Notice

NTI 2953: Russia import sanctions

Updated 18 December 2024

This notice provides an overview of the import prohibitions in force on certain goods imported into the UK, including Northern Ireland, that have originated in or have been consigned from the territory covered by what is now the Russian Federation and non-government controlled Ukrainian territory.^{[footnote 1]} It also sets out the licensing process for traders looking to import goods subject to prohibitions.

It should be read alongside the statutory guidance published by the Foreign, Commonwealth and Development Office (FCDO). This notice has no legal effect, and in case of conflict with the statutory guidance published by the FCDO, the statutory guidance will prevail.

Import prohibitions

Read guidance on third country processed iron and steel sanctions.

Read guidance on third country processed Russian diamonds measures.

The Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Sanctions Regulations) replaced, with substantially the same effect, relevant existing EU legislation. Corresponding prohibitions in this sanctions regime are aimed at encouraging Russia to cease actions destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.

On 30 March 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 amended the Russia Sanctions Regulations. This amendment extends the existing import sanctions measures in relation to Crimea and the city of Sevastopol to the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine.

On 14 April 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 amended the Russia Sanctions Regulations. This amendment extends the existing import sanctions measures by prohibiting the import of certain iron and steel products. It also prohibits the acquisition, supply and delivery, directly or indirectly, of certain iron and steel products.

On 23 June 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 amended the Russia Sanctions Regulations. This amendment has now been replaced by the Russia (Sanctions) (EU Exit) (Amendment) (No. 11) 2022. This amendment extends the existing import sanctions measures. It prohibits the import of certain revenue generating goods as well as the acquisition, supply and delivery, directly or indirectly, of revenue generating goods. It also prohibits the provision of technical assistance, financial services and funds and brokering services relating to the revenue generating goods. The new measures also prohibit the provision of technical assistance, financial services and funds and brokering services relating to certain iron and steel products. The full list of revenue generating goods can be found in (following the 21 April 2023 Amendment, detailed below) Schedule 3DA to the Russian Sanctions Regulations and Schedule 3D to the Russia Sanctions Regulations.

On 21 July 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 amended the Russia Sanctions Regulations. This amendment prohibits the import of oil and oil products, coal and coal products and gold as well as the acquisition, supply and delivery, directly or indirectly of these goods. It also prohibits the provision of technical assistance, financial services and funds and brokering services relating to these goods. The prohibition on the import of gold entered into force on 21 July, the prohibition on the import of coal took effect on 10 August 2022 and the prohibition on the import of oil took effect on 5 December 2022.

On 29 October 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 amended the Russia Sanctions Regulations. This amendment prohibits the import and acquisition of liquefied natural gas and gold jewellery, as well as extending the existing prohibitions on the import of gold to include that of gold processed in a third country. It also expands the existing list of revenue generating goods to goods falling under commodity codes 2208 and 2303. The new measures also prohibit the provision of technical assistance, financial services and funds and brokering services relating to these goods. These measures took effect from 29 October 2022, with the exception to those related to liquefied natural gas, which took effect on 1 January 2023.

On 21 April 2023, the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 amended the Russia Sanctions Regulations. This amendment extends the existing import sanctions measures by prohibiting: the import, acquisition and supply and delivery, directly or indirectly, of further iron and steel products; the import of certain iron and steel products processed in a third country; the import and acquisition of further revenue generating goods; and the supply and delivery to a third country of certain revenue generating goods. The new measures also prohibit the provision of technical assistance, financial services and funds and brokering services relating to these goods. These measures took effect on 21 April 2023, with the exception of those relating to iron and steel products processed in a third country, which took effect on 30 September 2023.

On 14 December 2023, the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 amended the Russia Sanctions Regulations. This amendment prohibits the import of metals as well as the acquisition, supply and delivery, directly or indirectly of these goods. These measures took effect on 15 December 2023.

On 14 December 2023, the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023 amended the Russia Sanctions Regulations. This amendment prohibits the import of diamonds and diamond jewellery as well as the acquisition, supply and delivery, directly or indirectly of these goods. These measures also prohibit the provision of technical assistance, financial services and funds, and brokering services relating to these goods. These measures are to take effect on 1 January 2024.

