Trading under sanctions with Russia
What import and export restrictions apply due to sanctions for UK companies when trading with Russia.
If you have a question about trading with Ukraine, Russia or Belarus:
The UK government has imposed a range of sanctions measures, including trade and financial sanctions, under The Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Sanctions Regulations”).
The purposes of the Russia Sanctions Regulations are to encourage Russia to cease actions:
- destabilising Ukraine, or
- undermining or threatening the territorial integrity, sovereignty or independence of Ukraine
Find detailed guidance on UK sanctions relating to Russia.
UK businesses are responsible for the decision on whether to trade with Russia.
Business should expect a high unpredictable trading environment as a result of:
- designations of individuals and entities under the Russia Sanctions Regulations by the UK
- retaliatory measures by Russia
The Russia Sanctions Regulations affects several aspects of trade with Russia, including:
- the movement of goods to and from Russia
- the settling of financial transactions with suppliers and customers
- trading with certain businesses and individuals
Businesses should seek legal advice if they plan to continue trading with Russia.
Trade sanctions
The following sections provide an outline of the key restrictions and exemptions, which should be read alongside other guidance on UK sanctions relating to Russia.
Sanctions applicability
UK trade sanctions apply to all persons within the territory and territorial sea of the UK and to all UK persons, wherever they are in the world.
This means:
- all individuals and legal entities who are within, or undertake activities within, the UK’s territory must comply with UK financial sanctions that are in force
- all UK nationals and legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force, irrespective of where their activities take place
Breaches of sanctions measures under the Russia Sanctions Regulations is a criminal offence.
EU sanctions regulations also apply where they relate to trade in goods between the EU and third countries.
The regulation defines “third country” as a country that is not the UK, the Isle of Man or Russia.
All UK sanctions apply in Northern Ireland. EU sanctions regulations also apply where they relate to trade in goods between the EU and third countries as stipulated by Annex 2 of the Northern Ireland Protocol, in which traders in Northern Ireland must adhere to:
“Restrictive measures in force based on Article 215 TFEU, insofar as they relate to trade in goods between the Union and third countries.”
Trade sanctions in the Russia Sanctions Regulations
Trade sanctions are set out in Part 5 of The Russia (Sanctions) (EU Exit) Regulations 2019 (“the regulations”).
Check the regulations for information on prohibited commodities, products and services.
The regulations set out the restrictions currently imposed, while the schedules provide definitions of the prohibited goods.
Example: If Chapter 5 of Part 5 sets out the prohibitions for the exporting of infrastructure-related goods to non-government controlled Ukrainian territory, you will need to refer to its relevant schedule (Part 3, Schedule 3) for the definitions of the goods.
The Regulations also cover a range of other items such as transfer of technology, providing technical assistance, brokering services and financial services.
For further guidance, check the statutory guidance on sanctions against Russia.
