HMRC (UK) Guidance on New Russian Sanctions

The UK Government is distributing new guidance and instructions to UK-based businesses on compliance, and related obligations with respect to the latest UK sanctions on Russia arising from its war on the Ukraine. Of course, EU and other national legislation and sanction regimes including US sanctions also apply to cross-border businesses.

The HMRC guidelines to UK businesses are as follows:

In light of the events in Ukraine, the Government has imposed new sanctions on Russia.

Checking for updated sanctions is an important part of your customer due diligence. You should also check the Office of Financial Sanctions Implementations (OFSI) list of asset freeze targets for financial sanctions obligations.  

You are legally required to report to OFSI if you know or suspect that a breach of financial sanctions has occurred. This includes if a person you are dealing with, directly or indirectly is a designated person, if you hold any frozen assets, or if knowledge or suspicion of these come to you while conducting your business. You must contact OFSI at the earliest opportunity. 

You should consider any increased risks associated with transactions with Russia at this time. You can find out more information about customer due diligence and risk assessments for businesses like yours on GOV‌‌‌.UK. 

You can find all of HMRC’s anti money laundering guidance and help for businesses on GOV.‌‌‌UK.

HMRC Economic Crime Supervision 

For further information or for any assistance please contact uk@transatlanticlaw.com

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