Search for exceptions to the Russia commerce and transport sanctions

An exception applies mechanically so you do not want to get a licence, however some exceptions have reporting obligations.

To verify the complete authorized wording of an exception, go to the rules listed in Part 7 of the Russia regulations. If you’re uncertain whether or not an exception applies in your circumstances, you’re suggested to hunt impartial authorized recommendation.

Exceptions for exporting, making accessible, provide and switch

Exceptions for private results, private use, diplomatic missions and many others (regulation 60A)

60A exceptions for restricted items and expertise

These exceptions relate to prohibitions partially 5 chapter 2 concerning the export, provide, supply, making accessible or switch of essential {industry} items or expertise, or quantum computing or superior supplies items or expertise, and associated companies to or to be used in Russia, to an individual related with Russia, to a Russian-flagged ship, or to a spot in Russia, together with from a 3rd nation.

The exception applies if the products or expertise are:

• the non-public results of an individual travelling to Russia, or
• of a non-commercial nature for the non-public use of an individual travelling to Russia and contained in that particular person’s baggage, or
• mandatory for the official functions of a diplomatic mission or consular put up in Russia, or of a global organisation having fun with immunities within the UK in accordance with worldwide legislation

60A exceptions for luxurious items

These exceptions relate to prohibitions in regulation 46B concerning the export, provide, supply or making accessible of luxurious items, and associated companies, to or to be used in Russia, or to an individual related with Russia.

The exception applies if the posh items are:

• mandatory for the official functions of a diplomatic mission or consular put up in Russia, or of a global organisation having fun with immunities in accordance with worldwide legislation, or
• the non-public results of their workers, or
• inside commodity codes 7113 00 00 and 7114 00 00, and for private use of and owned by the pure particular person exporting it, or a right away member of the family, travelling with them to Russia, contained of their baggage offered that the gadgets will not be meant on the market

60A exceptions for G7 dependency and additional items and expertise

These exceptions relate to prohibitions in chapter 4H concerning the export, provide, supply, making accessible or switch of G7 dependency and additional items or expertise, and associated companies, to or to be used in Russia, to an individual related with Russia, or to a spot in Russia.

The exception applies if the G7 dependency and additional items or expertise are:

• mandatory for the official functions of a diplomatic mission or consular put up in Russia, or a global organisation having fun with immunities in accordance with worldwide legislation, or
• the non-public results of their workers

60A exceptions for Russia’s weak items and expertise

These exceptions relate to prohibitions in chapter 4M concerning the export, provide, supply, making accessible or switch of Russia’s weak items or expertise, and associated companies, to or to be used in Russia, to an individual related with Russia, or to a spot in Russia.

The exception applies if the weak items or expertise are:

• mandatory for the official functions of a diplomatic mission or consular put up in Russia, or a global organisation having fun with immunities in accordance with worldwide legislation, or
• the non-public results of their workers

60A exceptions for sectoral software program and expertise

These exceptions relate to prohibitions in chapter 4N concerning the making accessible or switch of sectoral software program or expertise, and associated companies, to or to be used in Russia, to an individual related with Russia or to a spot in Russia.

The exception applies if the sectoral software program or expertise are:

• mandatory for the official functions of a diplomatic mission or consular put up in Russia or a global organisation having fun with immunities in accordance with worldwide legislation

Exceptions for shopper communication units and software program updates (regulation 60B)

These exceptions relate to prohibitions in rules 22, 24(1)(a), 25(1)(a) and (b), 26(1)(a) and (b) concerning the export, provide, supply, making accessible or switch of sure luxurious, G7 dependency and additional items and expertise or essential {industry} items and expertise, and associated companies, to or to be used in Russia, an individual related with Russia or to a spot in Russia.

The exception applies if the posh, G7 dependency and additional items or essential {industry} items or expertise are:

• shopper communication units for civilian use, or
• software program updates for civilian use

Exceptions for the elimination of plane and vessels from the UK to Russia (regulation 60C)

These exceptions relate to prohibitions in rules 22 and 28 concerning the export of critical-industry items or aviation and area items, and associated companies to or to be used in Russia.

