Sanctions: The UK’s Amendment 17 Regulations

Rahman Ravelli’s Aziz Rahman and Zulfi Meerza detail the main points of the UK’s latest sanctions on Russia.

On 15 December 2022, the UK adopted the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (the Regulations), which implement new financial and trade sanctions.

The new measures are significant as they expand the scope of the prohibition on professional and business services. They were expected, following the UK government’s announcement on 30 September 2022 in response to Russia’s illegal annexation of Ukrainian regions.

The new measures also introduce a new prohibition on the provision of trust services to Russia. This was a development that was anticipated as the European Union (EU) has introduced similar provisions.

It is important to note, however, that the proposed ban on “transactional legal advisory services” has not yet been introduced at this stage.

Key Features of the New Measures

Earlier this year, the UK introduced a professional services ban, which imposed prohibitions on the direct or indirect provision of accounting, business and management consulting, and public relations services to a “person connected with Russia”. Under the new measures, the UK has now expanded the UK professional services ban to also cover advertising, architectural, auditing, engineering, IT consultancy and design services, subject to certain exceptions. Schedule 3J of the Regulations helpfully provides definitions of the professional and business services covered by these prohibitions.

There is now the aforementioned prohibition on the provision of services related to trusts or similar arrangements to - or for the benefit of - designated persons or persons connected with Russia, subject to certain exceptions. The prohibition covers trust services as simple as providing a registered office or correspondence address for a trust.

The Regulations also amend existing restrictions on transferable securities and money market instruments, loans and credit arrangements, and investments in Russia. These amendments have been designed to prohibit new investments in Russia via third countries.