 or ancillary contracts necessary for the execution of such contracts.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the export, making available, transfer, supply, or delivery of the goods or technology is necessary for the maintenance and safety of dual-use goods or technology within the UK.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the goods or technology are intended for intergovernmental cooperation in space programmes. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if necessary in relation to the repair of an aircraft which is not registered in Russia, or owned or operated by a person connected with Russia.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the goods or technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology for the delivery of humanitarian assistance activity.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the export, making available, transfer, supply, or delivery of items for use by the news media, provided that there are reasonable grounds to determine that the dual-use goods or technology will be safely returned to the UK when no longer required and will not be hired, exchanged, sold or otherwise disposed of in Russia.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology where this is necessary for a software update for civilian use.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the export, making available, transfer, supply, or delivery of dual-use goods or technology is necessary for ensuring cyber security and information security for natural and legal persons, and bodies in Russia, except for its government and undertakings directly or indirectly controlled by its government.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the export, making available, transfer, supply, or delivery of dual-use goods or technology is necessary for the commissioning, operation, maintenance or repair of civilian telecommunications networks, (other than those which are the property of an entity that is publicly controlled or with over 50% state ownership), including the provision of internet services. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the export, making available, transfer, supply, or delivery of dual-use goods or technology is necessary for maritime safety. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the dual-use goods or technology are intended for the exclusive use of entities owned, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under UK law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of items if the export, making available, transfer, supply, or delivery of these items is necessary for the official purposes of a diplomatic mission, consular post or international organisation enjoying immunities in the United Kingdom in accordance with international law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to dual-use goods or technology	Regulations 27 to 29	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the execution of obligations arising from contracts concluded before 1 March 2022 or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 1 May 2022. If this contract relates to technical assistance, brokering services, financial services or funds for a military end-use or a military end-user, the licence will only be granted to facilitate the execution of obligations arising of contracts concluded before 1 August 2014 or ancillary contracts necessary for the execution of such contracts.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the maintenance and safety of dual-use goods or technology within the UK.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds relate to the maintenance and safety of Russian manufactured dual-use goods or technology within the UK.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for intergovernmental cooperation in space programmes. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are required to enable activities for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are required for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the if the technical assistance, brokering services, financial services or funds are for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the export, making available, transfer, supply, or delivery of dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary in relation to the repair of an aircraft which is not registered in Russia, or owned or operated by a person connected with Russia.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the news media, and there are reasonable grounds to determine that the dual-use goods or technology will be safely returned to the UK when no longer required and will not be hired, exchanged, sold or otherwise disposed of in Russia.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for software updates for civilian use.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for ensuring cyber security and information security for natural and legal persons, and bodies in Russia, except for its government and undertakings directly or indirectly controlled by its government.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the commissioning, operation, maintenance or repair of civilian telecommunications networks (other than those which are the property of an entity that is publicly controlled or with over 50% state ownership), including the provision of internet services. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology if the technical assistance, brokering services, financial services or funds are necessary for maritime safety. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology intended for the exclusive use of entities owned, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under UK law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to controlled items if the technical assistance, brokering services, financial services or funds are necessary for the official purposes of a diplomatic mission, consular post or international organisation enjoying immunities in the United Kingdom in accordance with international law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to dual-use goods or technology where the technical assistance, brokering services, financial services or funds are necessary to prevent degradation or allow safe storage of aircraft or vessels located in the UK that are detained or are unable to operate due to UK financial, trade or transport sanctions measures.
Prohibitions on the export, making available, transfer, supply, or delivery of critical-industry goods and technology	Regulations 22, 24, 25 and 26	A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods or technology if the goods or technology relate to the execution of obligations arising from contracts concluded before 1 March 2022 or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 1 May 2022.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods or technology if the export, making available, transfer, supply, or delivery of the goods or technology is necessary for the maintenance and safety of critical-industry goods or technology within the UK.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods or technology if the goods or technology are intended for intergovernmental cooperation in space programmes. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods or technology if the goods or technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology for humanitarian purposes for the delivery of humanitarian assistance activity.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology for use by the news media, provided that there are reasonable grounds to determine that the critical-industry goods or technology will be safely returned to the UK when no longer required and will not be hired, exchanged, sold or otherwise disposed of in Russia.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology if the export, making available, transfer, supply, or delivery of critical-industry goods and technology is necessary for ensuring cyber security and information security for natural and legal persons, and bodies in Russia, except for its government and undertakings directly or indirectly controlled by its government.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology if the export, making available, transfer, supply, or delivery of critical-industry goods and technology is necessary for the commissioning, operation, maintenance and repair of civilian communications networks (other than those which are the property of an entity that is publicly controlled or with over 50% state ownership), including the provision of internet services. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology if the export, making available, transfer, supply, or delivery of critical-industry goods and technology is necessary for maritime safety. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology if the critical-industry goods and technology are necessary for the repair of an aircraft which is not registered in Russia, or owned or operated by a person connected with Russia.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods and technology if the critical-industry goods and technology are intended for the exclusive use of entities owned, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under UK law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods or technology where: - the restricted goods are: - vessels and their component parts controlled under 8A992f and technology related to such vessels controlled under 8E992; or - aircraft and their component parts controlled under Schedule 2C and restricted technology which is technology related to such aircraft, but not including aircraft defined as military goods or related technology defined as military technology - the aircraft or vessel is moving from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian territorial waters or airspace; - in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers; - the vessel or aircraft is moving under its own power, and; - the movement of the vessel or aircraft is not for the purpose of a transfer of ownership of the aircraft or vessel or any of its component parts, or a change of the operator of the vessel or aircraft A general licence is available under this provision.
