UK bans acquisition and import of Russian-origin metals (Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023, SI 2023/1364)

Mechanism

Trade-sanctions amendment under the Sanctions and Anti-Money Laundering Act 2018 framework. SI 2023/1364 (the primary source) inserts new metals restrictions into the 2019 Russia regulations, alongside iron and steel and luxury-goods amendments visible in its table of contents. The companion SI 2023/1367 (No. 5) covers diamonds and financial measures and is not part of this action.

The metals list and grace-period terms above come from a law-firm reading of the Regulations (Schedule 3BA); the SI's own schedule text was not re-read line by line. GTA logs the measure as implemented 2023-12-14; the Regulations' main commencement is reported as 15 December 2023, which is used as effective_date.

Downstream implications

• Closes the UK import route for Russian-origin base and minor metals ahead

of the EU's own metals phase-out; it targets UK persons, so third-country processing and London Metal Exchange delivery rules are separate questions.

• Buyers of copper, nickel and aluminium with Russian-origin exposure need

origin documentation after the grace window (14 January 2024).

Open questions

• No trade value or quota is disclosed in the primary text read, so

severity is qualitative.

• Whether the No. 4 commencement provisions differ for individual

Schedule 3BA lines from the main 15 December date.