Definitions and commodity codes
The Russia Sanctions Regulations impose trade prohibitions on (with links to definitions and HS codes where available):
- military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008 on legislation.gov.uk)
- anything which falls within Chapter 93 of the Goods Classification Table, other than military goods
- provision of technical assistance, armed personnel, financial services or funds, or associated brokering services where such provision enables or facilitates the conduct of certain military activities
- defence and security goods and defence and security technology (as specified in Schedule 3C to the Regulations on legislation.gov.uk)
- dual-use goods and technology (as specified in Annex I to Council Regulation 428/2009 on legislation.gov.uk, as retained by the European Union (Withdrawal) Act 2018 (‘the Dual-Use Regulation’))
- special materials and related equipment and materials processing (as specified in Parts 1A and 1B of Schedule 2A to the regulations on legislation.gov.uk)
- critical-industry goods and technology (as specified in Schedule 2A to the Regulations on legislation.gov.uk)
- quantum computing and advanced materials goods and technology (as specified in Schedule 2E to the Regulations on legislation.gov.uk)
- aviation and space goods and technology (as specified in Schedule 2C to the Regulations on legislation.gov.uk)
- jet fuel and fuel additives (as specified in Part 8 of Schedule 2A to the Regulations on legislation.gov.uk)
- maritime goods and maritime technology (defined by reference to Chapter 4 (Navigation Equipment) and Chapter 5 (Radio-Communication Equipment) of Annex 1 of Merchant Shipping Notice 1874(a))
- infrastructure-related goods (as specified in Part 3 of Schedule 3 to the Regulations on legislation.gov.uk)
- energy-related goods (as specified in Part 2 of Schedule 3 to the Regulations on legislation.gov.uk) and energy-related services
- oil refining goods and technology (as specified in Schedule 2D to the Regulations on legislation.gov.uk)
- luxury goods (as specified in Schedule 3A to the Regulations on legislation.gov.uk)
- G7 dependency and further goods (as specified in Schedule 3E to the Regulations on legislation.gov.uk)
- goods originating in non-government controlled Ukrainian territory
- iron and steel products (as specified in Schedule 3B to the Regulations on legislation.gov.uk) and associated ancillary services
- oil and oil products (as specified in Schedule 3F to the Regulations on legislation.gov.uk)
- coal and coal products (as specified in Schedule 3H to the Regulations on legislation.gov.uk)
- gold and products related to gold (as specified in Schedule 3G to the Regulations on legislation.gov.uk)
- banknotes denominated in sterling and any official currency of the EU
- goods which generate significant revenues for Russia (as specified in Schedule 3D to the Regulations on legislation.gov.uk)
- provision of technical assistance, armed personnel, financial services or funds, or associated brokering services where such provision enables or facilitates the conduct of certain military activities
- services relating to a relevant infrastructure sector in non-government controlled Ukrainian territory
- services relating to tourism in non-government controlled Ukrainian territory
- internet services
- professional and business services (as specified in Chapter 6B to the Regulations on legislation.gov.uk)
Trading via a third country
Current prohibitions apply to:
- exports of certain goods or technology to Russia or to non-government controlled Ukrainian territory
- exports of certain goods or technology that are for use in Russia or to non-government controlled Ukrainian territory
- supply and delivery of certain goods or technology from a third country to Russia or to non-government controlled Ukrainian territory or from Russia to a third country
- transfer of certain technology to Russia or a person connected with Russia or transfer from Russia to persons or place outside the UK
- making certain goods or technology available for use in Russia or to a person connected with Russia or use in non-government controlled Ukrainian territory or to a person connected with non-government controlled Ukrainian territory
- acquiring certain goods or technology which originate in Russia or which are located in Russia or from a person connected with Russia
- providing technical assistance, brokering services or financial services and funds related to certain specified goods or technology for use in Russia, or person connected with Russia, or for use in non-government controlled Ukrainian territory or to persons connected with non-government controlled Ukrainian territory
- providing certain services such as services insurance or reinsurance services for specified goods or technology or certain specified services necessary for a “relevant oil exploration or production project” in Russia
- providing certain services such as services relating to certain specified infrastructure sectors or services relating to tourism in non-government controlled Ukrainian territory
- imports that are consigned from Russia
- imports that originated in Russia
For exports, this means that the prohibition may apply even if the immediate destination is not Russia.
There are import prohibitions on certain goods that have originated from Russia and all goods from non-government controlled Ukrainian territory. These prohibitions are applicable even if the immediate place the goods were shipped from was not from Russia or non-government controlled Ukrainian territory.
See “Import Restrictions” below for more information.
For both exports and imports, the same applies to goods or services to and originating from Ukrainian territory that is not controlled by Ukraine’s government.
‘Non-government controlled Ukrainian territory’ is defined in the Regulations as ‘Crimea and non-government controlled areas of the Donetsk and Luhansk oblasts’.