		A licence may be granted for the export, making available, transfer, supply, or delivery of critical-industry goods or technology where: - the restricted goods or technology are aero gas turbine engines and specially designed components therefore controlled under 9A991c and technology related to such engines and components controlled under 9E991 - the restricted goods or technology form part of an aircraft which is controlled under Schedule 2C, not including aircraft defined as military goods, and; - the restricted goods or technology form part of an aircraft which is undertaking an activity in accordance with the following provisions: - the aircraft is moving from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian airspace - it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the aircraft is moving under its own power, and; - the movement of the aircraft is not for the purpose of a transfer of ownership of the aircraft or any of its component parts, or a change of the operator of the aircraft A general licence is available under this provision.
		A licence may be granted for the export, making available, supply or delivery of critical-industry goods and technology if it is necessary for ensuring critical energy supply to any country.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to critical-industry goods and technology	Regulations 27 to 29	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods and technology if the technical assistance, brokering services, financial services or funds are necessary for the execution of obligations arising from contracts concluded before 1 March 2022, (or 29 October 2022 for goods introduced by the 15th amendment (SRAMs)) , or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 1 May 2022 (or 31 December 2022 for goods introduced by the 15th amendment).
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods and technology if the technical assistance, brokering services, financial services or funds are necessary for the maintenance and safety of critical-industry goods and technology within the UK.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are necessary for intergovernmental cooperation in space programmes. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology for use by the news media, provided that there are reasonable grounds to determine that the critical-industry goods or technology will be safely returned to the UK when no longer required and will not be hired, exchanged, sold or otherwise disposed of in Russia.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are necessary for ensuring cyber security and information security for natural and legal persons, and bodies in Russia, except for its government and undertakings directly or indirectly controlled by its government.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the commissioning, operation, maintenance and repair of civilian communications networks (other than those which are the property of an entity that is publicly controlled or with over 50% state ownership), including the provision of internet services. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are necessary for maritime safety. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the repair of an aircraft which is not registered in Russia, or owned or operated by a person connected with Russia.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods or technology if the technical assistance, brokering services, financial services or funds are intended for the exclusive use of entities owned, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under UK law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods and technology where: - the restricted goods are: - vessels and their component parts controlled under 8A992f and technology related to such vessels controlled under 8E992; or - aircraft and their component parts controlled under Schedule 2C and restricted technology which is technology related to such aircraft, but not including aircraft defined as military goods or related technology defined as military technology; - the aircraft or vessel is moving from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian territorial waters or airspace, or moving between 2 third countries; - in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the vessel or aircraft is moving under its own power; - the movement of the vessel or aircraft is not for the purpose of a transfer of ownership of the vessel or aircraft or any of its component parts, or a change of the operator of the vessel or aircraft, and; - in the case of technical assistance and brokering services, they are not being provided to a person connected with Russia. A general licence is available under this provision.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical-industry goods and technology where: - the restricted goods or technology are aero gas turbine engines and specially designed components therefor controlled under 9A991c and technology related to such engines and components controlled under 9E991 - the restricted goods or technology form part of an aircraft which is controlled under Schedule 2C, not including aircraft defined as military goods, and; - the restricted goods or technology form part of an aircraft which is undertaking an activity in accordance with the following provisions: - the aircraft is moving from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian airspace, or moving between 2 third countries - it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the aircraft is moving under its own power, and; - the movement of the aircraft is not for the purpose of a transfer of ownership of the aircraft or any of its component parts, or a change of the operator of the aircraft In the case of technical assistance and brokering services a licence cannot be granted to a person connected with Russia. A general licence is available under this provision.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to critical industry goods and technology where the technical assistance, brokering services, financial services or funds are necessary to prevent degradation or allow safe storage of aircraft or vessels located in the UK that are detained or are unable to operate due to UK financial, trade or transport sanctions measures.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to critical-industry goods and technology if it is necessary for ensuring critical energy supply to any country.
Prohibitions on the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods and technology	Regulations 22, 24, 25 and 26	A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the goods or technology relate to the execution of obligations arising from contracts concluded before 14 April 2022, (or 29 October 2022 for goods affected by the change in wavelength range introduced by the 15th amendment) , or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 1 May 2022 (or 31 December 2022 for goods affected by the change introduced by the 15th amendment).
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the export, making available, transfer, supply, or delivery of the goods or technology is necessary for the maintenance and safety of quantum computing and advanced materials goods or technology within the UK.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the goods or technology are intended for intergovernmental cooperation in space programmes, provided that this is for non-military use and for a non-military end user.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if necessary in relation to the repair of an aircraft which is not registered in Russia, or owned or operated by a person connected with Russia.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology for the delivery of humanitarian assistance activity.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the export, making available, transfer, supply, or delivery of items for use by the news media, provided that there are reasonable grounds to determine that the quantum computing and advanced materials goods or technology will be safely returned to the UK when no longer required and will not be hired, exchanged, sold or otherwise disposed of in Russia.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology where this is necessary for a software update for civilian use.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology is necessary for ensuring cyber security and information security for natural and legal persons, and bodies in Russia, except for its government and undertakings directly or indirectly controlled by its government.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology is necessary for the commissioning, operation, maintenance or repair of civilian telecommunications networks (other than those which are the property of an entity that is publicly controlled or with over 50% state ownership), including the provision of internet services. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the quantum computing and advanced materials goods or technology are intended for the exclusive use of entities owned, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under UK law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to quantum computing and advanced materials goods and technology	Regulations 27 to 29	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the execution of obligations arising from contracts concluded before 14 April 2022, (or 29 October 2022 for goods affected by the change in wavelength range introduced by the 15th amendment), or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 1 May 2022 (or 31 December 2022 for goods affected by the change introduced by the 15th amendment).
