UK WEEKLY SANCTIONS UPDATE – WEEK OF APRIL 22, 2024 – Export Controls & Trade & Investment Sanctions

In this weekly update, we summarise the most notable
updates in the UK sanctions world. If you have any questions in
respect of any of the developments set out below, please do not
hesitate to contact a member of our London Global and Government
Trade team listed above.

1. Russia Sanctions

• OFSI issues new Legal Services General Licence
  under the Russia Regulations: On April 26,
  2024, OFSI issued General Licence INT/2024/4671884, replacing
  General Licence INT/2023/3744968, with effect from April 29, 2024.
  At the same time, OFSI also issued 37 FAQs in connection with the
  General Licence. The General Licence authorises certain payments
  connected with the provision of legal services to a designated
  person subject to certain conditions. The general licence expires
  on October 28, 2024. (Legal_services_INT.2024.4671884_PN.pdf
  (publishing.service.gov.uk); https://assets.publishing.service.gov.uk/media/662ba57d6963baceeb2252b3/Legal_services_INT.2024.4671884_PN.pdf).




• HMRC issues compound settlement offers to six UK
  exporters: On April 25, 2024, the ECJU issued a notice to
  exporters reporting that, between January and March 2024, HMRC
  issued settlement offers to six UK companies. These settlements
  were in relation to: a breach of licence conditions in relation to
  the export of military goods; the unlicensed exports of military
  goods controlled by The Export Control Order 2008; and the
  unlicenced exports of dual use goods controlled by Retained
  Regulation 428/2009. HMRC has seen an increase over the last 12
  months in the number of voluntary disclosures relating to:
  unlicenced exports; incorrect licence usage; and breach of licence
  conditions. (Notice to exporters 2024/08: breaches of strategic
  export compound settlement issued – GOV.UK (www.gov.uk)).




• HMRC issues compound settlement of over £1
  million relating to export of goods in breach of Russia
  sanctions: On April 25, 2024, the ECJU published Notice to
  Exporters 2024/07 announcing a compound settlement issued in March
  2024 worth £1,058,781.79 in relation to the export of goods
  in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
  Over £20 billion of UK-Russia bilateral trade (2021 figures)
  is now under full or partial sanction. There has been a 94% fall in
  Russian imports into the UK and a 74% fall in UK exports to Russia.
  (NTE 2024/07: Russian sanctions compound settlement
  issued – GOV.UK (www.gov.uk)).




• UK Supreme Court upholds UK Court of appeal decision to
  grant an anti-suit injunction against Russian company’s
  proceedings against UniCredit: On April 23, 2024, in
  UniCredit Bank GmbH v RusChemAlliance LLC (RCA), the UK
  Supreme Court held that an anti-suit injunction against proceedings
  brought by RCA against UniCredit should be upheld. The declarations
  and injunctive relief granted by the Court of Appeal on January 29,
  2024, will remain in force. RCA wished to bring proceedings on the
  basis of non-payment by UniCredit under bonds issued to RCA.
  UniCredit was prohibited from making payment because of EU Russia
  sanctions. There were parallel proceedings in the Arbitrazh Court
  of the St Petersburg and Leningrad region which were adjourned
  pending the UK Supreme Court’s consideration of the appeal. (Watch Decision in the matter of UniCredit Bank
  GmbH (Respondent) v RusChemAlliance LLC (Appellant) – The Supreme
  Court).

2. Iran Sanctions

• UK Government adds six entries to the UK
  sanctions list under the Iran regime: On
  April 25, 2024, the UK Government added two individuals (Abbas Abdi
  Asjerd and Seyed Mohsen Vahabzadeh) and four entities (Alvand
  Motorbuilding Industries Company, Bonyan Danesh Shargh Private
  Company, Moj Gostar Aseman Parvaz Company and Pishro Sanat Aseman
  Sharif Company) to the UK sanctions list under the Iran regime.
  They are each believed to be or have been involved in hostile
  activity by the Government of Iran by carrying on business in the
  Iranian defence sector. (Notice_Iran_250424.pdf
  (publishing.service.gov.uk)).

3. Other Sanctions

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This
Mayer Brown article provides information and comments on legal
issues and developments of interest. The foregoing is not a
comprehensive treatment of the subject matter covered and is not
intended to provide legal advice. Readers should seek specific
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