For the elimination of an plane, the exception applies if:

• it travels below its personal energy, and
• it’s carrying items or passengers, or travelling from the UK to be able to undertake a return flight carrying items or passengers, and
• its elimination shouldn’t be for the aim of a switch of possession (together with any of its element components) or a change of operator

For the elimination of a vessel, the exception applies if:

• it’s faraway from the UK below its personal energy, and
• its elimination shouldn’t be for the aim of a switch of possession (together with any of its element components) or a change of operator

The exceptions additionally present that prohibitions concerning the provide, supply, making accessible or switch of essential {industry} items or expertise or area and aviation items or expertise, or the supply of insurance coverage and reinsurance companies, will not be contravened when sure actions are carried out in reference to a qualifying elimination.

The exceptions additionally present that the prohibition in regulation 27(1)(a) shouldn’t be contravened by the supply of technical help to an plane owned, chartered or operated by an individual related with Russia, at a UK airport offered that the help shouldn’t be for the needs of facilitating a switch of possession of the plane or any of its element components; or a change within the operator of the plane.

Exception for technical help to plane and ships when lives can be endangered (regulation 60D)

This exception pertains to prohibitions in regulation 46A about technical help referring to plane or ships offered to or for the advantage of a delegated particular person.

The exception applies if:

• a failure to supply technical help would endanger the lives of individuals on board or the protection of an plane in flight or a ship at sea

Exceptions for accounting, enterprise and administration consulting and different companies (regulation 60DA)

These exceptions relate to prohibitions in regulation 54C concerning the provision of accounting, promoting, architectural, auditing, enterprise and administration consulting, engineering, IT consultancy and design, or public relations companies.

The exceptions apply if the companies are:

• authorised conduct in a related nation, such because the Channel Islands, Isle of Man, or any British abroad territory, as in regulation 62A (applies to all prohibitions in regulation 54C)
• official functions of a diplomatic mission or consular put up in Russia or of a global organisation having fun with immunities in accordance with worldwide legislation (applies to all prohibitions in regulation 54C)
• the discharge or compliance with UK statutory or regulatory obligations, such obligations not arising below contract (applies solely to accounting, enterprise and administration consulting, engineering and public relations companies prohibitions, and an analogous tailor-made exception applies to the auditing companies prohibition)
• companies offered to a Russian subsidiary of a UK credit score establishment (applies to auditing companies prohibition solely)
• provision of making certain the continuance or resumption of civilian telecommunications companies or companies incident to the change of communications over the web (applies to IT consultancy and design companies prohibition solely)

Further exceptions referring to obligations arising or concluded previous to sure rules coming into power in 2022 and 2023 are nonetheless energetic, however are unlikely to to be wanted in follow.

Exceptions for sectoral software program and expertise (regulation 60DZA)

These exceptions relate to prohibitions in chapter 4N concerning the making accessible, provide or switch of sectoral software program or expertise to or to be used in Russia, to an individual related with Russia, or to a spot in Russia, and associated companies.

The exceptions apply if the software program or expertise are:

• in satisfaction of an obligation arising below a contract concluded earlier than 23 April 2025 (or ancillary contracts mandatory for his or her execution) offered that the act is carried out by 22 July 2025 and is notified to the Secretary of State by that date, or
• of a non-commercial nature, or
• for private use, or
• the place that act is to discharge, or adjust to, UK statutory or regulatory obligations and the Secretary of State is notified inside 12 months

Exceptions for authorized advisory companies for diplomatic, compliance or contractual causes (regulation 60DB)

These exceptions relate to prohibitions in regulation 54D concerning the provision of authorized advisory companies.

The exceptions apply if the companies are:

• mandatory for official functions of a diplomatic mission or consular put up in Russia or of a global organisation having fun with immunities in accordance with worldwide law- the discharge or compliance with UK statutory or regulatory obligations
• in relation to the discharge or compliance with UK statutory or regulatory obligations
• for the aim of advising on compliance with the rules
• for the aim of advising on compliance with, or the consequence of compliance with any related legislation, the place ‘relevant law’ contains sanctions and legal legislation imposed by any jurisdiction, and any Russian legislation that frustrates, or is meant to frustrate, sanctions
• for the aim of advising on the discharge of obligations below the related law- the potential or precise software of punitive measures
• for the aim of advising on the potential or precise software of punitive measures

Exceptions for the export of maritime items and maritime expertise (regulation 60E)

These exceptions relate to prohibitions in chapter 2 of half 5 concerning the export, sale, making accessible, provide or switch of maritime items or maritime expertise, and associated companies, to or to be used in Russia, for a Russian flagged ship, to an individual related with Russia, or to a spot in Russia.