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the maintenance and safety of quantum computing and advanced materials goods or technology within the UK.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for intergovernmental cooperation in space programmes, provided that this is for non-military use and for a non-military end user. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation or energy sectors.
		A licence may be granted for the export, making available, transfer, supply, or delivery of quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary in relation to the repair of an aircraft which is not registered in Russia, or owned or operated by a person connected with Russia.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are required for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the if the technical assistance, brokering services, financial services or funds are for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the news media, and there are reasonable grounds to determine that the quantum computing and advanced materials goods or technology will be safely returned to the UK when no longer required and will not be hired, exchanged, sold or otherwise disposed of in Russia.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for software updates for civilian use.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for ensuring cyber security and information security for natural and legal persons, and bodies in Russia, except for its government and undertakings directly or indirectly controlled by its government.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the commissioning, operation, maintenance or repair of civilian telecommunications networks (other than those which are the property of an entity that is publicly controlled or with over 50% state ownership), including the provision of internet services. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology if the technical assistance, brokering services, financial services or funds are necessary for maritime safety. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to quantum computing and advanced materials goods or technology intended for the exclusive use of entities owned, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under UK law. A licence may not be granted if there are reasonable grounds to believe that the goods or technology may be intended for the Russian military, aviation, space or energy sectors.
Prohibitions on the export, making available, transfer, supply, or delivery of aviation and space goods and technology	Regulations 22, 24, 25 and 26	A licence may be granted for the execution of an aircraft financial lease concluded before 8 March 2022 where: It is strictly necessary to ensure lease re-payments to a legal person, entity or body incorporated or constituted under the law of any part of the United Kingdom which does not fall under any of the prohibitions provided for in the regulations; and; No economic resources will be made available to the Russian counterpart, with the exception of the transfer of ownership of the aircraft after full reimbursement of the financial lease.
		A licence may be granted for the export, making available, transfer, supply, or delivery of aviation goods or technology if the goods or technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment. A licence may be granted for the export, making available, transfer, supply, or delivery of aviation and space goods and technology where: - the restricted goods are aircraft and their component parts controlled under Schedule 2C and restricted technology which is technology related to such aircraft, but not including aircraft defined as military goods or related technology defined as military technology; - the aircraft is moving from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian airspace - it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the aircraft is moving under its own power, and; - the movement of the aircraft is not for the purpose of a transfer of ownership of the aircraft or any of its component parts, or a change of the operator of the aircraft. A general licence is available under this provision.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to aviation and space goods and technology	Regulations 27 to 29	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to aviation and space goods and technology where the technical assistance, brokering services, financial services or funds are necessary to prevent degradation or allow safe storage of aircraft located in the UK that are detained or are unable to operate due to UK financial, trade or transport sanctions measures.
		A licence may be granted for the execution of an aircraft financial lease concluded before 8 March 2022 where: It is strictly necessary to ensure lease re-payments to a legal person, entity or body incorporated or constituted under the law of any part of the United Kingdom which does not fall under any of the prohibitions provided for in the regulations; and; No economic resources will be made available to the Russian counterpart, with the exception of the transfer of ownership of the aircraft after full reimbursement of the financial lease.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to aviation and space goods or technology if the technical assistance, brokering services, financial services or funds are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to aviation and space goods and technology where: - the restricted goods are aircraft and their component parts controlled under Schedule 2C and restricted technology which is technology related to such aircraft, but not including aircraft defined as military goods or related technology defined as military technology - the aircraft is moving from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian airspace, or moving between 2 third countries - it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the aircraft is moving under its own power - the movement of the aircraft is not for the purpose of a transfer of ownership of the aircraft or any of its component parts, or a change of the operator of the aircraft, and; - in the case of technical assistance and brokering services, they are not being provided to a person connected with Russia A general licence is available under this provision.
Prohibition on the provision of insurance and reinsurance relating to aviation and space goods and technology	Regulation 29A	A licence may be granted for the provision of insurance and reinsurance services related to aviation and space goods and technology where the insurance or reinsurance services are necessary to prevent degradation or allow safe storage of aircraft or vessels located in the UK that are detained or are unable to operate due to UK financial, trade or transport sanctions measures.
		A licence may be granted for the provision of insurance or reinsurance services related to aviation and space goods and technology where: - the restricted goods are aircraft and their component parts controlled under Schedule 2C and restricted technology which is technology related to such aircraft, but not including aircraft defined as military goods or related technology defined as military technology - the aircraft is moving from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian airspace - it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the aircraft is moving under its own power - the movement of the aircraft is not for the purpose of a transfer of ownership of the aircraft or any of its component parts, or a change of the operator of the aircraft, and; - the insurance and reinsurance services are not being provided to a person connected with Russia A general licence is available under this provision.
		A licence may be granted for the insurance and reinsurance services related to aviation and space goods or technology if the insurance and reinsurance services are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibitions on the provision of technical assistance relating to aviation and space goods and technology or critical-industry goods and technology, or making available or transferring that same technology.	Regulations 25, 26 and 27	A licence may be granted for the provision of technical assistance relating to restricted goods and restricted technology, and/or making available or transferring restricted technology. Where the technical assistance or technology is for: - aircraft and their component parts controlled under Schedule 2C to the regulations and technology related to such aircraft controlled under Schedule 2C to the regulations, but in each case not including anything defined under Part 5 of the regulations as military goods or military technology, or - aero gas turbine engines and specially designed components therefor, as controlled under 9A991c of Schedule 2A of the regulations and technology related to such engines and components controlled under 9E991 of Schedule 2A to the regulations; and if the exchange of information is aimed at establishing technical standards in the framework of the International Civil Aviation Organization.
Prohibitions on the export, making available, supply or delivery of oil refining goods and technology	Regulations 22, 24, 25 and 26	A licence may be granted for the export, making available, transfer, supply, or delivery of oil refining goods or technology if the goods or technology relate to the execution of obligations arising from contracts concluded before 14 April 2022, (or 29 October 2022 for goods affected by the inclusion of code ex 8419 89 10 introduced by the 15th amendment), or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 27 May 2022 (or 31 December 2022 for goods affected by the change introduced by the 15th amendment).
		A licence may be granted for the export, making available, transfer, supply, or delivery of oil refining goods or technology if the goods or technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
