US Sectoral Sanctions

UK Sanctions (post-Brexit) UK left the EU on 31 Jan. 2020, but transition period to (at least) 31 Dec. 2020 The EU sanctions (see slides 70-82) continue to apply during this period - - But the UK has 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 76-77) This is the Russia (Sanctions) (EU Exit) Regulations 2019; enacted in April 2019 and the substantive provisions came into force on 31 Jan. 2020 The Regulations revoke and replace the EU Regs (and the UK laws which give effect to them) as of transition period end, and allow the government then 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 Morgan Lewis 83 83

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