On 3 October 2014, the UK’s Department for Business, Innovation and Skills (“BIS”), which is responsible for implementing and enforcing EU trade restrictions within the UK, published an updated version of its frequently asked questions (“FAQs”) about the trade aspects of the two sets of EU sanctions against Russia introduced since July 2014.
Two clarifications are provided regarding the scope of the sanctions, among other minor updates:
- BIS clarified that where a prohibition on the provision of “financial assistance” does not expressly refer to “insurance or reinsurance”, the prohibition does not apply to insurance or reinsurance activities.
- As the sanctions prohibit direct or indirect provision of specified “associated services” to the Russian oil industry, an EU national or business supplying personnel or arranging the supply of staff to carry out those activities would indirectly be providing prohibited services. However, the FAQs state that the sanctions would not cover the provision of purely HR or payroll services.