United Kingdom

The UK announced a ban on professional services exports to Russia on 4 May 2022, covering accountancy, management consulting, and PR services. This was implemented in SI 2022/850 (amending The Russia (Sanctions) (EU Exit) Regulations 2019) and came into force on 21 July 2022. The article Prohibition on provision of accountancy services to Russia comes into force (Insights, 21 July 2022) highlights 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. In December 2022, the Government laid new regulations in Parliament that extend the prohibition on the provision of professional services to include “auditing services”, subject to certain limited exemptions, which took effect from 16 December 2022. This is covered in the article what the ban on auditing services to Russia means for your clients.

These prohibitions apply within the territory of the United Kingdom (including Northern Ireland) and in relation to the conduct of all UK persons wherever they are in the world. A person in the UK and UK persons are prohibited from providing the sanctioned services, directly or indirectly, to a person connected with Russia. A person connected with Russia is defined in Regulation 21 of the 2019 Russia Sanctions Regulations as a person who is ordinarily resident or located in Russia, a person domiciled in Russia, or a body incorporated or constituted under Russian law.

The Russia sanctions: guidance was updated by the UK Government on 5 January 2023.

European Union

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.

The EU published Guidance for EU operators: Implementing enhanced due diligence to shield against Russia sanctions circumvention in September 2023, highlighting key considerations and listing red flags to be aware of before entering commercial relationships with new trading partners.

A breakdown of the areas covered by EU sanctions is available from a dedicated page on EU sanctions against Russia following the invasion of Ukraine

United States

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.

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