Table of Contents
Russia (Sanctions) (EU Exit) Regulations 2019 [SI 2019 No. 855]Introductory TextPart 1 General (regs. 1-4)Regulation 1 Citation and commencementRegulation 2 InterpretationRegulation 3 Application of prohibitions and requirements outside the United KingdomRegulation 4 PurposesPart 2 Designation of persons (regs. 5-9B)Regulation 5 Power to designate personsRegulation 6 Designation criteriaRegulation 6A Conditions for the designation of persons by descriptionRegulation 7 Meaning of "owned or controlled directly or indirectly"Regulation 8 Notification and publicity where designation power usedRegulation 9 Confidential information in certain cases where designation power usedRegulation 9A Notification and publicity where power to designate by description is usedRegulation 9B Confidential information in certain cases where power to designate by description is usedPart 3 Finance (regs. 10-19A)Chapter 1 Asset-freeze etc. (regs. 10-15)Regulation 10 Meaning of "designated person"Regulation 11 Asset-freeze in relation to designated personsRegulation 12 Making funds available to designated personRegulation 13 Making funds available for benefit of designated personRegulation 14 Making economic resources available to designated personRegulation 15 Making economic resources available for benefit of designated personChapter 2 Other financial and investment restrictions (regs. 16-18C)Regulation 16 Dealing with transferable securities or money-market instrumentsRegulation 17 Loans and credit arrangementsRegulation 17A Correspondent banking relationships and processing paymentsRegulation 18 Investments in relation to non-government controlled Ukrainian territoryRegulation 18A Provision of financial services relating to foreign exchange reserve and asset managementRegulation 18B Investments in relation to RussiaRegulation 18C Trust servicesChapter 3 Further provision (regs. 19-19A)Regulation 19 Circumventing etc. prohibitionsRegulation 19A Interpretation of Part 3Part 3A Director disqualification sanctionsRegulation 19B Director disqualification sanctionsPart 4 Immigration (reg. 20)Regulation 20 ImmigrationPart 5 Trade (regs. 21-56)Chapter 1 Interpretation (regs. 21-21A)Regulation 21 Interpretation of this PartRegulation 21A Definition of interception and monitoring servicesChapter 2 Restricted goods, restricted technology and related activities (regs. 22-30)Regulation 22 Export of restricted goodsRegulation 23 Import of arms and related materialRegulation 24 Supply and delivery of restricted goodsRegulation 25 Making available or acquiring restricted goods and restricted technologyRegulation 26 Transfer of restricted technologyRegulation 27 Technical assistance relating to restricted goods and restricted technologyRegulation 28 Financial services and funds relating to restricted goods and restricted technologyRegulation 29 Brokering services: non-UK activity relating to restricted goods and restricted technologyRegulation 29A Insurance and reinsurance services relating to aviation and space goods and aviation and space technologyRegulation 30 Enabling or facilitating military activitiesChapter 2A Goods and technology relating to non-government controlled Ukrainian territory (regs. 30A-30H)Regulation 30A InterpretationRegulation 30B Export of relevant restricted goods to non-government controlled Ukrainian territoryRegulation 30C Supply and delivery of relevant restricted goodsRegulation 30D Making available relevant restricted goods and relevant restricted technologyRegulation 30E Transfer of relevant restricted technologyRegulation 30F Technical assistance relating to relevant restricted goods and relevant restricted technologyRegulation 30G Financial services and funds relating to relevant restricted goods and relevant restricted technologyRegulation 30H Brokering services relating to relevant restricted goods and relevant restricted technologyChapter 3 Dual-use goods, dual-use technology and related activities (regs. 31-38)Regulation 31 Interpretation of this ChapterRegulation 32 Export of dual-use goodsRegulation 33 Supply and delivery of dual-use goodsRegulation 34 Making dual-use goods and dual-use technology availableRegulation 35 Transfer of dual-use technologyRegulation 36 Technical assistance relating to dual-use goods and dual-use technologyRegulation 37 Financial services and funds relating to dual-use goods and dual-use technologyRegulation 38 Brokering services: non-UK activity relating to dual-use goods and