Professional and business services to a person connected with Russia
Regulation 54C prohibits a legal or natural person from providing, directly or indirectly, accounting, business and management consulting, and public relations services to a ‘person connected with Russia’. These services (‘covered services’) are defined in regulation 54B, while a ‘person connected with Russia’ is defined in regulation 21. The prohibitions in regulation 54C are subject to exceptions and licences.
Professionals and businesses connected with Russia are advised to read the guidance on Russia sanctions.
Exceptions to trade sanctions
The Regulations set out exceptions to some of the trade restrictions which apply within certain defined circumstances. These are set out in Part 7 of the Regulations. An exception applies automatically, and does not require you to obtain a licence issued in accordance with the Regulations.
Licences may also be issued for certain trade activities that would otherwise be prohibited by the Regulations. Circumstances for which a licence may be granted for certain trade activities are listed in Section 3.3 of the Russia sanctions guidance.
Generally, there may be a case for licence applications to be granted under ‘prior obligation’ grounds if goods or services have already been provided.
Under prior obligation grounds, the obligation must:
- have arisen before the designation date
- not relate to trade provisions (specified in the Regulations)
- not result in funds or economic resources being made available (directly or indirectly) to the designated person
A licence may also be granted for goods, technology or services required for the delivery of humanitarian assistance activity.
Apply for trade sanctions licences through SPIRE, the online export licensing system.
Apply for import licenses through DIT’s Import Case Management System.
You must provide with your application all the relevant documentation and information about the activities you want to carry out.
Contact tradesanctions@trade.gov.uk if you have questions on trade sanctions licensing.
Export control licensing
Exporters should check the ultimate end-use of goods. You should apply for a licence via SPIRE or contact the Export Control Joint Unit (ECJU) if you know or think the items may be used in Russia or non-government controlled Ukrainian territory.
Refer and subscribe to notices to exporters for the latest export controls relating to Russia and non-government controlled Ukrainian territory.
Go to regulation 21 of the Regulations on legislation.gov.uk for definitions on controlled goods.
Import control licensing
Importers should check the original place goods were consigned from. You should apply for a licence or contact the Import Licensing Branch if you think the items may have originated in or have been consigned from Russia or non-government controlled Ukrainian territory.
Refer and subscribe to the notice to importers for the latest import controls relating to Russia, which should be read alongside the statutory guidance.
Where traders are looking to import prohibited goods, and where an exception does not apply, you will need to make a licence application through ILB’s Import Case Management System (ICMS). You will need to register on ICMS, if you do not already have an account, and submit an importer access request.
Please then contact importcontrols@trade.gov.uk with details of your proposed import for further instruction. We will then consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.
For further instructions, please contact importcontrols@trade.gov.uk in the first instance, with details of your proposed import.
Tariffs on Russian and Belarusian goods
The UK has increased import tariffs by 35% percent on a number of goods from Russia and Belarus. The 35% additional duty will apply on top of existing tariff measures. The tariff increase applies to goods originating in Russia and Belarus.
Products affected are those that are important to the Russian economy and include iconic Russian goods such as vodka and fur skin clothing.
The tariffs on Belarus are in line with the evolving sanctions positions, and will prevent the circumvention of Russian-origin goods.
The government will continue to keep these tariffs under review as the situation in Ukraine develops.
See the Reference Documents for Customs (Additional Duty) (Russia and Belarus) Regulations 2022 to find out what additional duties apply on certain goods originating from Russia and Belarus. The document contains commodities codes.
Rules of origin
The origin of goods is based on where they have been grown, produced, or manufactured, and may not be the country where they have been shipped or brought from.
Use the guidance to determine the country of origin of goods.
Goods originating in other countries and then shipped through Russia and Belarus will not receive a higher tariff.
Financial sanctions
The regulations impose financial sanctions on designated persons.
Financial sanctions are specific to each designated person. However, in general, they comprehend a prohibition on:
- dealing with funds or economic resources (non-monetary assets, such as property or vehicles) owned, held or controlled by a designated person
- making funds and economic resources available to or for the benefit of a designated person, either directly or indirectly
Applicability
You should ensure that you consider the above financial sanctions. This might impact your ability to get paid.
