On 29 June 2023, the UK government released the 3rd amendment of 2023 to the Russia (Sanctions) (EU Exit) Regulations 2019 (as amended). This effectively imposes a new Regulation 54D which prohibits UK lawyers (including in-house counsel) from directly or indirectly providing legal advisory services to non-UK persons in connection with any activity that is inconsistent with the current finance and trade related Russia sanctions restrictions. In particular, this is prohibited even if the activity does not have a UK nexus.

There are various exemptions under Regulation 60DB, but it is likely that Regulation 60DB(3) will provide some comfort as it permits UK lawyers to provide advice whether the activity or proposed activity is (or will be) in compliance with the UK sanctions rules.