The UK’s sanctions against Russia now covers professional services. Read about the impact to your company – and how to navigate compliance.
The UK introduced new sanctions on professional services against Russia, with legislation and guidance released on July 22 . As it stands, UK legislation is out of step with comparable EU and US sanctions, especially related to subsidiaries of UK companies.
The CBI is engaging with businesses and government on the impact of these new sanctions – click through the topics to find expert insight.
What is the difference between an “exemption” and a “license”?
An exemption allows acts or work that would be otherwise prohibited by sanctions. They will be specifically outlined in legislation and apply automatically where the specified criteria is met. They do not require a written notification or application.
A license is written authorisation, granted by a relevant governmental body. Licenses permit specific acts and work that would be otherwise prohibited by sanctions. Government may grant licenses where the applicable legislation provides grounds enabling it to do so and those grounds are met.
What exemptions are in the recent professional services sanctions?
The legislation grants exemptions in the following cases:
- in relation to the discharge or compliance with UK statutory or regulatory obligations (other than obligations arising under contract)
- in relation to contractual obligations that arise under a contract concluded before 20 July 2022, or an ancillary contract necessary for the satisfaction of such a contract.
For the exemption to apply to contracts concluded before 20 July:
- the act must be carried out before 21 August 2022 (the end of the period of one month beginning with the day on which the regulation comes into force)
- the person providing the accounting services must notify the Secretary of State no later than 10 working days before the day on which the act is carried out;
In addition to the above, th
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