• Expanded definition of legal services: The amendment redefines what constitutes "legal advisory services" and clarifies exceptions, ensuring legal representation before courts is not restricted.
• Sanctions compliance advice: Legal professionals can now advise on compliance with both UK and non-UK sanctions without breaching sanctions rules.
• Territorial scope: The updated regulations apply across the UK and to UK persons acting abroad. It also ensures that advice on global sanctions is not prohibited.
• Prohibition adjustments: Legal services are prohibited only if they knowingly facilitate actions that would be illegal under UK sanctions, streamlining previous restrictions that created uncertainty.

These amendments follow stakeholder consultations and aim to balance sanctions enforcement with legitimate legal services, especially regarding non-UK sanctions compliance. The goal remains to pressure Russia over its actions in Ukraine, while offering clarity to legal professionals navigating complex global sanctions frameworks.

As a result of this amendment, the Legal Advisory Services General Trade Licence introduced to streamline licencing for certain legal services, was revoked on 6 September 2024 following regulatory amendments. Despite its revocation, the record-keeping requirements under Regulation 76 of the Regulations remain in effect. Providers must retain relevant records for four years and allow inspection by authorised personnel.

As of the date of this blog, there is no corresponding Overseas Territories implementing legislation yet.

For more details, the Notice to Exporters can be found here.

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 are in force as of 6 September 2024 and can be found here.