dual-use technologyChapter 4 Energy-related goods and related activities (regs. 39-46)Regulation 39 Interpretation of this ChapterRegulation 40 Export of energy-related goodsRegulation 41 Supply and delivery of energy-related goodsRegulation 42 Making energy-related goods availableRegulation 43 Technical assistance relating to energy-related goodsRegulation 44 Financial services and funds relating to energy-related goodsRegulation 45 Brokering services: non-UK activity relating to energy-related goodsRegulation 46 Prohibition on providing other energy-related servicesChapter 4A Aircraft and ships (reg. 46A)Regulation 46A Technical assistance relating to aircraft and shipsChapter 4B Luxury goods (regs. 46B-46BC)Regulation 46B Luxury goodsRegulation 46BA Technical assistance relating to luxury goodsRegulation 46BB Financial services and funds relating to luxury goodsRegulation 46BC Brokering services relating to luxury goodsChapter 4C Iron and steel products (regs. 46C-46I)Regulation 46C InterpretationRegulation 46D Import of iron and steel productsRegulation 46E Acquisition of iron and steel productsRegulation 46F Supply and delivery of iron and steel productsRegulation 46G Technical assistance relating to iron and steel productsRegulation 46H Financial services and funds relating to iron and steel productsRegulation 46I Brokering services relating to iron and steel productsChapter 4CA Iron and steel products processed in a third country (regs. 46IA-46IE)Regulation 46IA InterpretationRegulation 46IB Import of relevant processed iron or steel productsRegulation 46IC Technical assistance relating to relevant processed iron or steel productsRegulation 46ID Financial services and funds relating to relevant processed iron or steel productsRegulation 46IE Brokering services relating to relevant processed iron or steel productsChapter 4CB Metals (regs. 46IF-46II)Regulation 46IF InterpretationRegulation 46IG Import of metalsRegulation 46IH Acquisition of metalsRegulation 46II Supply and delivery of metalsChapter 4D Interception and monitoring services (regs. 46J-46K)Regulation 46J InterpretationRegulation 46K Interception and monitoring servicesChapter 4E Banknotes (reg. 46L)Regulation 46L BanknotesChapter 4F Jet fuel and fuel additives (regs. 46M-46Q)Regulation 46M InterpretationRegulation 46N Jet fuel and fuel additivesRegulation 46O Technical assistance relating to jet fuel and fuel additivesRegulation 46P Financial services and funds relating to jet fuel and fuel additivesRegulation 46Q Brokering services relating to jet fuel and fuel additivesChapter 4G Schedule 3D Revenue generating goods (regs. 46R-46X)Regulation 46R InterpretationRegulation 46S Import of revenue generating goodsRegulation 46T Acquisition of revenue generating goodsRegulation 46U Supply and delivery of revenue generating goodsRegulation 46V Technical assistance relating to revenue generating goodsRegulation 46W Financial services and funds relating to Schedule 3D revenue generating goodsRegulation 46X Brokering services relating to Schedule 3D revenue generating goodsChapter 4GA Schedule 3DA revenue generating goods (regs. 46XA-46XG)Regulation 46XA InterpretationRegulation 46XB Import of Schedule 3DA revenue generating goodsRegulation 46XC Acquisition of Schedule 3DA revenue generating goodsRegulation 46XD Supply and delivery of Schedule 3DA revenue generating goods to a third countryRegulation 46XE Technical assistance relating to Schedule 3DA revenue generating goodsRegulation 46XF Financial services and funds relating to Schedule 3DA revenue generating goodsRegulation 46XG Brokering services relating to Schedule 3DA revenue generating goodsChapter 4H G7 dependency and further goods (regs. 46Y-46Z2)Regulation 46Y G7 dependency and further goodsRegulation 46Z Technical assistance relating to G7 dependency and further goodsRegulation 46Z1 Financial services and funds relating to G7 dependency and further goodsRegulation 46Z2 Brokering services relating to G7 dependency and further goodsChapter 4I Oil and Oil Products (regs. 46Z3-46Z9)Regulation 46Z3 Meaning of "relevant day"Regulation 46Z4 Import of oil and oil productsRegulation 46Z5 Acquisition of oil and oil productsRegulation 46Z6 Supply and delivery of oil and oil productsRegulation 46Z7 Technical assistance relating to oil and oil productsRegulation 46Z8 Financial services and funds relating to oil and oil productsRegulation 46Z9 Brokering services relating to oil and oil productsChapter 4IA Maritime