On 1 March 2024, the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2024 amended the Russia Sanctions Regulations. This amendment extends the existing import sanctions measures by prohibiting the import of certain diamonds processed in a third country. The new measures also prohibit the provision of technical assistance, financial services and funds and brokering services relating to these goods. These measures took effect on 1 March 2024.

The import prohibitions specified in the Russia Sanctions Regulations prohibit the import, acquisition, and supply and delivery of certain products, as well as the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition or supply and delivery of those products.

These cover goods that are consigned from, are located in or originate in Russia, as applicable under the relevant regulations. This means that even if the initial point from which the goods were shipped was not Russia, the prohibition may still apply.

The prohibitions may apply even if the products are not of Russian origin and even if transiting through Russian territory is part of a complete journey where the start and end point is not Russia.

For example, the transport of iron and steel products from or through any place in Russia to a third country, whether or not the starting point of the journey was in Russia, will be subject to the prohibition in Regulation 46F.

The import prohibitions specified in the Russia Sanctions Regulations are set out below.

Regulation 23

The import of arms and related materiel is prohibited.

This includes all military goods, and anything which falls within chapter 93 of the Goods Classification table, other than military goods.

These goods are prohibited where they are consigned from or originated from the territory which is comprised within what is now the Russian Federation.

This means that the prohibition extends to goods originating in those parts of the Soviet Union and Imperial Russia that are now comprised within the Russian Federation. The prohibition applies even if those goods are not consigned from what is now the Russian Federation (for example, arms manufactured near Moscow in 1945 but imported from the US).

Regulation 46C to 46I

Regulation 46C defines iron and steel products as anything specified in Schedule 3B to the Russia Sanctions Regulations.

Regulations 46D, 46E and 46F prohibit the import, acquisition, supply and delivery of iron and steel products. These cover goods that are consigned from, located in or originate in Russia, as applicable under the relevant regulation. This means that even if the initial point from which the goods were shipped was not Russia, the prohibition may still apply.

Regulations 46G, 46H and 46I prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition or supply and delivery of iron and steel products.

Regulation 46IA to 46IE

Regulation 46IA defines relevant processed iron and steel products as anything specified in Part 1, 2 or 3 of Schedule 3B to the Russia Sanctions Regulations that has been processed in a third country, incorporating one or more iron or steel products originating in Russia. This covers Russian-originating products that have been altered, transformed in any way or subjected to any other type of operation or process in a third country.

Regulation 46IB prohibits the import of relevant processed iron and steel products.

Regulations 46IC, 46ID and 46IE prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import of these products.

See guidance on third country processed iron and steel sanctions.

Regulation 46IF to 46II

Regulation 46IF defines metals as anything specified in Schedule 3BA to the Russia Sanctions Regulations.

Regulations 46IG, 46IH and 46II prohibit the import, acquisition, supply and delivery of metals. These cover goods that are consigned from, located in or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

Regulation 46R to 46X

Regulation 46R defines Schedule 3D revenue generating goods as anything specified in Schedule 3D to the Russia Sanctions Regulations.

Regulations 46S and 46T prohibit the import and acquisition of Schedule 3D revenue generating goods. These cover goods that are consigned from, located in, or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

Regulations 46V, 46W and 46X prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import or acquisition of revenue generating goods.

Regulation 46XA to 46XG

Regulation 46XA defines anything specified in Schedule 3DA to the Russia Sanctions Regulations as Schedule 3DA revenue generating goods.

Regulations 46XB and 46XC prohibit the import and acquisition of Schedule 3DA revenue generating goods. These cover goods that are consigned from, located in, or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply. Regulation 46XD prohibits the supply and delivery, directly or indirectly, of Schedule 3DA revenue generating goods originating or located in Russia to a third country.

Regulations 46XE, 46XF and 46XG prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition or supply and delivery of Schedule 3DA revenue generating goods originating or located in Russia to a third country.

Regulation 46Z3 to 46Z9

Oil and oil products are defined as anything specified in Schedule 3F to the Russia Sanctions Regulations.

Regulations 46Z4 and 46Z5, prohibit the import or acquisition of oil and oil products. These cover goods that are consigned from, located in or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply. Regulation 60H provides an exception for some non-oil and oil products which are only being loaded in, departing or transiting through Russia, see below.

Regulations 46Z7, 46Z8 and 46Z9 prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import or acquisition of oil and oil products.

