Sanctions on accountancy and auditing services
The UK announced a ban on professional services exports to Russia on 4 May 2022. This was implemented in SI 2022/850 (amending The Russia (Sanctions) (EU Exit) Regulations 2019) and came into force on 21 July 2022. The sanctions cover accountancy, management consulting, and PR services. The statutory guidance Russia sanctions: guidance was updated by the Government on 21 July 2022 to reflect the changes.
The revised regulations are considered in the article Prohibition on provision of accountancy services to Russia comes into force (Insights, 21 July 2022) along with suggested action points for ICAEW member firms.
The UK announced additional services sanctions on 30 September 2022, which include a ban on auditing services and transactional legal advisory services.
The EU announced a package of sanctions on 3 June 2022, which includes a prohibition on the provision of consulting services to Russia. The sanctions include accounting, auditing, bookkeeping, tax consulting services, business and management consulting, and PR services. The Council Regulation (EU) 2022/879 gives a detailed list of which services are prohibited and a number of exceptions (see paragraphs 23-26 and articles to be amended). The deadline for cessation of activities was 5 July 2022.
On 24 June 2022 the EU Commission published an updated FAQ on the prohibition of the provision of business services.
The US announced measures on 8 May 2022 that include a ban on the provision of accounting, trust and corporate formation, and management consulting services to any person in the Russian Federation. The US Treasury subsequently published a FAQ on the prohibitions, clarifying what is covered by the terms "accounting," "trust and corporate formation," and "management consulting" services.
OFSI issue general licence to permit the payment of legal fees to designated persons
As a result of the increasing number of new designations under the Russia and Belarus regimes, and the correlating increase in the number of those seeking a licence from OFSI for the payment of legal fees, OFSI has issued a general licence to permit the payment of legal fees owed by individuals and entities designated under either of these regimes. The licence was issued on 28 October 2022.
The licence distinguishes between legal fees in relation to ‘pre-designation’ work, and work started ‘post-designation’.
In practice, General Licence INT/2022/2252300 means that a UK legal firm or UK Counsel who has provided legal advice to a person designated under either the Russia or Belarus regime, will not have to wait for an OFSI specific licence before they can receive payment from that designated person, provided that the terms of the general licence are met.
Sanctions imposed by the UK
Sanctions imposed by the EU and Europe
Sanctions imposed by the US and Canada
Sanctions imposed by other jurisdictions
Counter-sanction measures imposed by Russia
Looking for information on counter-sanction and business support measures announced by Russia? We provide links to summaries of new regulations adopted since 24 February 2022 in English and Russian.
Support for members during the Ukraine crisis
Resources for members
Chartered Accountants from across the membership have reached out to share how they are responding to the sanctions. Many are re-screening all clients with connections to Russia. Here are some of the key resources to help you respond to clients' concerns.
Doing business in ...
Guides to affected countries
ICAEW's Library and Information Service produces guides for members who are considering doing business in overseas countries. There are separate guides for Ukraine and its neighbours, all of which include updates on the latest sanctions and restrictions.
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