UK extends sanctions against Russia, with focus on aircraft

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 came into force on 30 March.

Changes in this latest version of the UK’s sanctions regulations include the extension of previous restrictions on Crimea to also include the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine. The UK government has also updated its guidance on Russian sanctions in relation to the non-government controlled areas of the Donetsk and Luhansk oblasts, to include annexes setting out the English translations of Ukrainian decrees on the extent of the government-controlled areas of the Donetsk and Luhansk oblasts.

The sanctions also allow for designation by description enabling the UK government to designate persons by description rather than only by name.

The regulations prohibit the direct or indirect technical assistance relating to an aircraft or ship to, or for the benefit of, a person who has been designated for the purposes of this sanctions measure. This prohibition is not contravened where there was no reasonable cause to suspect that the technical assistance was provided to, or for the benefit of, a designated person; or a failure to provide the technical assistance would endanger the lives of persons on board or the safety of the aircraft or ship. Amendments are also made to some of the financial and aircraft measures already introduced in previous regulations.

The UK government will now have the power to issue a licence to authorise a movement of aircraft that would otherwise be prohibited.

Compliance expert Rebecca Devaney of Pinsent Masons said the latest amendments would likely be followed by further sanctions targeting Russia.

“In March the UK government alluded to banning the export of luxury goods, in a similar move to the EU,” Devaney said.

“The EU’s last package of sanctions also targets certain sectors – such as certain iron and steel items that originate in Russia or have been exported from Russia – that the UK has yet to implement sanctions on,” Devaney said.

On 31 March the UK government added a further 12 individuals and two entities (8 page / 161KB PDF) to its designated list of Russian sanctions targets (181 page / 1/34MB PDF).