UK GOVERNMENT SANCTIONS – RUSSIA AND BELARUS
7 March 2022
Following engagement with the Cabinet Office Registered Farriers are advised to note the following advice:
Registered Farriers may continue to trade with Russia and Belarus if their products, services, or clients are not covered by the current trade and financial sanctions.
Please refer to the current sanctions list for the former – ODS file, filter column Q for ‘Russia and/or Belarus’.
https://www.gov.uk/government/collections/uk-sanctions-on-russia
https://www.gov.uk/government/publications/the-uk-sanctions-list
Please note however that even if your product, services, or clients do not fall under the current trade sanctions, you must conduct due diligence to see whether your operations fall under current financial sanctions. For example, if the bank of your Russian/Belarusian client is on the sanctioned list this will impact their ability to pay you.
The due diligence relating to financial sanctions you should consider when importing/exporting include (but not limited to) are:
· Who and where the goods or services are coming from or going to? It is possible that financial sanctions such as an asset freeze may apply to one of the parties or to the financial aspects of the trade.
· Whether a designated person is based in a different country to the one you are operating in but is still subject to financial sanctions in that country.
You should also consider if individuals or organisations are ‘owned’ or ‘controlled’ either directly or indirectly by designated persons. If you are unsure, it is important that you seek legal advice.
Financial sanctions currently in force:
· Full list of those currently subject to financial sanctions under the Russia Financial Sanctions regime can be found on OFSI’s Russia regime page
· For all those designated with financial sanctions, please consult the OFSI Consolidated list
· In addition to those subject to an asset freeze, there are restrictions on capital market access for certain Russian State-owned entities. These can be found are The Russia (Sanctions) (EU Exit) Regulations 2019, and are further detailed in OFSI’s Russia Regime guidance
· For guidance on an overall approach to financial sanctions, please consult OFSI’s general guidance
· For specific guidance for those Importing / Exporting, please consult OFSI’s Guidance for the Import / Export sector
Specifically on Belarus, please be advised that new UK sanctions will apply to Belarussian individuals and organisations that have supported the Russian invasion of Ukraine:
It is also worth noting there are pre-existing sanctions on Belarus:
· For trade sanctions, visit: https://www.gov.uk/government/publications/republic-of-belarus-sanctions-guidance/the-republic-of-belarus-sanctions-guidance (Section 1.3).
· For a list of all financial sanctions in force against Belarus, visit: https://www.gov.uk/government/publications/the-uk-sanctions-list (Select “New ODS format UK Sanctions List” and filter “Belarus” in Column Q).
· More info and links to the relevant legislation can be found here: https://www.gov.uk/government/collections/uk-sanctions-on-the-republic-of-belarus
If you would like guidance about cash flow, fulfilling an export, or getting paid, please contact UK Export Finance.
You can get in touch with UKEF here https://www.great.gov.uk/trade-finance/ or email customer.service@ukexportfinance.gov.uk
It is for business to decide whether to trade with Russia. Sanctions against Russia from UK and allies, and expected retaliatory measures, will continue to create a highly unpredictable trading environment for UK business.
Moving goods to and from Russia, settling financial transactions with suppliers and customers, and trading with certain businesses and individuals, have all been impacted by the newly announced sanctions and should be considered. It is advised that any business planning to continue trading with Russia, should seek necessary legal advice.
