UK announces one-year-anniversary Russia sanctions package — import ban on 140+ goods (SI 2023/440)

Mechanism

The measure is an import/export prohibition made under the Russia (Sanctions) (EU Exit) Regulations 2019, amended by SI 2023/440. The import leg bars over 140 product lines from Russia, including iron and steel products that were merely processed (not originating) in a third country — closing a transshipment route the earlier Schedule 3D import bans did not reach. The export leg bars goods documented as used by Russian forces on the battlefield in Ukraine. The package also added 92 entries to the UK asset-freeze list, including Rosatom, Rostec and Almaz-Antey executives. Most of SI 2023/440 entered into force 21 April 2023; the third-country iron/steel provision (Regulation 3) was delayed to 30 September 2023 to give importers a transition window.

Severity basis

The package bans over 140 distinct goods lines from import and adds 92 named individuals/entities to the asset-freeze list in a single instrument — a numerically disclosed, broad-based expansion of the existing UK Russia sanctions regime, comparable in scale to the EU's concurrent 10th sanctions package.

Downstream implications

• Closes a transshipment loophole for Russian-origin iron and steel

processed in a third country before import into the UK.

• Exporters of any goods documented on the battlefield in Ukraine (optics,

electronics, vehicle parts) fall into scope of the new export ban.

Open questions

• Full list of the 140+ banned import product lines by HS code is not

confirmed from a primary text here; no itemised magnitude: coverage share is filed.