Prohibitions on the making available and transfer of oil refining goods and technology	Regulations 25 and 26	A licence may be granted for the making available or transfer of oil refining goods and technology for use in Russia, or to a person connected with Russia, that are necessary for the purposes of divestment from Russia. This may be granted where: The goods or technology are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods or technology might be for a military end-user or have a military end-use; and - The goods or technology are located in Russia and were located in Russia before the item became subject to regulations 25 and 26.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to oil refining goods and technology	Regulations 27 to 29	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to oil refining goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the execution of obligations arising from contracts concluded before 14 April 2022, (or 29 October 2022 for goods affected by the inclusion of code ex 8419 89 10 introduced by the 15th amendment), or ancillary contracts necessary for the execution of such contracts, provided that the authorisation is requested before 27 May 2022 (or 31 December 2022 for goods affected by the change introduced by the 15th amendment).
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to oil refining goods or technology if the technical assistance, financial services or funds are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to oil refining goods or technology if the technical assistance, brokering services, financial services or funds are necessary for the purposes of divestment from Russia. This may be granted where: The goods or technology are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods or technology are located in Russia and were located in Russia before the item became subject to regulations 27 to 29.
Prohibitions on the export, making available, supply or delivery of goods relating to chemical and biological weapons	Regulations 22, 24, 25 and 26	A licence may be granted for the export, making available, transfer, supply, or delivery of goods relating to chemical and biological weapons provided that this is for the benefit of the civilian population.
Prohibitions on the export, making available, supply or delivery of energy-related goods	Regulations 40 to 42	A licence will not be granted for the export, making available, supply or delivery of energy-related goods if there are reasonable grounds to determine that the goods are destined for an oil or gas exploration or production project.
		A licence may be granted for the export, making available, supply or delivery of energy related goods if the export, making available, supply, or delivery of goods relate to the execution of obligations arising under contracts concluded before 1 August 2014 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the export, making available, transfer, supply or delivery of energy related goods if the goods are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the export, making available, supply or delivery of energy related goods if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the: - export of energy-related goods to, or for use in, Russia; - direct or indirect supply or delivery of energy-related goods from a third country to a place in Russia; - direct or indirect making energy-related goods available to a person connected with Russia if the export, supply or delivery, or making available relates to the execution of obligations arising under contracts concluded before 21 July 2022 or ancillary contracts necessary for the execution of such a contract, provided the actions carried out under these contracts are completed by 17 September 2022.
		A licence may be granted for the making available of energy-related goods for use in Russia, or to a person connected with Russia, that are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to Regulation 42.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to energy-related goods	Regulations 43 to 45	A licence will not be granted for the provision of technical assistance, brokering services, financial services, or funds related to energy-related goods if there are reasonable grounds to determine that the technical assistance, financial services, funds and brokering services relate to energy-related goods destined for an oil or gas exploration or production project. If your activity is controlled by regulations 43-45 and relates to energy-related goods which are not for use in Russia a general licence is available.
		A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds related to energy-related goods if the technical assistance, brokering services, financial services, or funds relate to the execution of obligations arising under contracts concluded before 1 August 2014 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the provision of brokering services, financial services, or funds relating to the: - export of energy-related goods to Russia where the goods are not for use in Russia - direct or indirect supply or delivery of energy-related goods from a third country to Russia where the goods are not for use in Russia - direct or indirect making energy-related goods available to a person connected with Russia if the brokering services, financial services, or funds relate to the execution of obligations arising under contracts concluded before 21 July 2022 or ancillary contracts necessary for the execution of such a contract, provided the actions carried out under these contracts are completed by 17 September 2022.
		A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds relating to energy-related goods if the technical assistance, brokering services, financial services, or funds are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds relating to energy-related goods or technology if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to energy-related goods if the technical assistance, brokering services, financial services or funds are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulations 43 to 45.
Prohibitions on providing energy-related services	Regulation 46	A licence may be granted for the provision of other energy-related services if the services relate to the execution of contracts concluded before 12 September 2014 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the provision of relevant energy services necessary for oil or gas exploration or production projects in Russia if the services relate to the execution of contracts concluded before 21 July 2022 provided these services are completed by 17 September 2022 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the provision of energy related services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of other energy-related services if it is necessary for ensuring critical energy supply to any country.
Prohibitions on the provision of technical assistance to or for the benefit of specific designated persons, in relation to an aircraft or ship	Regulation 46A	A licence may be granted for the provision of technical assistance to or for the benefit of a designated person where the technical assistance is necessary to prevent degradation or allow safe storage of aircraft or ships located in the UK that are detained or are unable to operate due to UK financial, trade or transport sanctions measures.
Prohibitions on the export, making available, supply or delivery of luxury goods	Regulation 46B	A licence may be granted for the export, making available, transfer, supply, or delivery of luxury goods for the delivery of humanitarian assistance activity.
		A licence may be granted for the export, making available, transfer, supply, or delivery of luxury goods for the delivery of humanitarian assistance activity.
		A licence may be granted for the export, making available, transfer, supply or delivery of borrowed cultural artefacts, loaned objects or artworks subject to temporary export licences, e.g. loaned artwork.
		A licence may be granted for the export, making available, transfer, supply, or delivery of luxury goods where: - the luxury goods are vessels, aircraft, or vehicles and their component parts - the vessel, aircraft or vehicle is moving from the UK to Russia, from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian territorial waters or airspace; - in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers; - the vessel, aircraft or vehicle is moving under its own power, and; - the movement of the vessel, aircraft or vehicle is not for the purpose of a transfer of ownership of the vessel, aircraft or vehicle (or any of its component parts), or a change of the operator of the vessel, aircraft or vehicle.
		A licence may be granted for the making available of luxury goods for use in Russia, or to a person connected with Russia, that are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulation 46B.
		A licence may be granted for the export, making available, supply or delivery of luxury goods if it is necessary for ensuring critical energy supply to any country.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to luxury goods	Regulations 46BA, 46BB and 46BC	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to luxury goods if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to luxury goods for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to borrowed cultural artefacts, loaned objects or artworks subject to temporary export licences, e.g. loaned artwork.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to luxury goods where: - the luxury goods are vessels, aircraft, or vehicles and their component parts - the vessel, aircraft or vehicle is moving from the UK to Russia, from a third country to Russia, or to the United Kingdom or a third country from Russia, or transiting Russian territorial waters or airspace; - in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers; - the vessel, aircraft or vehicle is moving under its own power, and; - the movement of the vessel, aircraft or vehicle is not for the purpose of a transfer of ownership of the vessel, aircraft or vehicle (or any of its component parts), or a change of the operator of the vessel, aircraft or vehicle.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to luxury goods if the technical assistance, brokering services, financial services or funds are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by (i)a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulations 46BA to 46BC.
