The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025

Explanatory Note

(This note is not part of the Regulations)

These Regulations are made under the Sanctions and Anti-Money Laundering Act 2018 (c. 13). Regulations 3 to 16 amend the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) (“the 2019 Regulations”). Regulation 17 makes transitional provision.

Regulation 3, for the purposes of the imposition of trade sanctions in Part 5, adds definitions of “energy-related technology”, “G7 dependency and further technology”, “Russia’s vulnerable technology” and “sectoral software and technology”. Regulations 4, 5, 8 and 9 impose the corresponding prohibitions (“the new prohibitions”) and regulation 16(26) and Schedule 5 add relevant definitions in relation to the “sectoral software and technology” prohibitions.

Regulation 7 imposes prohibitions in relation to the import of relevant processed synthetic diamonds. Regulation 6 makes a consequential amendment.

Regulations 10 to 14 create exceptions to the new prohibitions.

Regulation 15 both prescribes offences created by these Regulations and other regulations amending the 2019 Regulations, the suspected commission of which may be referred to His Majesty’s Revenue and Customs for investigation, and creates exceptions to such referrals in certain cases.

Regulation 16 amends certain Schedules to the 2019 Regulations.

The transitional provision in regulation 17 relates to licences issued under regulation 65 of the 2019 Regulations. These licences ensure that the licence holder is not subject to certain prohibitions in those Regulations in respect of the activities specified in the licence. Regulation 17 provides that such licences issued before these Regulations come into force, will continue to apply on and after that date in respect of certain activities which would otherwise be subject to the new prohibitions.

A full impact assessment has not been produced for this instrument as no, or no significant, impact on the private, voluntary or public sectors is foreseen.