On 23 April, the UK Parliament adopted The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, which introduced new trade restrictions. New restrictions involve export and import prohibitions, including prohibitions on technology and software transfers.
Export prohibitions target chemicals, plastics, metals, machinery and electronics, which have military and industrial uses. Import prohibitions involve synthetic diamonds, which were mined in Russia and have been processed in third countries. This includes prohibition of technical assistance, financial services and funds as well as brokering services related to relevant processed synthetic diamonds. The ban applies to synthetic diamonds weighting 0.5 carats and above, which is similar to already existing ban in respect of natural diamonds. Import of Russian helium, which has already been banned in the EU, is now prohibited by the UK authorities.
Technology transfer measures prohibit the transfer of technology related to a range of goods already sanctioned for export, unless exceptions and licences apply. Technology includes information, necessary for the development, production or use of goods or software, and may include trade secrets, IP and industrial know-how. The transfer of technology may take tangible (written in physical documents or recorded on other media) and intangible (e.g. via telephone calls, emails or video conferences) forms. As such, businesses need to take extra care to ensure that they comply with sanctions restrictions and do not breach new or already existing sanctions prohibitions.
Software transfer prohibitions target business enterprise software, industrial design software and oil and gas-related software, shared in and via non-tangible formats. Software sanctions prohibit the transfer of or access to sectoral technology and software to a person connected with Russia or for use in Russia. The ancillary services, namely brokering services, provision of financial services and funds as well as technical assistance relating to sectoral software and technology are also prohibited.
On 24 April, the Office of Trade Sanctions Implementation (OTSI) has published guidance on Complying with technology transfer sanctions and Complying with sectoral software sanctions. Both documents state that the technology transfer and sectoral software sanctions apply to any individual or entity in the UK and to UK persons overseas. Subsidiaries of UK companies operating overseas should exercise extra care to ensure that their UK nationals comply with those sanctions. It is recommended that businesses determine the extent of new sanctions application and map their sanctions risks accordingly.
The prohibited items include, but are not limited to, video games controllers, radio remote controllers, amplifiers and circuits.
There are many ways to reduce your and your business’s exposure to sanctions risks, which may include: the development of sanctions policies and implementation of the appropriate systems aimed at prevention of sanctions non-compliance; introduction of relevant clauses in existing and new contracts, implementing additional controls to ensure that restricted technologies and software are treated accordingly; regular assessment of your sanctions and a wider compliance risks.
New sanctions are complex and involve a high degree of diligence consistently exercised by companies and individuals. Gherson Solicitors will be glad to assist you with navigating your sanctions risks.
Updated: 25 April 2025
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The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.
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