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SI 2023/713: UK Russia sanctions banning non-contentious legal advisory services—scope, key exceptions and compliance risks for law firms

Published on: 04 July 2023

Published by a LexisNexis Practice Compliance expert
Legal News
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Article summary

What are the key provisions of The Russia (Sanctions) (EU Exit) (Amendment) (No 3) Regulations 2023?

The Russia (Sanctions) (EU Exit) (Amendment) (No 3) Regulations 2023, SI 2023/713, revise the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2009/855 (the Russia Regulations). Since September 2022, the UK has sought to sever Russia’s access to a range of professional services, and these latest steps reinforce the sanctions introduced over the past year.

The updated trade measures prohibit any person from directly or indirectly supplying “legal advisory services” to a non-UK person where the advice relates to, or is connected with, conduct that would be prohibited by the Russia Regulations if carried out by a UK person or within the UK. In effect, UK lawyers are barred from advising Russian businesses on certain transactions, such as:

  • commercial agreements between multinational companies
  • international money lending

Non-contentious legal advisory work is captured, including acting for a client, giving advice on or in connection with a commercial transaction, negotiation, or any other engagement with a third party. However, this does not extend to legal representation services linked to proceedings before administrative agencies, courts,...

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