See guidance on the UK ban on Russian oil and oil products.

Regulation 46Z10 to 46Z16

Gold is defined as the gold and products related to gold specified in Part 2 of Schedule 3G to the Russia Sanctions Regulations. These prohibitions only apply to gold that has been exported from Russia on or after 21 July 2022.

Regulations 46Z11 and 46Z12 prohibit the import and acquisition of gold. These cover goods that are consigned from, located in or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

Regulations 46Z14, 46Z15 and 46Z16 prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import or acquisition of gold.

Regulation 46Z16A to 46Z16I

Gold Jewellery is defined as anything specified in Part 3 of Schedule 3G to the Russia Sanctions Regulations. These prohibitions only apply to gold jewellery that has been exported from Russia on or after 29 October 2022.

Processed gold is defined as anything specified in Part 2 of Schedule 3G to the Russia Sanctions Regulations, that has been processed in a third country and incorporates gold that, on or after 21 July 2022, originated in and was exported from Russia. The prohibition came into effect on 29 October 2022.

Regulations 46Z16B, 46Z16C and 46Z16D cover the relevant prohibitions on the import and acquisition of these products. These cover goods that originate in, are located in, or have been exported from Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

Regulations 46Z16E, 46Z16F, 46Z16G, 46Z16H and 46Z16I prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import of gold jewellery and processed gold, and the acquisition of gold jewellery.

Regulation 46Z16J to 46Z16P

Regulation 46Z16J defines diamonds as anything specified in Part 2 of Schedule 3GA, and diamond jewellery as anything specified in Part 3 of Schedule 3GA to the Russia Sanctions Regulations.

Regulations 46Z16K, 46Z16L and 46Z16M prohibit the import, acquisition, supply and delivery of diamonds and diamond jewellery. These cover goods that are consigned from, located in or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

Regulations 46Z16N, 46Z16O and 46Z16P prohibit the provision of technical assistance, financial services and funds, and brokering services relating to the import, acquisition or supply and delivery of diamonds and diamond jewellery.

Regulation 46Z16Q to 46Z16U 

Regulation 46Z16Q defines relevant processed diamonds as any diamond specified within that regulation that has been processed in a third country and originated in Russia. This covers Russian-originating products that have been altered, transformed in any way or subjected to any other type of operation or process in a third country.

Regulation 46Z16R prohibits the import of relevant processed diamonds.

Regulations 46Z16S, 46Z16T and 46Z16U prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import of these products.

See guidance on third country processed Russian diamonds measures.

Regulation 46Z17 to 46Z23

Coal and coal products are defined as anything specified in Schedule 3H to the Russia Sanctions Regulations.

Regulations 46Z18 and 46Z19 prohibit the import and acquisition of coal and coal products. These cover goods that are consigned from, located in or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

Regulations 46Z21, 46Z22 and 46Z23 prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import or acquisition of coal and coal products.

Regulation 46Z24 to 46Z29

Liquefied natural gas is defined as liquefied natural gas falling within commodity code 2711 1100 00.

Regulations 46Z25 and 46Z26 prohibit the import and acquisition of liquefied natural gas. These cover goods that are consigned from, are located in, or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply.

Regulations 46Z27, 46Z28 and 46Z29 prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import and acquisition of liquefied natural gas.

Regulation 47

Prohibits the import of any goods originating in non-government controlled Ukrainian territory into the UK.

This means that even if the immediate place the goods were shipped from was not non-government controlled Ukrainian territory, the prohibition may still apply.

Under regulation 52(3), the direct or indirect provision of financial services or funds in pursuance or in connection with the import into the UK of goods originating in non-government controlled Ukrainian territory is prohibited.

Exceptions

Part 7 of the Russia Sanctions Regulations also sets out exceptions to some of the import prohibitions which apply within certain defined circumstances. An exception applies automatically and does not require you to obtain a licence issued in accordance with the regulations.

The exceptions specified in the Russia Sanctions Regulations include:

Regulation 60G

Regulation 60G provides an exception in relation to goods consigned from Russia before the prohibitions entered into force. For goods falling under Part 3 of Schedule 3B, Part 3 of Schedule 3D and Part 3 of Schedule 3DA, this is provided that the goods are consigned from Russia before 21 April 2023 and imported into the UK before 21 May 2023. For goods falling under Part 4 of Schedule 3B and Schedule 3BA, save for the commodity codes listed in Regulation 60G(1G), this is provided that the goods are consigned from Russia before 15 December 2023 and imported into the UK before 14 January 2024.

