The United Kingdom has finalized its ban on the delivery, sale, transit, and export of luxury goods to Russia, focusing on items that will impact Russian oligarchs and other members of the Russian elite.
The UK Department for International Trade announced on April 21, 2022, that its export ban on luxury goods to Russia, including high-end fashion goods, vehicles, works of art, pearls, semi-precious stones, and jewelry, had come into force pursuant to the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 (the UK Regulations). As discussed in our earlier LawFlash, the UK government first announced the ban on March 15, 2022, following similar moves by its G7 allies.
Under the UK Regulations, it is prohibited to export luxury goods with a sales price (excluding value-added tax (VAT)) over £250 (approximately $320) and vehicles (except for ambulances) with a sales price (excluding VAT) over £42,000 (approximately $53,460) per vehicle. The full list of all luxury goods is set out in Schedule 3A of the UK Regulations.
The ban does not extend to luxury goods that are necessary for the official purposes of a diplomatic mission or consular post in Russia or of an international organization enjoying immunities in accordance with international law.
The United Kingdom has also denied Russia and Belarus access to the “most favored nation” tariff treatment of key Russian imports valued around £900 million (approximately $1.2 billion), in addition to applying further import tariffs that represent a 35 percentage point hike on current rates. These tariffs apply to a wide range of products including vodka, works of art, antiques, fur skins and artificial fur, fertilizers, iron, steel, and aluminum.
The United Kingdom has also cut off any new UK Export Finance support for Russia and Belarus.
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If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following Morgan Lewis lawyers:
Ukraine Conflict Task Force
Giovanna M. Cinelli
Alexey Chertov
Bruce Johnston
Grigory Marinichev
Michael Masling
Kenneth J. Nunnenkamp
Christina Renner
Vasilisa Strizh
Carl A. Valenstein
Abaigael R. Clifford
Jiazhen (Ivon) Guo
Katelyn M. Hilferty
Christian Kozlowski
Pauline Mutuc
Eli Rymland-Kelly
Dr. Axel Spies