Prohibition on the import of certain iron and steel products and the acquisition, supply and delivery, directly or indirectly, of certain iron and steel products as set out in Part 3 and 4 of Schedule 3B	Regulations 46D to 46F	A licence may be granted for the import of certain iron and steel products and the acquisition, supply or delivery, directly or indirectly, of: Part 3, Schedule 3B iron and steel products if it relates to the execution of obligations arising from contracts concluded before 21 April 2023; and Part 4 Schedule 3B iron and steel products if it related to the execution of obligations arising from contracts concluded before 15 December 2023.
Prohibition on the import of certain Russian iron and steel products processed in a third country	Regulation 46IB	A licence may be granted for the import of certain Russian iron and steel products processed in a third country if it relates to the execution of obligations arising from contracts concluded before 21 April 2023. The General Trade License for sanctioned iron and steel permits the import into the UK of certain prohibited goods that: - are used as reuseable packaging; - were manufactured or produced before 23 June 2023; or - were previously in free circulation in the United Kingdom. Other conditions apply. For more information, please refer to guidance on third country processed iron and steel measures.
Prohibition on the import of metals and the acquisition, supply and delivery, directly or indirectly, of metals	Regulations 46IG, 46IH and 46II	A licence may be granted for the import of metals and the acquisition, supply or delivery, directly or indirectly, of metals if it relates to the execution of obligations arising from contracts concluded before 15 December 2023. A Trade Licence is available for the acquisition of Russian metals on a global metal exchange in certain circumstances. This was amended with effect from 23:59 on 12 April 2024 to: - prevent UK persons (and non-UK persons in the UK) from acquiring, on a global metal exchange, a warrant relating to Russian metal that was produced after 23:59 on 12 April 2024; and - allow UK persons (and non-UK persons in the UK) to take physical delivery, outside the UK, of metals that were under warrant on a global metal exchange at that time. Other conditions apply. For more information, please refer to: Notice: Russian metals sanctions.
Prohibition on the import of Schedule 3D and 3DA revenue generating goods and the acquisition, directly or indirectly, into the UK Schedule 3D and 3DA of revenue generating goods	Regulations 46S, 46T, 46XB and 46XC	A licence may be granted for the import of goods falling under Part 2 of Schedule 3D and part 2 of Schedule 3DA and the acquisition, directly or indirectly, into the UK of these goods revenue if it relates to the execution of obligations arising from contracts concluded before 23 June 2022, or before 29 October 2022 for codes 2208 and 2303.
		A licence may be granted for the import of goods falling under Part 3 of Schedule 3D and Part 3 of Schedule 3DA, and the acquisition, directly or indirectly, into the UK of these goods if it relates to the execution of obligations arising from contracts concluded before 21 April 2023.
		A licence may be granted for the import of silver and the acquisition, directly or indirectly, into the UK of silver, where it can be demonstrated that the silver was exported from Russia before 23 June 2022.
Prohibitions on the Import, supply, or delivery of Schedule 3DA revenue generating goods	Regulations 46XB and 46XD,	A licence may be granted for the import, supply, or delivery of Schedule 3DA revenue generating goods where: - the revenue generating goods are: Vessels or aircraft controlled under Schedule 3DA to the regulations; - the aircraft or vessel is moving from Russia to a third country or the aircraft or vessel originates from Russia and is being imported into the United Kingdom; - in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers; - the vessel or aircraft is moving under its own power, and; - the movement of the vessel or aircraft is not for the purpose of a transfer of ownership of the aircraft or vessel or any of its component parts, or a change of the operator of the vessel or aircraft. A general licence is available under this provision.
		A licence may be granted for the import, supply, or delivery of revenue generating goods where: - the revenue generating goods are aero gas turbine engines which form part of an aircraft which is controlled under Schedule 3DA and which is undertaking an activity in accordance with the following provisions: - the aircraft is moving from Russia to a third country or the aircraft originates from Russia and is being imported into the United Kingdom; - it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers; - the aircraft is moving under its own power, and; - the movement of the aircraft is not for the purpose of a transfer of ownership of the aircraft or any of its component parts, or a change of the operator of the aircraft. A general licence is available under this provision.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to Schedule 3D and 3DA revenue generating goods	Regulations 46V to 46X and 46XE to 46XG	A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds relating to goods falling under Part 2 of Schedule 3D and Part 2 of Schedule 3DA if it relates to the execution of obligations arising from contracts concluded before 23 June 2022, or before 29 October 2022 for codes 2208 and 2303.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating goods falling under Part 3 of Schedule 3D and Part 3 of Schedule 3DA if it relates to the execution of obligations arising from contracts concluded before 21 April 2023.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to silver that was exported from Russia before 23 June 2022.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to Schedule 3DA revenue generating goods	Regulations 46XE, 46XF and 46XG	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to revenue generating goods where - the revenue generating goods are: - vessels controlled under Schedule 3DA; or - aircraft controlled under Schedule 3DA; - the aircraft or vessel is moving from Russia to a third country or the aircraft or vessel originates from Russia and is being imported into the United Kingdom; - in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the vessel or aircraft is moving under its own power; - the movement of the vessel or aircraft is not for the purpose of a transfer of ownership of the vessel or aircraft or any of its component parts, or a change of the operator of the vessel or aircraft, and; - in the case of technical assistance and brokering services, they are not being provided to a person connected with Russia. A general licence is available under this provision.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to revenue generating goods where: - the revenue generating goods are aero gas turbine engines which form part of an aircraft which is controlled under Schedule 3DA and which is undertaking an activity in accordance with the following provisions. - the aircraft is moving from Russia to a third country or the aircraft originates from Russia and is being imported into the United Kingdom; - it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers - the aircraft is moving under its own power, and; - the movement of the aircraft is not for the purpose of a transfer of ownership of the aircraft or any of its component parts, or a change of the operator of the aircraft In the case of technical assistance and brokering services a licence cannot be granted to a person connected with Russia. A general licence is available under this provision.
Prohibition on the import of diamonds and diamond jewellery, and the acquisition and supply and delivery, directly or indirectly, of diamonds and diamond jewellery	Regulations 46Z16K to 46Z16M	A licence may be granted for the import of diamonds and diamond jewellery, and the acquisition, supply or delivery, directly or indirectly, of diamonds and diamond jewellery, if it relates to the execution of obligations arising from contracts concluded before 15 December 2023.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to diamonds and diamond jewellery	Regulations 46Z16N to 46Z16P	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to diamonds or diamond jewellery if it relates to the execution of obligations arising from contracts concluded before 15 December 2023.
Prohibition on the import of certain Russian diamonds processed in third countries	Regulation 46Z16R	A licence may be granted for the import of certain Russian diamonds processed in third countries if it relates to the execution of obligations arising from contracts concluded before 1 March 2024 for diamonds larger than or equal to 1 carat in weight. A licence may also be granted for the import of certain Russian diamonds processed in third countries if it relates to the execution of obligations arising from contracts concluded before 1 September 2024 for diamonds larger than or equal to 0.5 carats and smaller than 1 carat.
		A General Licence is available under this provision. It permits the import into the UK of Russian diamonds processed in third countries that were outside of Russia before 1 March 2024 and are larger than or equal to 1 carat in weight. It also permits the import of Russian diamonds processed in third countries that were outside of Russia before 1 September 2024 and are smaller than 1 carat but larger than or equal to 0.5 carats in weight. Other conditions apply. for more information please refer to Guidance on third country processed Russian diamonds