UK financial sanctions apply to all persons within the territory and territorial sea of the UK and to all UK persons, wherever they are in the world.
This means:
- all individuals and legal entities who are within, or undertake activities within, the UK’s territory must comply with UK financial sanctions that are in force
- all UK nationals and legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force, irrespective of where their activities take place
Exceptions to financial sanctions
There are certain exceptions that apply to financial payments under the Russia (Sanctions) (EU Exit) Regulations 2019. This are listed in the regulations and also detailed in OFSI’s Russia guidance (PDF, 547KB).
OFSI has issued several general licences under the Russia regulations that allow multiple parties to undertake an activity that would otherwise be prohibited.
For other activities, you may be able to apply for a specific licence from OFSI under certain conditions. Please note that you may need a licence from ECJU as well as a licence from OFSI in some circumstances.
Getting paid
You will need to check first whether your Russian agents, partners or suppliers are subject to current financial sanctions. Even if they are not, current financial sanctions could impact your ability to make or receive payment via a Russian bank should they be subject to any financial sanctions.
As a part of your financial sanctions due diligence when importing or exporting, you should consider:
- who and where the goods or services are coming from or going to (it is possible that financial sanctions such as an asset freeze may apply to one of the parties or to the financial aspects of the trade)
- who is shipping the goods, and whether they are being shipped on a sanctioned vessel
- whether a designated person is based in a different country to the one you are operating in, but is still subject to financial sanctions in that country
You should also consider if individuals or organisations are ‘owned’ or ‘controlled’ either directly or indirectly by designated persons.
The financial measures extend to entities, owned or controlled by designated persons within the meaning of regulation 7 of the Russia Sanctions Regulation unless specific activities are covered by an exception or General Licence; or if a licence is granted under the usual process.
You can use the OFSI Consolidated List Search tool to search for Russian banks to see if they are affected by sanctions. Some Russian companies are also listed on a separate list of financial and investment restrictions. This companies have restrictions on specified activities such as dealing with transferable securities or money-market instruments and granting or entering into arrangements to grant loans or credit.
Transport sanctions
The regulations impose transport prohibitions relating to aircraft and shipping.
Go to the relevant sections of Russia sanctions: guidance for more detailed information including exceptions. A brief outline of the regulations can be found below.
Shipping sanctions
The following provides an outline of the shipping sanctions in the Russia Sanctions Regulations.
The sanctions:
- prohibit Russian ships, and other ships specified by the Secretary of State, from entering UK ports
- confer powers on the Secretary of State and harbour authorities to issue port barring directions to the master or pilot of a specified ship
- provide the Secretary of State with a power to control the movement of Russian ships or specified ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are
- prohibit the registration of ships owned, controlled, chartered or operated by designated persons or persons connected with Russia on the UK Ship Register and confer powers on the Secretary of State to direct the UK Ship Registrar to terminate the registration of such ships
Aircraft sanctions
The Russia Sanctions Regulations, in outline, prohibit a Russian aircraft which is owned, chartered or operated by persons connected with Russia or designated persons from overflying the UK or landing in the UK.
Sanctions relating to Belarus
The UK has designated various individuals and entities under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, which can be found on legislation.gov.uk.
Check the Republic of Belarus sanctions: guidance for detailed information in relation to the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019.
You can use the OFSI Consolidated List Search tool to search for individuals or entities to see if they are designated under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019.
Last updated 2 December 2022 + show all updates
-
This page has been updated to add guidance on the requirement of a licence for Professional and Business Services to a person connected with Russia, a link to new page has been added in to the text.
-
Added links to the relevant schedules following the passing of amendments 11-14. Deletion of 'Additional trade sanctions' section. Addition of 'Import control licensing' section.
-
Additional schedules and definitions added to the export and import ban sections following the passing of Amendment No. 10 of the Russia (Sanctions) (EU Exit) Regulations 2019.
-
First published.