The exceptions apply if the export, sale, making accessible, provide or switch are for:

• non-military use and for a non-military end-user
• humanitarian help exercise
• well being emergencies
• the pressing prevention or mitigation of an occasion more likely to have a critical and important influence on human well being and security or the surroundings
• responding to pure disasters

Exceptions for the export of banknotes for private use or for diplomatic missions or worldwide organisations (regulation 60F)

These exceptions relate to prohibitions in chapter 4E of half 5 concerning the export, provide, supply and making accessible of banknotes to or to be used in Russia.

The exceptions apply if:

• the banknotes are meant for the non-public use of individuals and their households travelling to Russia as much as a worth of £10,000
• the banknotes are for the official functions of diplomatic missions, consular posts and worldwide organisations, which doesn’t have a restrict
• an individual doesn’t know and has no affordable trigger to suspect that the banknotes had been in the end to be exported to be exported, provided, delivered or made accessible to particular person related with Russia or to be used in Russia

Exception for emergencies in sure circumstances the place time is brief (regulation 61)

This exception pertains to sure commerce prohibitions about energy-related items, infrastructure in non-government managed Ukrainian territory, restricted items and expertise, and companies referring to critical-industry items, aviation and area items, oil refining items, critical-industry expertise, aviation and area expertise and oil refining expertise, G7 and additional items and expertise, Russia’s weak items and expertise, sectoral software program and expertise, skilled and authorized advisory companies, and maritime companies referring to Russian oil.

The exception applies to acts coping with an emergency, the place passable justification is offered to the Secretary of State inside 5 working days.

An emergency is outlined as an act helping with the pressing prevention or mitigation of an occasion more likely to have a critical and important influence on human well being or security, infrastructure or the surroundings.

Exceptions for importing, acquisition and provide

Exceptions for the import of private results, private use, diplomatic missions and many others (regulation 60A)

60A exceptions for gold and gold jewelry

One exception pertains to prohibitions in chapters 4J and 4JA concerning the import of gold, processed gold, gold jewelry or diamond jewelry, or the acquisition of gold, gold jewelry, or the availability or supply of gold, and associated companies, from Russia to a 3rd nation or to the UK.

The exception applies if the products are:

• mandatory for the official functions of a diplomatic mission or consular put up in Russia, or a global organisation having fun with immunities in accordance with worldwide legislation

A second exception pertains to prohibitions in chapters 4JA and 4JB concerning the import of gold, processed gold, gold jewelry or diamond jewelry, or the acquisition of gold, gold jewelry or diamond jewelry, or the availability or supply of gold, and associated companies, from Russia to a 3rd nation or to the UK.

The exception applies if the products are:

• non-commercial jewelry that’s for private use of and owned by the pure particular person importing it, or a right away member of the family, travelling with them to the UK, contained of their baggage offered that the jewelry shouldn’t be meant on the market

60A exception for sure revenue-generating items

This exception pertains to prohibitions in regulation 46XC concerning the acquisition of schedule 3DA revenue-generating items that originated in Russia or are positioned in Russia.

The exception applies if the products are:

• mandatory for the official functions of a UK diplomatic mission or consular put up in Russia

Exception for sure items consigned from Russia earlier than sanctions had been imposed (regulation 60G)

These exceptions relate to sure items imported into the UK earlier than both 20 May 2023 or 14 January 2024.

This exception pertains to sure prohibitions in chapter 4C, in addition to in regulation 46IH(1)(a), in regards to the acquisition of iron and metal merchandise, acquisition of metals, and associated companies.

The exception applies the place the related iron and metal merchandise, or metals, are positioned within the United Kingdom or the Isle of Man, having been lawfully imported there.

This exception pertains to sure prohibitions in chapter 4CA regarding iron and metal merchandise, sure processed iron or metal merchandise and metals, and associated companies.

The exception applies if the related iron and metal merchandise, processed iron and metal merchandise, or metals:

• had been exported from Russia earlier than the relevant prohibition got here into power, and
• are to not be launched into free circulation within the United Kingdom or Isle of Man

Exception for acquisition of ancillary companies when iron and metal merchandise are in third international locations (regulation 60GAB)

This exception pertains to sure prohibitions in chapter 4C about companies associated to iron and metal merchandise.