Regulation 60GA

Regulation 60GA provides an exception in relation to the acquisition, technical assistance, financial services and brokering services of iron and steel products, and acquisition of metals, in relation to such goods located in the United Kingdom or the Isle of Man, having been lawfully imported there.

Regulation 60GAA

Regulation 60GAA provides an exception in relation to:

• the import of iron and steel products and associated ancillary services
• the import of relevant processed iron or steel products and associated ancillary services
• the import of metals

This is provided that these goods were exported from Russia before the applicable prohibition entered into force and are not to be released into free circulation in the United Kingdom.

Regulation 60GAB

Regulation 60GAB provides an exception in relation to the provision of ancillary services related to the acquisition of iron or steel products, provided these goods were exported from Russia before the applicable prohibition came into force.

Regulation 60GB

Regulation 60GB provides an exception in relation to the acquisition, technical assistance, financial services and brokering services of Schedule 3DA revenue generating goods:

• where those goods are located in the United Kingdom or the Isle of Man, having been lawfully imported there

• where a United Kingdom national located in Russia engages in these activities in relation to goods which are located in Russia and are for personal use of that United Kingdom national or their immediate family members

Regulation 60GC

Regulation 60GC provides an exception in relation to the acquisition, technical assistance, financial services and funds, and brokering services related to diamonds and diamond jewellery, where those goods are located in the United Kingdom or the Isle of Man, having been lawfully imported there.

Regulation 60H

The prohibitions on oil and oil products are not contravened if the goods (all conditions must apply):

• originate in a country that is not Russia
• are not owned by a person connected with Russia
• are only being loaded in, departing or transiting through Russia

Regulation 60ZA

The import of prohibited goods from the non-government controlled areas of Donetsk and Luhansk oblasts and the related provision of financial services and funds (prohibitions in regulations 47 and 52(3)) are permitted if related to an obligation arising from a contract concluded before 23 February 2022.

For this exception to apply, the action carried out under these contracts, or ancillary contracts necessary for their execution, must be carried out by 24 August 2022. The Secretary of State for the Department for Business and Trade (DBT) should also have been informed at least 10 working days in advance of this exception being used.

Regulation 62

Provides for an exception in relation to prohibitions relating to the import of goods originating in non-government controlled Ukrainian territory (regulation 47), where those goods have been satisfactorily certified by or on behalf of the Government of Ukraine as originating in Ukraine.

Regulation 63

The prohibitions mentioned above do not apply if the act is one which a ‘responsible officer’ (for example, a government or agency official) has determined would be in the interests of national security, or the prevention or detection of serious crime in the United Kingdom or elsewhere.

Trade sanctions licences

A licence is a written authorisation that permits an otherwise prohibited activity. See guidance on how to apply for a trade sanctions licence for information on the types of trade sanctions licences available.

Please note, it is for the trader to carry out their own due diligence, determining any relevant controls or actions they may need to take, including obtaining the correct licence. If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.

Import licences

DBT’s Import Controls and Sanctions Team is responsible for administering the licensing provisions on behalf of the Secretary of State for all trade sanctions licence applications from importers.

Where traders are looking to import prohibited goods, and where an exception does not apply, you will need to apply for an import licence. If you do not already have an account, you will need to create a GOV.UK One Login account. Once logged in, please submit an importer access request and, under ‘What are you importing and where are you importing it from’, please also state that you wish to apply for a Sanctions and Adhoc Licence, include your 12-digit EORI number and the relevant commodity codes associated with your import.

Once the importer access request has been approved, you will be able to submit your licence application. We will then consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.

For certain prohibitions there are some specific activities that we consider likely to be consistent with the aims of the sanctions regime. These are set out below and in further detail in the statutory guidance. If you think that your proposed activity falls within one of these specific descriptions, you should make this clear and explain why you believe this to be the case in your application for a licence. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.

For further instructions, contact [email protected] in the first instance, with details of your proposed import.

You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted. If you are unclear on any aspect of the regulations and in what cases a trade sanctions licence is required, we recommend that you seek independent legal advice in the first instance.