Prohibitions on the export, making available, supply, or delivery and making available of infrastructure-related goods to a person connected with, or for use in, non-government controlled Ukrainian territory	Regulations 48 to 50	A licence may be granted for the export, making available, supply, or delivery of infrastructure related goods if the goods are necessary for official purposes of consular missions or international organisations enjoying immunities in accordance with international law located in non-government controlled Ukrainian territory.
		A licence may be granted for the export, making available, supply, or delivery of infrastructure related goods if the goods are related to projects exclusively in support of hospitals, or other public health institutions providing medical services or civilian education establishments located in non-government controlled Ukrainian territory.
		A licence may be granted for the export, making available, supply, or delivery of infrastructure related goods if the goods are appliances or equipment for medical use.
		A licence may be granted for the export, making available, supply, or delivery of infrastructure related goods if the goods are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the export, making available, supply, or delivery of infrastructure related goods if the goods are necessary for the delivery of humanitarian assistance activity.
Prohibitions on the provision of technical assistance, brokering services, financial services and funds related to infrastructure-related goods to a person connected with, or for use in, non-government controlled Ukrainian territory.	Regulations 51 to 53	A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds related to infrastructure related goods if the technical assistance, brokering services, financial services or funds relate to infrastructure-related goods necessary for official purposes of consular missions or international organisations enjoying immunities in accordance with international law located in non-government controlled Ukrainian territory.
		A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds related to infrastructure related goods if the technical assistance, brokering services, financial services, or funds relate to infrastructure-related goods related to projects exclusively in support of hospitals, or other public health institutions providing medical services or civilian education establishments located in non-government controlled Ukrainian territory.
		A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds related to infrastructure related goods if the infrastructure-related goods are appliances or equipment for medical use.
		A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds related to infrastructure related goods if the technical assistance, brokering services, financial services or funds relate to infrastructure-related goods are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to the infrastructure related goods if the technical assistance, brokering services, financial services or funds are necessary for the delivery of humanitarian assistance activity.
Prohibition on providing certain services relating to a relevant infrastructure sector, and tourism, in non-government controlled Ukrainian territory	Regulation 54	A licence may be granted for the provision of services relating to a relevant infrastructure sector in non-government controlled Ukrainian territory if the services are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.
Prohibitions on the export, making available, transfer, supply, or delivery of military goods and technology to, or for use in, non-government controlled Ukrainian territory	Regulations 30B to 30E	A licence may be granted for the export, making available, transfer, supply, or delivery of military goods and technology to, or for use in, non-government controlled Ukrainian territory if the goods or technology relate to the execution of contracts concluded before 22 June 2022 or ancillary contracts necessary for the execution of such contracts.
		A licence may be granted for the export, making available, transfer, supply, or delivery of military goods and technology to, or for use in, non-government controlled Ukrainian territory if the export, making available, transfer, supply, or delivery is necessary for the maintenance and safety of existing capability within the UK.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to military goods and technology to, or for use in, non-government controlled Ukrainian territory	Regulations 30F to 30H	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds if the technical assistance, brokering services, financial services or funds relate to the transfer, supply or delivery of military goods and technology to, or for use in, non-government controlled Ukrainian territory for the execution of a contract concluded before 22 June 2022 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds if the technical assistance, brokering services, financial services or funds relate to the provision of spare parts necessary for the maintenance and safety of existing capability within the UK.
Prohibitions on interception and monitoring related services	Regulation 46K	A licence will not be granted for the provision of interception and monitoring services if there are reasonable grounds to determine that the services would be used for internal repression by the Government of Russia (as defined in regulation 6).
Prohibitions on export of jet fuel and fuel additives	Regulation 46N	A licence may be granted for the export of jet fuel and fuel additives if it relates to the execution of contracts concluded before 22 June 2022 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the export of jet fuel and fuel additives for the delivery of humanitarian assistance activity.
Prohibitions on the making available of jet fuel and fuel additives	Regulation 46N	A licence may be granted for the making available of jet fuel and fuel additives for use in Russia, or to a person connected with Russia, that are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulation 46N.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds for the export of jet fuel and fuel additives	Regulations 46O to 46Q	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds for the export of jet fuel and fuel additives if the services relate to the execution of contracts concluded before 22 June 2022 or ancillary contracts necessary for the execution of such a contract.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds for the export of jet fuel and fuel additives if the technical assistance, brokering services, financial services or funds are required for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to jet fuel if the technical assistance, brokering services, financial services or funds are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulations 46O to 46Q.
Prohibitions on the export, making available, supply, or delivery of G7 dependency and further goods	Regulation 46Y	A licence may be granted for the export, making available, supply, or delivery of G7 dependency and further goods necessary for the performance of any humanitarian assistance activity, including the work of international and non-governmental organisations carrying out relief activities.
		A licence may be granted for the export, making available, supply, or delivery of G7 dependency and further goods if the goods relate to the execution of contracts concluded before 21 July 2022 or ancillary contracts necessary for the execution of such contracts, provided the actions carried out under these contracts are completed by 29 October 2022.
		A licence may be granted for the export, making available, supply, or delivery of G7 dependency and further goods (as listed in Schedule 3E Part 3) if the goods relate to the execution of contracts concluded before 29 October 2022 or ancillary contracts necessary for the execution of such contracts, provided the actions carried out under these contracts are completed by 31 December 2022.
		A licence may be granted for the export, making available, transfer, supply, or delivery of G7 dependency and further goods if the goods are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the export, making available, supply, or delivery of G7 dependency and further goods for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the making available or transfer of making available of G7 dependency and further goods for use in Russia, or to a person connected with Russia, that are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulation 46Y.
		A licence may be granted for the export, making available, supply or delivery of G7 dependency and further goods if it is necessary for ensuring critical energy supply to any country.
Prohibitions on the provision of technical assistance, financial services or funds relating to G7 dependency and further goods	Regulations 46Z to 46Z1	A licence may be granted for the provision of technical assistance, financial services or funds related to G7 dependency and further goods if the if the technical assistance, financial services or funds are for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to G7 dependency and further goods	Regulations 46Z to 46Z2	A licence may be granted for technical assistance, brokering services, financial services or funds related to G7 dependency and further goods necessary for the performance of humanitarian assistance activity, including the work of international and non-governmental organisations carrying out relief activities.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to G7 dependency and further goods if the technical assistance, brokering services, financial services or funds are necessary for the execution of obligations arising from contracts concluded before 21 July 2022 or ancillary contracts necessary for the execution of such contracts, provided the actions carried out under these contracts are completed by 29 October 2022.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to further G7 dependency and further goods (as listed in Schedule 3E Part 3) if the technical assistance, brokering services, financial services or funds are necessary for the execution of obligations arising from contracts concluded before 29 October 2022 or ancillary contracts necessary for the execution of such contracts, provided the actions carried out under these contracts are completed by 31 December 2022.
		A licence may be granted for the provision of technical assistance, brokering services, financial services, or funds related to G7 dependency and further goods if the technical assistance, brokering services, financial services or funds are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to G7 dependency and further goods if the technical assistance, brokering services, financial services or funds are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulations 46Z to 46Z2.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to G7 dependency and further goods if it is necessary for ensuring critical energy supply to any country.
Prohibition of accounting services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of accounting services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibition of advertising services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of advertising services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibition of architectural services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of architectural services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibition of auditing services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of auditing services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibition of business and management consulting services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of management and business services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibition of engineering services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of engineering services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibition of IT consultancy and design services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of IT consultancy and design services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment.
Prohibition of public relations services	Regulation 54C	A licence may be granted for the delivery of humanitarian assistance activity.
		A licence may be granted for the provision of services in connection with the production or distribution of food provided that this is for the benefit of the civilian population.
		A licence may be granted for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for civil society activities that directly promote democracy, human rights or the rule of law in Russia.
		A licence may be granted for services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia.
		A licence may be granted for the provision of services if it is necessary for ensuring critical energy supply to any country.
		A licence may be granted for the export of public relations services if the service is required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure, or the environment. I
Restriction on legal advisory services	Regulation 54D	A licence may be granted for the provision of legal advisory services where a licencing ground would apply to the activity in relation to which the legal advisory services are being provided (the “relevant activity”) if the relevant activity was done by a UK person or taking place in the UK.
		The legal advisory services general licence issued on 11 August 2023 has now been revoked. Any entity who relied on the General Licences must, as per regulation 76, continue to retain relevant records for 4 years. Under regulation 79(3), information with respect to which a claim to legal professional privilege (in Scotland, to confidentiality of communications) could be maintained in legal proceedings does not have to be disclosed in relation to this general licence. The Secretary of State does not consider the retention of such information, or information which is protected from disclosure under laws of privilege applicable in other jurisdictions to be “appropriate” under regulation 76(2) for the purposes of the general licence.

