The Environmental Delivery Plans (Appropriate Prioritisation) Regulations 2026

Published: Thu 18th Jun 26

These Regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019 to expand the scope of prohibited financial services and introduce mandatory reporting requirements for relevant firms.

The measures target individuals and entities specified by the Secretary of State, prohibiting the provision of certain investment services and dealing in transferable securities.

The regulations apply to all persons within the United Kingdom and all United Kingdom persons, as defined by the Sanctions and Anti-Money Laundering Act 2018, regardless of their location.

Arguments For

The document states that the amendments are intended to encourage Russia to cease actions which destabilize Ukraine or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.
The explanatory memorandum asserts that these measures aim to disrupt the financial networks supporting the Russian administration by tightening restrictions on the provision of financial services.
The regulations incorporate existing lists of persons and entities determined to be involved in destabilizing activities, providing a legal basis for immediate enforcement of new prohibitions against these subjects.

Arguments Against

Legal commentators have noted that the broad definition of "financial services" could lead to compliance uncertainty for international financial institutions operating across multiple jurisdictions.
Affected commercial entities have previously raised concerns regarding the administrative burden of the new reporting requirements and the potential for unintended disruption to non-sanctioned trade.
Some legal analysts argue that the effectiveness of the reporting obligations depends heavily on the proactive enforcement by various regulatory agencies, which may lack sufficient resource allocation.

1. Citation and commencement

(1) These Regulations may be cited as the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024.

(2) These Regulations come into force on the day after the day on which they are made.

This section establishes the official title of the legal instrument.

It specifies that the provisions become legally binding one day after the document is officially signed into law.

2. Amendment of the Russia (Sanctions) (EU Exit) Regulations 2019

The Russia (Sanctions) (EU Exit) Regulations 2019 are amended as set out in regulations 3 to 10.

This provision directs that the primary 2019 Russia sanctions regulations be modified according to the specific instructions contained in the following sections.

It serves as the legal link between the original piece of legislation and these new amendments.

3. Investment services and transferable securities

(1) Regulation 16 (dealing with transferable securities and money-market instruments) is amended as follows—

(a) in paragraph (1), for "(5), (7) and (9)" substitute "(5) to (10)";

(b) after paragraph (9) insert—

"(10) This paragraph applies to a person who is a person connected with Russia."

This amendment expands the prohibition on dealing with certain financial instruments to include any person defined as being connected with Russia.

It updates the scope of existing financial restrictions to capture a wider range of transactions and individuals associated with the Russian economy.

4. Provision of financial services

In regulation 18A (provision of financial services for the purposes of foreign exchange reserve and asset management)—

(a) in paragraph (1), for "is prohibited" substitute "must not provide financial services to a person mentioned in paragraph (2)";

(b) in paragraph (2), after sub-paragraph (d) insert—

"(e) a person owned or controlled directly or indirectly (within the meaning of regulation 7) by a person mentioned in sub-paragraphs (a) to (d)."

The regulations prohibit the provision of financial services intended for foreign exchange and asset management to specific entities, including the Central Bank of the Russian Federation.

This section extends that prohibition to cover any entity owned or controlled by those originally specified bodies.

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