Parliamentary briefing: Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023

We're briefing parliamentarians about concerns with the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023. The regulations will negatively impact the ability of solicitors to support businesses to comply with the complex web of sanctions legislation and enable them to cut ties effectively with Russia.
The skyline of the Kremlin complex in Moscow, Russia at night
Photograph: Ivanco Vlad

The Ministry of Justice (MoJ) and the Foreign, Commonwealth and Development Office (FCDO) have jointly published new regulations aiming to restrict the provision of legal advisory services.

These regulations were published on 29 June 2023 and came into force on 30 June 2023.

The regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019 by adding measures relating to legal services under the section that deals with professional and business services.

The objective of the regulations is to "prevent UK lawyers form advising Russian companies in certain business deals – thwarting the nation from benefitting economically from the UK's world-leading legal expertise".

Our view

While we fully support the UK government's objective, we have grave concerns the measures will lead to severe unintended consequences for UK law firms and English and Welsh-qualified lawyers.

The regulations as published will likely harm non-Russian businesses more than Russian businesses and are significantly more onerous than both US and EU sanctions.

Clear action from the government is needed to address these concerns.

In the interim, a general licence and additional guidance are urgently required to address the immediate and most severe unintended consequences caused by the regulations.

This will merely act as a short-term sticking plaster while a longer-term solution is agreed.

What we're doing

We're speaking with the MoJ to share our concerns and highlight the need to address the immediate consequences.

We've also been briefing parliamentarians on the need for swift government action.

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