Prohibition on the import and acquisition, directly or indirectly, of coal and coal products	Regulation 46Z18- 46Z20	A licence may be granted for the import and acquisition, directly or indirectly, of coal products if it relates to the execution of obligations arising from contracts, including ancillary services, concluded before 21 July 2022.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to coal products	Regulation 46Z21 – 46Z23	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to coal products if it relates to the execution of obligations arising from contracts concluded before 21 July 2022.
Prohibitions on the export, making available, supply, or delivery of Russia’s vulnerable goods	Regulation 46Z30	A licence may be granted for the export, making available, supply, or delivery of Russia’s vulnerable goods necessary for the performance of any humanitarian assistance activity, including the work of international and non-governmental organisations carrying out relief activities.
		A licence may be granted for the export, making available, supply, or delivery of Russia’s vulnerable goods for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the making available or transfer of making available of Russia’s vulnerable goods for use in Russia, or to a person connected with Russia, that are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to regulation 46Z30.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to Russia’s vulnerable goods	Regulations 46Z31 to 46Z33	A licence may be granted for technical assistance, brokering services, financial services or funds related to Russia’s vulnerable goods necessary for the performance of humanitarian assistance activity, including the work of international and non-governmental organisations carrying out relief activities.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to Russia’s vulnerable goods if the technical assistance, brokering services, financial services or funds are for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds related to Russia’ vulnerable goods if the technical assistance, brokering services, financial services or funds are necessary for the purposes of divestment from Russia. This may be granted where: - The goods are owned by: (i) a non-Russian person, or (ii) a person other than an individual, which is owned or controlled by a non-Russian person; and - There are no reasonable grounds to believe that the goods might be for a military end-user or have a military end-use; and - The goods are located in Russia and were located in Russia before the item became subject to the relevant regulations 46Z31 to 46Z33.
Prohibition on the provision of financial services and funds relating to restricted goods and G7 dependency and further goods	Regulations 28(1)(b) or (c), 28(2), 46Z1(1)(b) or (c), and 46z1(2)	A licence may be granted for the provision of financial services and funds to a person connected with Russia for directly or indirectly making available restricted goods and G7 dependency and further goods from Russia to a third country, the direct or indirect supply or delivery of restricted goods and G7 dependency and further goods from Russia to a third country, where: the restricted goods are ammonium nitrate, including fertilisers and fertiliser blends containing more than 15% by weight ammonium nitrate, except liquid fertilisers (containing any amount of ammonium nitrate) or dry fertilisers containing less than 15% by weight ammonium nitrate, controlled under 1C997, as listed on Part 2 of Schedule 2A - Critical-industry goods; the G7 dependency and further goods are ammonia in aqueous solution controlled under commodity code 2814 20 as listed in Schedule 3E Part 2 of the Russia Regulations. Where these are intended only for agricultural use. A general licence is available under this provision.

