New restrictions on the trade in Russian metals

On 12 April, the UK government announced a joint action with the US to “clamp down harder on prohibited Russian metal exports”. Please see our separate post for further detail on the new restrictions.

Guidance on financial sanctions and the maritime sector

The Office of Financial Sanctions Implementation has published some additional guidance on financial sanctions and their impact on the maritime sector in the form of: (i) a blogpost containing key compliance tips; (ii) updated guidance for the sector; and (iii) a summary factsheet.


Post-legislative scrutiny of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”)

The UK government recently published a post-legislative scrutiny memorandum on SAMLA, providing a preliminary assessment of the provisions and implementation of the Act.

The following sections of the memo may be of particular interest to readers:

  • Information on the numbers of administrative reviews of designations carried out to date (see Table B on page 27).
  • A summary of key court cases reviewing designations (from page 34).
  • A case study of the UK’s Russia sanctions regime to illustrate the role that SAMLA plays in enabling the UK’s sanctions response to international crises (from page 53).


UK government launches sanctions perception survey

The UK government has launched a “sanctions perceptions survey” as part of its efforts to improve sanctions infrastructure. The survey asks recipients to provide (anonymous) feedback on how sanctions have impacted them and their organisation.

The survey data is being collected by a third party; aggregated survey data will then be used to formulate recommendations on how the Government can better support industry. A follow-up survey will be conducted in early 2025 to measure changes in industry perceptions as a result of the UK Government’s efforts to support industry.

The survey can be accessed here.


Sanctions-related decisions and human rights

Our public law colleagues have recently published their analysis of two recent appeals concerning decisions made by Government ministers under the Russia (Sanctions) (EU Exit) Regulations 2019. In considering these appeals, the Court of Appeal discussed the role of both a first instance court and an appellate court when reviewing decisions based on proportionality under the Human Rights Act 1998.

Susannah Cogman
Susannah Cogman
+44 20 7466 2580
Elizabeth Head
Elizabeth Head
Of Counsel
+44 20 7466 6443