Morgan Lewis US and Russia Sanctions Update
UK Sanctions (post-Brexit)
Brexit transition period ended on 31 Dec. 2020
The EU sanctions (see slides 71-83) thus lost effect in UK as of that date
But the UK had already adopted its own Russia sanctions, which diverge from the EU sanctions
to some extent (e.g., the finance sanctions carve-out is limited to UK-based, rather than EU-
based, subsidiaries of five targeted Russian banks - see slides 77-78)
This is
the Russia (Sanctions) (EU Exit) Regulations 2019 as further amended
its substantive provisions first came into force on 31 Jan. 2020, then fully on 31 Dec. 2020
covers general sectoral sanctions, blacklisting sanctions, and Crimea sanctions against Russia
These Regs. (based on the Sanctions and Anti-Money-Laundering Act 2018) have now revoked
/replaced the EU Regs. as of 31 Dec. 2020, and allow the UK gov't now to autonomously
amend/lift the existing sanctions, impose new sanctions etc.
See also the accompanying Explanatory Memo from April 2019
explaining the reasons for keeping sanctions on Russia and justifying associated criminal sanctions and
penalties
and two related reports per Sections 2(4) and 18 of the underlying Sanctions and Anti-Money
Laundering Act of 2018
And the UK's underlying act on criminal liability for violations of the EU Russia sanctions -
2014 Regulations
also note a UK law granting power to impose fine of £1 million or 50% of deal value, for EU financial
sanctions breaches as of April 2017
now all applies to the UK's own replacement sanctions regime
Morgan Lewis
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