Understanding Export Controls in UK Sanctions Legislation Relating to Russia: Issues for Lenders

Butterworths Journal of International Banking and Financial Law
November 30, 2022

Jacqueline Cook, Of Counsel and Senior Knowledge Development Lawyer in our London Trade  & Export Finance Practice, has written an article, "Understanding Export Controls in UK Sanctions Legislation Relating to Russia: Issues for Lenders," first published by Butterworths Journal of International Banking and Financial Law (JIBFL) in November 2022.

The article focuses on the identification of assets that are subject to export controls and looks at some considerations for lenders in finance documentation. It provides examples from a number of statutory instruments issued by the UK Parliament under The Russia (Sanctions) (EU Exit) Regulations 2019 since the invasion of Ukraine by Russia in Spring 2022.

Since the time of writing, the UK Parliament has passed a further two statutory instruments:
(i) the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (SI 2022/1110) the majority of which came into force on 29 October 2022 with regulation 6 coming in on 1 January 2023  which covers restrictions on the import of liquefied natural gas; and (ii) the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (SI 2022/1122), which comes  into force on 5 December 2022 which restricts imports, exports and transport of oil and certain oil products between Russia and third countries or through third countries to some degree. Financial services and brokerage supporting these actions are also prohibited. The UK Government Department for Business, Energy and Industrial Strategy has issued guidance to assist with the reading of amendment No. 16 (SI 2022/1122).

If you would like more information on the effect of the UK Sanctions on Russia, or further details of the additional statutory instruments, please contact Jacqueline Cook at jcook@sullivanlaw.com or Sam Fowler-Holmes at sfowlerholmes@sullivanlaw.com.

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