Articles Posted in United Kingdom (UK)

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On September 12, 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), granting the UK’s trade sanctions enforcement body, the Office of Trade Sanctions Implementation (OTSI), new implementation and enforcement powers effective from 10 October 2024. The Regulations also grant the Department for Transport (DfT) corresponding powers in relation to aircraft and shipping sanctions (i.e., sanctions relating to the movement, registration and ownership of aircrafts and ships).

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The United Kingdom introduced new sanctions against Russia on December 14, 2023, with the European Union also adopting its twelfth package of sanctions against Russia on December 18, 2023.

The latest UK restrictions include:

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On June 8, 2023, the United States and the United Kingdom announced the Atlantic Declaration for a Twenty-First Century U.S.-UK Economic Partnership (“Declaration”). The Declaration reaffirms the need to adapt and reimagine the unique alliance between the two countries. From critical and emerging technologies to digital transformation, clean energy, and defense collaboration, businesses can leverage the partnership to exploit new trans-Atlantic opportunities.

(This is the first post of a three-part series on U.S., UK and EU alignment on economic security strategy.)

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Takeaways

  • Sanctions operate prospectively and do not affect payment obligations to a non-sanctioned party accruing before sanctions became effective.
  • Payment obligations under standby letters of credit at issue were autonomous and unconnected with the underlying transaction.
  • The fulfilment of an independent obligation owed by a German bank to Irish-incorporated aircraft lessors was found not to have intended to benefit the Russian entities involved in other elements of the transaction.

The English Court recently confirmed that sanctions do not excuse non-payment to a non-sanctioned party where the aircraft lease arrangements and related letters of credit were created before sanctions came into effect: Celestial Aviation Services Limited, Constitution Aircraft Leasing (Ireland) 3 Limited and another v UniCredit Bank AG (London Branch) [2023] EWHC 663 (Comm).

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On February 24 and 25, 2023, the United Kingdom and European Union each adopted additional sanctions against Russia due to the ongoing conflict in Ukraine. These new measures are summarized below.

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In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian territories. The referendums have been condemned by the Group of 7 (G7) nations, which committed to imposing further economic costs on individuals and entities both inside and outside of Russia.

The latest measures include actions by the Office of Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the U.S. Department of State, and the United Kingdom (UK) Office of Financial Sanctions Implementation (OFSI), as well as further announcements from the European Union (EU), described in turn below.

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EU update
On July 21, 2022, the EU published its “maintenance and alignment” package of sanctions. This latest package seeks to tighten existing sanctions, perfect their implementation, and strengthen their effectiveness. In summary, this latest package has the following effects:

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EU introduces a sixth package of sanctions.

On June 3, 2022, the EU adopted a sixth package of sanctions against Russia which includes economic, individual, media and diplomatic measures. (See the full text of the regulation here.) Continue reading →

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UK DEVELOPMENTS

Further designations
On 10 March 2022, the UK Government added a further seven oligarchs to its list of sanctions targets, including the owner of Chelsea football club, Roman Abramovich. This was closely followed on 11 March 2022 by the sanctioning of 386 members of the Russian Duma (comparable sanctions had already been imposed by the EU).

Further aircraft-related sanctions
Airport operators, air traffic controllers and the Secretary of State have been granted new powers to issue directions to Russian aircraft (e.g., to take off, not to take off, and to land) and to suspend and revoke permissions needed to operate. The new provisions also allow the detention and movement of Russian aircraft and prohibit a person from providing aircraft insurance or reinsurance services to a person connected with Russia or where the aircraft is for use in Russia.

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