The UK is no longer implementing EU sanctions, and UK sanctions are now officially in force.
Some key points to be aware of:
- Consolidated list of UK sanctions targets under the UK Sanctions Act - OFSI has published a "bridging document" to help UK persons screen against this list. While EU targets have been brought across to the UK consolidated list at the end of the transition period, some of the identifying information and/or format of the information for screening may differ.
- Sanctions programmes implemented through specific UK legislation - may contain some different licenses and exemptions from the EU equivalents. See our previous post here.
- Licensing - new application form must now be used.
- General License under the Russia sanctions - using its new general license power, OFSI issued General License INT/2020/059.
This general license makes explicit that under UK law persons may make payments to the Crimean Sea Ports for services at Kerch Fishery Port, Yalta Commercial Port and Evpatoria Commercial Port, and for services provided by Gosgidrografiya and by Port-Terminal branches of the Crimean Sea Ports.
The transition period has ended. The UK is no longer implementing EU sanctions. All sanctions regimes will now be implemented through UK regulations.