In this weekly update, we summarise the most notable updates in the UK sanctions world.

1. Russia Sanctions

• UK Government adds Russian bank to UK sanctions list: On December 15, 2023, the UK Government added JSC Bank Novikombank to the UK sanctions list under the Russia regime. The UK Government also amended entries on the UK sanctions list for 27 other financial institutions, which each remain subject to an asset freeze, correspondence banking restrictions and trust services sanctions. (Notice_Russia_151223.pdf (publishing.service.gov.uk))
• UK Government introduces new trade and financial sanctions against Russia: On December 14, 2023, the UK Government introduced the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023, which implement new trade and financial sanctions targeting Russia. The new legislation bans inter alia the export of certain goods carrying a risk of military or industrial usage, including machine parts and electronics, and the import of Russian metals and diamonds. (New trade and financial sanctions against Russia come into force - GOV.UK (www.gov.uk); https://www.legislation.gov.uk/uksi/2023/1364/contents/made; https://www.legislation.gov.uk/uksi/2023/1367/contents/made).
• UK Government issues new general trade licence for Russian iron and steel: On December 11, 2023, the UK Government issued Licence GBSAN0001, which permits the import (as well as related services) into the UK of goods that would otherwise be prohibited by the third country Russia-connected iron and steel ban in certain circumstances. (general trade licence iron and steel russia sanctions 1 (publishing.service.gov.uk)).
• UK announces new unit to clamp down on evasion of Russian sanctions: On December 11, 2023, UK Industry and Economic Security Minister, Nusrat Ghani, announced that the UK government will launch the Office of Trade Sanctions Implementation (OTSI) in early 2024. OTSI will be responsible for inter alia the civil enforcement of trade sanctions, investigating trade sanctions breaches, issuing penalties and referring cases to HMRC. (New unit to crack down on firms dodging Russian sanctions - GOV.UK (www.gov.uk); https://www.mayerbrown.com/en/perspectives-events/publications/2023/12/uk-government-to-launch-new-unit-to-enforce-export-controls-and-trade-sanctions).
• UK Government amends one entry on UK sanctions list under Russia regime: On December 11, 2023, the UK Government made an administrative amendment to the entry for OOO MVIZION under the Russia sanctions regime. The entity remains subject to an asset freeze and trust services sanctions. (Notice_Russia_111223.pdf (publishing.service.gov.uk))

2. Iran Sanctions

• UK launches Iran sanctions regime: On December 14, 2023, the Iran sanctions regime came into force, revoking and replacing the Iran (Human Rights) sanctions regime. As a result, 173 entries have been transferred from the Iran (Human Rights) regime to the Iran regime and a further eight entries have been added to the UK sanctions list. These are: (i) Esmail Qaani; (ii) Mohammed Saeed Izadi; (iii) Ali Marshad Shirazi; (iv) Majid Zaree; (v) Mostafa Majid Khani; (vi) Khaled Qaddoumi; (vii) Nasser Abu Sharif; and (viii) Islamic Revolutionary Guard Corps Quds Force. (Notice_Iran_141223.pdf (publishing.service.gov.uk); New Iranian sanction regime comes in to force - GOV.UK (www.gov.uk)).

3. Counter-terrorism Sanctions

• UK Government adds seven entries to UK sanctions list under counter terrorism regime: On December 13, 2023, the UK Government, in a coordinated act with the United States, designated seven individuals affiliated with Hamas under the Counter Terrorism International Sanctions Regime. The individuals sanctioned are: (i) Akram Al-Ajouri; (ii) Aiman Ahmad Al-Duwaik; (iii) Khaled Chouman; (iv) Maher Rebhi Namr Obeid; (v) Mahmoud Zahar; (vi) Ali Baraka; and (vii) Rida Ali Khamis. (UK and US target Hamas with new sanctions to isolate terror group - GOV.UK (www.gov.uk); https://assets.publishing.service.gov.uk/media/65798c920467eb001355f6cb/Notice_Counter_Terrorism__International__131223.pdf).
• UK Government amends one entry on UK sanctions list under counter terrorism regime: On December 11, 2023, the UK Government amended the entry for Adbelbasit Hamza Elhassan Mohamed Khair, under the Counter Terrorism (International) sanctions regime. This individual remains subject to an asset freeze, travel ban, and targeted arms embargo. (Notice_Counter_Terrorism__International__111223.pdf (publishing.service.gov.uk))

4. Haiti Sanctions

• UK Government adds four entries to UK sanctions list under Haiti regime: On December 11, 2023, the UK sanctioned four individuals under the Haiti Sanctions Regime. The individuals are: (i) Johnson Andre, (ii) Renel Destina, (iii) Wilson Joseph, and (iv) Vitelhomme Innocent, each of whom are believed to be gang leaders. (Notice_Haiti_111223.pdf (publishing.service.gov.uk)).

5. Belarus Sanctions

• UK Government amends two entries on UK sanctions list under Belarus regime: On December 11, 2023, the UK Government made two administrative amendments to the entries for (i) Mikhail Ivanovich Dola and (ii) Mikhail Kavaliou, under the Belarus sanctions regime. Both individuals remain subject to an asset freeze and travel ban. (Notice_Belarus_111223.pdf (publishing.service.gov.uk)).

6. Other Sanctions

• OFSI publishes annual sanction review for 2022-2023: On December 14, 2023, OFSI published its annual report for year 2022-2023. The report sets out inter alia details of OFSI’s enforcement activity and licensing decisions during the reporting period. (OFSI_Annual_Review_2022_to_2023_Strengthening_our_Sanctions.pdf (publishing.service.gov.uk)).

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