Licences granted will not permit activity in respect of Northern Ireland that is not consistent with EU sanctions regulations as they apply via the Windsor Framework.^{[footnote 2]} You will also have to comply with any other licensing requirements under UK import control legislation as applicable.

Consideration for licensing

Military goods and technology

Licences may be issued for the import of military goods or technology subject to one or more of the conditions being met.

The conditions are:

• a licence may be granted for the import of military goods if the import is necessary for the maintenance and safety of existing capability within the UK
• a licence may be granted for the import of: Hydrazine (CAS 302-01-2) in concentrations of 70% or more, or Monomethyl hydrazine (CAS 60-34-4) if it is for:
  • use in launchers operated by UK service providers
  • use in launches by the European Space Agency or UK space programmes
  • or the fuelling of satellites by UK satellites manufacturers
• a licence may be granted for the import of unsymmetrical dimethyl hydrazine (CAS 57-14-7) if it is for:
  • use in launchers operated by UK launch service providers
  • use in launches by the European Space Agency or UK space programmes
  • or the fuelling of satellites by UK satellites manufacturers
• a licence may be granted for the import of hydrazine (CAS 302-01-2) in concentrations of 70% or more for the tests and flight of ExoMars descent module and for the flight of ExoMars carrier module in the framework of the ExoMars 2020 mission

Iron and steel

A licence may be issued for the import of certain iron and steel products and the acquisition, supply or delivery, directly or indirectly, of:

• certain iron and steel products as specified in Schedule 3B to the Russia Sanctions Regulations, if it relates to the execution of obligations arising from contracts concluded before 14 April 2022
• certain iron and steel products as specified in Part 3 of Schedule 3B to the Russia Sanctions Regulations, if it relates to the execution of obligations arising from contracts concluded before 21 April 2023
• certain iron and steel products as specified in Part 4 of Schedule 3B to the Russia Sanctions Regulations, if it relates to the execution of obligations arising from contracts concluded before 15 December 2023
• certain Russian iron and steel products processed in a third country as specified in Parts 1, 2 and 3 of Schedule 3B to the Russia Sanctions Regulations, if it relates to the execution of obligations arising from contracts concluded before 21 April 2023

The General Trade Licence for sanctioned iron and steel permits the import into the UK of certain prohibited goods that:

• are used as reuseable packaging
• were manufactured or produced before 23 June 2023
• were previously in free circulation in the United Kingdom

Other conditions apply. For more information, please refer to guidance on third country processed iron and steel measures

Metals

A licence may be issued for the import of metals and the acquisition, supply or delivery, directly or indirectly, of metals if it relates to the execution of obligations arising from contracts concluded before 15 December 2023.

A Trade Licence is available for the acquisition of Russian metals, in relation to their trade on global metal exchanges, subject to the conditions set out in the Licence.

Revenue generating goods

A licence may be issued for the import and acquisition, directly or indirectly, into the UK of Schedule 3D and Schedule 3DA revenue generating goods if it relates to:

• goods falling under Part 2 of Schedule 3D and Part 2 of Schedule 3DA, the execution of contracts concluded before 23 June 2022, or before 29 October 2022 for codes 2208 and 2303
• goods falling under Part 3 of Schedule 3D and Part 3 of Schedule 3DA, the execution of contracts concluded before 21 April 2023
• ancillary contracts necessary for the execution of such a contract

A licence may be issued for the provision of technical assistance, brokering services, financial services or funds for the import or acquisition, revenue generating goods into the UK if it relates to at least one of the following:

• for goods falling under Part 2 of Schedule 3D and Part 2 of Schedule 3DA, the execution of contracts concluded before 23 June 2022, or before 29 October 2022 for codes 2208 and 2303
• for goods falling under Part 3 of Schedule 3D and Part 3 of Schedule 3DA, the execution of contracts concluded before 21 April 2023.
• ancillary contracts necessary for the execution of such a contract

Silver

There are additional licensing considerations that apply to the import of silver, listed under Schedule 3DA the revenue generating goods list.

A licence may be issued for the import of silver and for the acquisition, directly or indirectly, into the UK of silver, where it can be demonstrated that the silver was exported from Russia before 23 June 2022.

