On 29 June 2023, the UK government introduced a new restriction (under the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023), prohibiting the provision of legal advisory services by UK lawyers to non-UK persons where such advice is connected with an activity that would breach the sectoral (trade) and asset freeze (finance) restrictions on Russia currently existing under the UK sanctions regime.

Main elements:

• The provision (regulation 54D) came into force on 30 June 2023.
• The provision may restrict UK lawyers from providing advice even where the underlying activity has no UK nexus.
• In broad terms the underlying activities focussed on will typically comprise services that may not be provided to ‘persons connected with Russia’.
• The provisions extend and expand on the restrictions on professional services more generally, such as those on the provision of trustee services (regulation 18C) and accounting, auditing and other professional services (regulation 54C).
• As at the date of this blog, regulation 54D has not been tailored to the UK Overseas Territories though changes to the relevant Order in Council are expected soon.

The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 can be found here.

Official press release can be accessed here.