Fionna Gavin Joint Head of Insurance, Partner
A brief summary of some recent developments in international sanctions.
On 28 June 2017, the EU extended sanctions against Russia for a further six month period, until 31 January 2018. This decision followed an update by the French President and German Chancellor on the implementation of the Minsk agreements. Anyone transacting Russian business is, therefore, advised to consider the impact of the continuing EU sanctions on these activities.
The Queen’s speech on 21 June 2017, which sets out the Government’s legislative agenda for the next two years, stated that one of the bills to be introduced in the UK will be an International Sanctions Bill. It is understood that this will support the UK’s role as a permanent member of the UN Security Council and establish a new sovereign framework for the UK to implement international sanctions, whether that be with or without other countries, as part of the ‘Brexit’ process.
It is likely that the UK and remaining 27 EU countries post-Brexit will maintain a high level of regulatory convergence, as both will continue to fulfil international obligations as UN members. Nevertheless, there exists the possibility that the UK and EU sanctions regimes might diverge and it is recommended to make appropriate contractual provision for this potential situation, e.g. if either the UK and EU did adopt different sanctions regimes or where one party is subject to UK sanctions and the other is not.
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