We are sharing this update from ACCA, our professional body, for the interest of clients and contacts. The content is (c) ACCA
The UK government has extended regulations to prohibit the provision of professional services to Russia
On 30 September 2022 Foreign Secretary James Cleverly announced the UK government’s intention to impose further restrictions on the provision of professional services to Russia (these being advertising, auditing, architectural, engineering and IT consultancy and design services).
Read the foreign secretary’s announcement.
On 15 December the new regulations were laid in Parliament and came into force from 16 December.
The prohibitions apply to the UK and to the conduct of all UK legal persons (including companies and accountancy firms), wherever they are based in the world. It is a criminal offence under the regulations to contravene any of the prohibitions set out in them.
What services are prohibited?
New regulation 54C of the 2019 Regulations now stipulates that a person must not directly or indirectly provide to a person connected with Russia:
- accounting services
- advertising services
- architectural services
- auditing services
- business and management consulting services
- engineering services
- IT consultancy and design services
- public relations services.
Regulation 21(2) provides that ‘A person connected with Russia’ means:
- an individual who is, or an association or combination of individuals who are, ordinarily resident in Russia
- an individual who is, or an association or combination of individuals who are, located in Russia
- a person, other than an individual, who is incorporated or constituted under the law of Russia
- a person, other than an individual, who is domiciled in Russia.
Where are the full links to the relevant parts of the regulations?
Below are the links to the specific regulations relevant to this announcement:
9. Amendment of regulation 54B (interpretation of Chapter 6B)
10. Amendment of regulation 54C (professional and business services)
14. Substitution of regulation 60DA (trade: exception relating to professional and business services)
Insertion of Schedule 3J to the Russia (Sanctions) (EU Exit) Regulations 2019
You can also read the full legislation.
Has the government published any guidance?
Read the government’s statutory guidance, which iscurrently being updated to include auditing services.
Licences may be issued for certain trade activities that would otherwise be prohibited by the sanctions regulations. Read the guidance on applying for a licence.