A licence may be issued for the provision of technical assistance, brokering services, financial services and funds relating to silver that was exported from Russia before 23 June 2022.

Diamonds and diamond jewellery

A licence may be issued for the import, acquisition, or supply and delivery, directly or indirectly, of diamonds and diamond jewellery if it relates to:

• the execution of obligations arising from contracts concluded before 15 December 2023

A licence may be issued for the provision of technical assistance, financial services and funds, or brokering services relating to diamonds or diamond jewellery if it relates to:

• the execution of obligations arising from contracts concluded before 15 December 2023

A licence may be issued for the import of certain diamonds processed in a third country, as specified in regulation 46Z16Q, if it relates to:  

• the execution of obligations arising from contracts concluded before 1 March 2024 where the diamonds are larger than or equal to 1 carat (0.2 grams or equivalent)

• the execution of obligations arising from contracts concluded before 1 September 2024 where the diamonds are larger than or equal to 0.5 carats (0.1 grams or equivalent) and smaller than 1 carat

A licence may be issued for the provision of technical assistance, financial and brokering services related to certain diamonds processed in a third country, as specified in regulation 46Z16Q, if it relates to: 

• the execution of obligations arising from contracts concluded before 1 March 2024 where the diamonds are larger than or equal to 1 carat (0.2 grams or equivalent)

• the execution of obligations arising from contracts concluded before 1 September 2024 where the diamonds are larger than or equal to 0.5 carats (0.1 grams or equivalent) and smaller than 1 carat

The General Trade Licence for sanctioned diamonds permits the import into the UK of:

• certain Russian-originating diamonds of 1 or more carats processed in a third country that were outside of Russia on 1 March 2024 and have remained outside of Russia since that date, and of
• certain Russian-originating diamonds of between 0.5 and 1 carats processed in a third country that were outside of Russia on 1 September 2024 and have remained outside of Russia since that date 

Other conditions apply. For more information, refer to guidance on third country processed diamonds measures.

Coal and coal products

A licence may be issued for the import of coal and coal products and for the acquisition, directly or indirectly, of coal and coal products, if it relates to at least one of the following:

• the execution of obligations arising from contracts concluded before 21 July 2022
• ancillary contracts necessary for the execution of such a contract

A licence may be issued for the provision of technical assistance, brokering services, financial services or funds relating to coal and coal products if it relates to at least one of the following:

• the execution of contracts concluded before 21 July 2022
• ancillary contracts necessary for the execution of such a contract

This is provided the actions carried out under these contracts are completed by 31 December 2022.

Enforcement of trade sanctions

The Russia Sanctions Regulations, in combination with the Customs and Excise Management Act 1979 (CEMA) make it a criminal offence to contravene the trade sanctions. Some breaches of the import sanctions prohibitions are triable either way and carry a maximum sentence on indictment of 7 years’ imprisonment or a fine (or both). Under regulation 86 of the Russia (Sanctions) (EU Exit) Regulations 2019, this maximum sentence has been modified to 10 years’ imprisonment.

Any breach of the trade licensing provisions or information requirements in connection with general trade licences is also triable either way and carries a maximum sentence on indictment of 2 years’ imprisonment or a fine (or both). Please refer to Part 4 of the CEMA and Part 9 of the Russia Sanctions Regulations for further details.

HM Revenue and Customs (HMRC) is responsible for enforcing the licensing restrictions and investigating suspected offences.

If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible.

Enquiries

For further information on import sanctions, contact [email protected].

For information on export controls:

• contact the Export Control Joint Unit (ECJU) on 020 7215 4594
• email [email protected]
• subscribe to the ECJU’s notices to exporters

For specific queries on export-related trade sanctions, contact [email protected].

If your query is related to trade services sanctions, contact [email protected].

If you have a question about trading with Ukraine, Russia or Belarus due to the ongoing crisis, please use the dedicated online service to contact the export support team.

1. ‘non-government controlled Ukrainian territory’ means Crimea and non-government controlled areas of the Donetsk, the Autonomous Republic of Crimea, the City of Sevastopol and the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine. Please see the Russia sanctions statutory guidance published by the FCDO for further details. ↩

2. ‘Windsor Framework’ has the same meaning as in Joint Declaration No.1/2023 of the EU and the United Kingdom in the Withdrawal Agreement Joint Committee of 24 March 2023. ↩