When you export goods, you may need to submit an electronic export declaration via the National Export System (NES), part of HMRC’s Customs Handling of Import and Export Freight (CHIEF) system. Guidance is available on how to make an export declaration.

Licence applications for import of goods can be made through the online import licensing system ICMS, managed by DBT’s Import Controls Team. The DBT Import Controls Team will, to the extent possible, aim to inform the trader of the application outcome within 30 days. However, in some circumstances, for operational or legal reasons, DBT may need to take longer than the 30 day period. We will inform the applicant if this is the case.

When you import goods, you may need to submit an import declaration through HMRC’s CHIEF system. Guidance is available on how to make an import declaration.

By exception within trade sanctions, OFSI is responsible for issuing licences relating to the supply or delivery by ship of oil and oil products under the commodity codes 2709 and 2710 from Russia to and between third countries and services associated with that supply or delivery (such as financial services and brokering). OFSI can be contacted by emailing oilpricecap.ofsi@hmtreasury.gov.uk. Full guidance on the Russian Oil Services ban can be found on the OFSI website.

3.5 Overlap with strategic export licensing

Military goods and military technology

Please note the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence which is valid under that legislation. This means that all licence applications relating to military goods and military technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.

The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the regulations and the Export Control Order 2008 as an application for a licence under both pieces of legislation. This means that only a single licence application is required.

The application will be considered against the relevant licensing criteria. If a licence is granted it will be valid under both the Export Control Order 2008 and the regulations.

Dual-use goods and technology

Please note that the export of and trade in dual-use goods and technology are also controlled under the Dual-Use Regulation. Authorisations under that regulation are granted by the Secretary of State for Business and Trade under licensing powers in the Export Control Order 2008.

This means that all licence applications relating to items which are controlled dual-use goods and technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the regulations is unlikely to be granted if an authorisation is refused for the same activity under the Dual-Use Regulation.

As explained above in relation to military goods and technology, only a single licence application will be required in relation to dual-use goods and technology which falls within the scope of both the regulations and the Dual-Use Regulation. If the application is compatible with both criteria, a licence will be granted which will be valid under the Dual-Use Regulation and the Export Control Order 2008 as well as the regulations.

Overlap between items falling under Schedule 2C (aviation and space goods and technology) which are also military goods and technology or dual-use goods and technology

Where an item falls within the definition of “aviation and space goods” or “aviation and space technology” list and also within the definitions of either military goods, military technology, dual-use goods or dual-use technology, it is subject to prohibitions under all relevant regulations. If you wish to rely on an exception, there must be a relevant exception available for all relevant prohibitions that it engages.

Similarly, if you wish to apply for a licence, your activity must be compatible with licensing grounds for all relevant prohibitions that it engages. The ECJU will assess your application against all relevant prohibitions and licensing grounds.

Overlap between trade sanctions and financial sanctions

If you import or export goods or services, you need to consider if financial sanctions apply to you. You may need a licence from OFSI as well as from ECJU, OTSI or the Import Controls Team.

Transit control

Certain goods transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception meaning that in many situations a licence is not required. This exception does not apply to goods destined for Russia, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to Russia.

3.6 Licensing for transport sanctions

Licences may also be issued for certain transport activities that would otherwise be prohibited by the regulations. DfT has overall responsibility for transport sanctions licensing. The Secretary of State for Transport is ultimately responsible for decisions to grant or refuse a transport sanctions licence in any individual case.

For some prohibitions there are some specific activities that DfT considers are likely to be consistent with the aims of the sanctions.

These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions you should make this clear and explain why you believe this to be the case in your application for a licence.

Prohibition description	Prohibition reference	Considerations for licensing
Prohibition on the movement of Russian aircraft	Regulation 57J	A licence may be granted for the overflight of UK airspace, or for the landing in the UK, of a Russian aircraft where it is necessary either: - for the delivery of humanitarian assistance, or; - for the official purposes of a diplomatic mission or consular post in Russia or the UK, or of an international organisation enjoying immunities in the UK in accordance with international law, or; - for testing the aircraft for the purposes of providing technical assistance.

You should not assume that a licence will be granted or engage in any activities prohibited by the sanctions until your licence has been granted.

A licence may be general or be issued to a particular category of person or to a particular person. Licences may contain conditions and they may be of a defined duration or of indefinite duration.

Information on how to apply for a transport sanctions licence is available on GOV.UK.

3.7 Immigration sanctions

If you are subject to immigration sanctions the Home Office may direct, on a case by case basis, that the sanction does not apply in particular circumstances, such as for travel to, or through, the UK for a UN sponsored meeting. You can check how to apply for a UK visa, and find further information about travelling to the UK on GOV.UK.

Question 4

4. Further information

Accepted Answer

Sign up to receive Notices to Exporters and view the Notices to Importers for updates on trade sanctions.

To receive an email alerting you to any changes to the consolidated list of financial sanctions targets, you can subscribe to OFSI’s e-alert.

The amount of any export of hydrazine shall be calculated in accordance with the launch or launches or the satellites for which it is made and shall not exceed a total quantity of 800 kg for each individual launch or satellite. The amount of any export of monomethyl hydrazine shall be calculated in accordance with the launch or launches or the satellites for which it is made. ↩
The amount of hydrazine that can be exported for each individual launch or satellite shall not exceed a total quantity of 800 kg. The amount of any export of monomethyl hydrazine shall be calculated in accordance with the launch or launches or the satellites for which it is made. ↩
The amount of hydrazine that can be exported for each individual launch or satellite shall not exceed a total quantity of 800 kg. The amount of any export of monomethyl hydrazine shall be calculated in accordance with the launch or launches or the satellites for which it is made. ↩

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1. Prohibitions and requirements imposed by the Russia (Sanctions) (EU Exit) Regulations 2019

1.1 Non-government controlled territory of Ukraine

1.2 Designation of persons

1.3 Specification of ships

1.4 Financial sanctions

Asset freeze and making available provisions

Other financial and investment restrictions

Loan and credit arrangements

Correspondent banking relationships and sterling payments

Investments in relation to non-government controlled Ukrainian territory

Provision of financial services for the purpose of foreign exchange reserve and asset management

Investments in relation to Russia

Trust Services

Suspension of Banking Act 2009 requirement to recognise third-country resolution actions

1.5 Director disqualification sanctions

1.6 Trade sanctions

Export of goods

Import of goods

Supply and delivery of goods

Making available or acquiring goods and technology

Transfer of technology

Technical assistance

Financial services and funds related to goods and technology

Brokering services

Other service provisions

DBT contact details

1.7 Transport sanctions

Shipping sanctions

Aircraft sanctions

1.8 Immigration sanctions

1.9 Information and record keeping

2. How will these sanctions measures be enforced?

2.1 Financial sanctions

2.2 Director disqualification sanctions

2.3 Trade sanctions

2.4 Transport sanctions

3. Are there circumstances when I can get an authorisation or licence for a sanctioned activity?

3.1 Exceptions

3.2 Licensing for financial sanctions

3.3 Licensing for director disqualification sanctions

3.4 Licensing for trade sanctions

3.5 Overlap with strategic export licensing

Military goods and military technology

Dual-use goods and technology

Overlap between items falling under Schedule 2C (aviation and space goods and technology) which are also military goods and technology or dual-use goods and technology

Overlap between trade sanctions and financial sanctions

Transit control

3.6 Licensing for transport sanctions

3.7 Immigration sanctions

4. Further information

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