Sanctions tracker: recent Russia sanctions developments

In this post, we provide a round-up of key recent Russia sanctions developments in the UK, including new and amended general licences, guidance from the Office of Financial Sanctions Implementation ("OFSI") and developments in respect of sanctions on gold and circumvention. Read more

Court takes a tough stance in challenge to sanctions decisions on judicial review principles

In R. (on the application of Mikhail Fridman) v HM Treasury [2023] EWHC 2657 (Admin) the High Court dismissed all grounds of challenge raised by an individual designated under the sanctions regime. In doing so the court made comments on the proper role of judicial review and evidence in such proceedings, in keeping with the recent trend of insisting on procedural rigour in public law cases. Read more

Court of Appeal confirms judgments can be entered in favour of Russian sanctioned parties but leaves uncertainty in relation to the “ownership and control” test

The Court of Appeal has confirmed that UK sanctions do not preclude the entry of judgments in favour of Russian sanctioned parties: Mints v PJSC National Bank Trust [2023] EWCA Civ 1132. The court also held that the Office of Financial Sanctions Implementation (OFSI) is entitled to license a sanctioned party to pay an adverse costs order, security for costs or damages on a cross-undertaking in damages. It can also license payment of a costs order in favour of a sanctioned party. Read more

Sanctions tracker: UK issues general licence in respect of legal services restrictions

The UK introduced restrictions on the provision of legal services to Russia in June 2023 (as summarised in our previous post). Since then, the legal industry has raised a number of concerns about the drafting of the relevant legislation, culminating in the issuance of a new general licence (the "GL") which seeks to address some of the most significant unintended consequences arising from the new restrictions. In this post, we review the provisions of the GL and the remaining issues with these restrictions, as well as providing a round-up of key recent Russia sanctions developments in the UK and EU. Read more

Sanctions tracker – UK introduces legal services restrictions

The UK's long-awaited sanctions restricting the provision of legal services to Russia were announced on 29 June. The announcement gives a somewhat misleading impression of the law, and we summarise the new restrictions in this post. The new measures are introduced by the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (the "Amending Regulations"), which amend the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). Read more

Sanctions tracker: EU adopts 11th sanctions package and UK introduces Russia-related legislation

Following its announcement of an 11th package of Russia sanctions in May (which we covered here), the European Union has now adopted the package. Key elements of the 11th sanctions package include fresh targeted sanctions against individuals and entities, an enlargement of restrictions on the sale, export and transit of certain goods and technology, as well as additional measures to prevent sanctions circumvention.  We summarise the key elements in this post, along with a round-up of other recent sanctions developments from the UK. Read more