In this weekly update, we summarise the most notable updates in the UK sanctions world.
1. Russia Sanctions
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OFSI extends general licence relating to Evraz plc’s North American subsidiaries: On December 22, 2023, OFSI updated General Licence INT/2022/1710676 relating to the continuation of business of the North American subsidiaries of Evraz plc. Among other things, the general licence was extended to 30 September 2024. (https://assets.publishing.service.gov.uk/media/65857431ed3c3400133bfdde/December_INT.2022.1710676_General_Licence_extension.pdf;
https://assets.publishing.service.gov.uk/media/6585743ffc07f300128d46ca/December_INT.2022.1710676_Publication_Notice_extension.pdf).
- OFSI publishes blog on correspondent banking restrictions: On December 21, 2023, OFSI published a blog post describing recent updates to the correspondent banking restrictions under UK sanctions. In the blog post, OFSI notes that it anticipates that “most of the transactions affected by this measure will be transactions which have used correspondent banking earlier in the chain of transactions, and where the correspondent bank is designated for the purposes of regulation 17A.” (https://ofsi.blog.gov.uk/2023/12/21/updates-to-correspondent-banking-restrictions/).
- UK Government amends Russia sanctions list: On December 21, 2023, the UK Government made one variation to the entry for Yuri Alekseyevich Soloviev. The individual is subject to an asset freeze, trust services, and transport sanctions. (The UK Sanctions List - GOV.UK (www.gov.uk)).
- OFSI updates Oil Price Cap Guidance: On December 20, 2023, the UK Government updated its guidance to the private sector on the Maritime Services Ban and Oil Price Cap. Among other things, the updated guidance provides additional clarity around the attestation requirements, reporting requirements for UK nationals in third countries and reporting timelines. The corresponding general licence has also been updated. (OFSI OPC Guidance - December 2023.docx (publishing.service.gov.uk); General_Licence_-_Oil_Price_Cap_INT_2022_2469656.pdf (publishing.service.gov.uk)).
- UK Government amends Russia sanctions list: On December 18, 2023, the UK Government amended the entry for Sergei Sergeevich Tregub, an individual that remains subject to an asset freeze, travel ban, trust services sanctions, and transport sanctions. The UK Government also made an administrative change to the entry for Alexander Borisovich Arutyunov, who remains subject to an asset freeze, travel ban, trust services sanctions. (The UK Sanctions List - GOV.UK (www.gov.uk)).
2. Other sanctions
- OFSI updates financial sanctions guidance: On December 21, 2023, OFSI updated its guidance on financial sanctions, monetary penalties and enforcement and Russia sanctions. The latest version of OFSI’s guidance is available at: https://www.gov.uk/government/publications/financial-sanctions-faqs.
- OFSI updates guidance on reporting information to OFSI: On December 21, 2023, OFSI updated its guidance on reporting information to OFSI. The updates included adding a new DP Reporting Template (for UK and non-UK Persons respectively) and an Immobilised Assets Reporting Document. The guidance also explains to whom and how the relevant documents apply (https://www.gov.uk/guidance/suspected-breach-of-financial-sanctions-what-to-do).
- OFSI updates UK Israel & Occupied Territories general licence: On December 20, 2023, OFSI update General Licence: Israel And The Occupied Palestinian Territories Humanitarian Activity INT/2023/3749168 to (i) add the Disasters Emergency Committee as a Relevant Person; (ii) amend the definition of a UK Funded Person; and (iii) provide clarity on reporting requirements and the geographical extent of the General Licence. (Gaza_Humanitarian_General_Licence_INT-2023-3749168_GL.pdf (publishing.service.gov.uk)).
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