Sanctions And Export Controls: Key Considerations In The EU And The UK In 2024

The effects of Russia's invasion of Ukraine on the architecture and implementation of UK and EU sanctions have continued to be felt in 2023, along with an increased focus on closing loopholes in existing sanctions legislation and cracking down on those that circumvent, or facilitate the circumvention, of sanctions. While aligned on these goals, the path to implementation and enforcement in the UK and EU has varied, a trend we expect to continue.

Businesses operating across the UK and the EU in 2023 saw increased evidence of divergence in the formulation and implementation of otherwise closely coordinated sanctions measures. For example, Russia services sanctions vary both in the conduct that they seek to restrict and the exceptions that they offer (or not, in the case of the UK) to support intragroup shared service provision. These developments continue to create additional compliance complexity for international businesses, despite sustained efforts by the UK and