The exception applies if:

• the related iron and metal merchandise had been exported from Russia earlier than the relevant prohibition got here into power

Exception for acquisition of sure revenue-generating items (regulation 60GB)

This exception pertains to prohibitions in chapter 4GA concerning the acquisition of schedule 3DA revenue-generating items, and associated companies.

The exception applies if:

• the products are positioned within the UK or the Isle of Man, having been lawfully imported there
• a UK nationwide positioned in Russia engages in these actions in relation to items that are positioned in Russia and are for private use of that UK nationwide or their quick relations

Exception for the acquisition of diamonds and diamond jewelry (regulation 60GC)

This exception pertains to prohibitions in chapter 4JB concerning the acquisition of diamonds and diamond jewelry that originated in Russia, and associated companies.

The exception applies if:

• the products are positioned within the United Kingdom or Isle of Man having been lawfully imported there

Exception for oil and oil merchandise positioned in Russia (regulation 60H)

This exception pertains to prohibitions in chapter 4I concerning the import and acquisition of oil and oil merchandise positioned in Russia, and associated companies.

The exception applies if the oil or oil merchandise:

• originated in a rustic that’s not Russia, and
• will not be owned by an individual related with Russia, and
• are solely being loaded in, departing from or transiting by way of Russia

One exception pertains to prohibitions in rules 44 and 45 about monetary or brokering companies for energy-related items and power associated expertise.

A second exception pertains to prohibitions in chapter 4 concerning the export, provide and supply, making accessible and switch of energy-related items and expertise and associated actions and companies.

The exception referring to rules 44 and 45 applies if insurance coverage or reinsurance companies are:

• offered to a related particular person with regard to that particular person’s actions outdoors the power sector in Russia

The second exception applies if a related exercise:

• is important for the needs of a UK petroleum challenge

Exceptions referring to non-government managed Ukrainian territory

Exceptions for non-government managed areas of the Donetsk and Luhansk oblasts (regulation 60ZA)

Certain time-limited exceptions referring to non-government managed areas of the Donetsk and Luhansk oblasts, apply in the event that they relate to an obligation arising from a contract concluded earlier than varied dates in 2022, and so are unlikely to to be wanted in follow.

Exception for humanitarian help exercise in non-government managed areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts (regulation 61ZA)

There is an exception to sure prohibitions regarding infrastructure-related items, and associated companies, in relation to non-government managed Ukrainian territory for actions mandatory to make sure the well timed supply of humanitarian help exercise in non-government managed areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts.

Exception for imports from non-government-controlled Ukrainian territory the place the products originate in Ukraine (regulation 62)

This exception pertains to prohibitions in rules 47 and 52(3)(a), and chapter 2 and 2A of half 5 as far as they relate to the import of products originating in non-government managed Ukrainian territory, and the supply of associated monetary companies or funds.

The exception applies if:

• the products originate in non-government managed Ukrainian territory and have been satisfactorily licensed by or on behalf of the Government of Ukraine as originating in Ukraine.

Exceptions for transport sanctions

Exception for sure ships to enter UK ports (regulation 61A)

This exception pertains to prohibitions in regulation 57A concerning the granting of, or inflicting or allowing, entry to a UK port.

The exception applies if:

• the entry is required by a ship within the case of an emergency, or
• required in accordance with a motion course

Exception for sure plane to make UK landings and use UK airspace (regulation 61B)

This exception pertains to prohibitions in regulation 57J concerning the overflight and touchdown within the UK of sure plane.

The exception applies to a touchdown, or overflight preparatory to a touchdown, if:

• failing to land would endanger the lives of individuals on board or the protection of the plane, or
• required in accordance with a motion course

General exceptions

Exception for authorised conduct in a related nation (regulation 62A)

This exception pertains to prohibitions in rules 11 to fifteen, r16, 17, 17A, 18, 18A, 18B and chapters 2 to six and chapter 6B of half 5 (Trade).

The exception applies if:

• conduct is authorised by a licence or different authorisation that’s issued below the legislation of the Channel Islands, Isle of Man or any British Overseas Territory for the aim of disapplying a prohibition in that jurisdiction which corresponds to the related prohibition

Exception for acts executed for functions of nationwide safety or prevention of significant crime (regulation 63)

There is an exception that can be utilized in relation to any prohibition or requirement imposed by the rules. The exception applies if:

• a accountable officer has decided the related actions to be within the pursuits of nationwide safety, or the prevention or detection of significant crime within the UK or elsewhere