The United Kingdom on 10 February 2022 amended its Russian sanctions law to more easily add persons to its targeted sanctions regime, which enhances the UK’s ability to quickly impose sanctions against most parts of the Russian economy (and their operations worldwide).
The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022 enable the UK government to impose sanctions on persons who meet new designation criteria. Those sanctions can be imposed at any time if the UK government believes they serve the purpose of encouraging Russia to cease destabilising or undermining Ukraine.
Under the new law, the UK government may only impose sanctions against a person who is involved in either
A “person involved in obtaining a benefit from or supporting the Government of Russia” includes persons
The amendments appear to be timed politically to coincide with meetings on 10 February 2022 between the UK and Russian foreign ministers in Moscow. If the UK decides to impose new sanctions against Russia—presumably only after a Russian invasion of Ukraine—there will need to be new UK laws to implement those sanctions, which could fall into the below categories:
If you have any questions or would like more information on the issues discussed in this LawFlash, the Ukraine conflict, or on actual and potential Russia sanctions imposed by the US, EU, or UK generally, please contact any of the following Morgan Lewis lawyers:
Ukraine Task Force
Giovanna M. Cinelli
Jennifer A. Josefson
Kenneth J. Nunnenkamp
Carl A. Valenstein
Jiazhen (Ivon) Guo
Katelyn M. Hilferty