transportation of certain oil and oil products (regs. 46Z9A-46Z9D)Regulation 46Z9A InterpretationRegulation 46Z9B Maritime transportation of certain oil and oil products to and between third countriesRegulation 46Z9C Financial services and funds relating to maritime transportation of certain oil and oil productsRegulation 46Z9D Brokering services relating to maritime transportation of certain oil and oil productsChapter 4J Gold (regs. 46Z10-46Z16)Regulation 46Z10 Meaning of "relevant day"Regulation 46Z11 Prohibition on the import of gold from RussiaRegulation 46Z12 Acquisition of gold from RussiaRegulation 46Z13 Supply and delivery of gold from RussiaRegulation 46Z14 Technical assistance relating to goldRegulation 46Z15 Financial services and funds relating to goldRegulation 46Z16 Brokering services relating to goldChapter 4JA Gold jewellery and relevant processed gold (regs. 46Z16A-46Z16I)Regulation 46Z16A InterpretationRegulation 46Z16B Prohibition on the import of gold jewellery from RussiaRegulation 46Z16C Prohibition on the import of relevant processed goldRegulation 46Z16D Acquisition of gold jewellery from RussiaRegulation 46Z16E Technical assistance relating to gold jewelleryRegulation 46Z16F Technical assistance relating to relevant processed goldRegulation 46Z16G Financial services and funds relating to gold jewelleryRegulation 46Z16H Financial services and funds relating to relevant processed goldRegulation 46Z16I Brokering services relating to gold jewellery and relevant processed goldChapter 4JB Diamonds and diamond jewellery (regs. 46Z16J-46Z16P)Regulation 46Z16J InterpretationRegulation 46Z16K Import of diamonds and diamond jewelleryRegulation 46Z16L Acquisition of diamonds and diamond jewelleryRegulation 46Z16M Supply and delivery of diamonds and diamond jewelleryRegulation 46Z16N Technical assistance relating to diamonds and diamond jewelleryRegulation 46Z16O Financial services and funds relating to diamonds and diamond jewelleryRegulation 46Z16P Brokering services relating to diamonds and diamond jewelleryChapter 4JC Certain diamonds processed in a third countryRegulation 46Z16Q InterpretationRegulation 46Z16R Import of relevant processed diamondsRegulation 46Z16S Technical assistance relating to relevant processed diamondsRegulation 46Z16T Financial services and funds relating to relevant processed diamondsRegulation 46Z16U Brokering services relating to relevant processed diamondsChapter 4K Coal and Coal Products (regs. 46Z17-46Z23)Regulation 46Z17 Meaning of relevant dayRegulation 46Z18 Import of coal and coal productsRegulation 46Z19 Acquisition of coal and coal productsRegulation 46Z20 Supply and delivery of coal and coal productsRegulation 46Z21 Technical assistance relating to coal and coal productsRegulation 46Z22 Financial services and funds relating to coal and coal productsRegulation 46Z23 Brokering services relating to coal and coal productsChapter 4L Liquefied natural gas (regs. 46Z24-46Z29)Regulation 46Z24 InterpretationRegulation 46Z25 Import of liquefied natural gasRegulation 46Z26 Acquisition of liquefied natural gasRegulation 46Z27 Technical assistance relating to liquefied natural gasRegulation 46Z28 Financial services and funds relating to liquefied natural gasRegulation 46Z29 Brokering services relating to liquefied natural gasChapter 4M Russia's vulnerable goods (regs. 46Z30-46Z33)Regulation 46Z30 Russia's vulnerable goodsRegulation 46Z31 Technical assistance relating to Russia's vulnerable goodsRegulation 46Z32 Financial services and funds relating to Russia's vulnerable goodsRegulation 46Z33 Brokering services relating to Russia's vulnerable goodsChapter 5 Exports and imports, and related activities, in relation to non-government controlled Ukrainian territory (regs. 47-53A)Regulation 47 Imports from non-government controlled Ukrainian territoryRegulation 48 Export of infrastructure-related goods to non-government controlled Ukrainian territoryRegulation 49 Supply and delivery of infrastructure-related goodsRegulation 50 Making infrastructure-related goods availableRegulation 51 Technical assistance relating to infrastructure-related goodsRegulation 52 Financial services and funds relating to infrastructure-related goods etc.Regulation 53 Brokering services: non-UK activity relating to infrastructure-related goods and goods from non-government controlled Ukrainian territoryRegulation 53A Application of prohibitions and requirements in Chapter 2 of Part 5 to non- government controlled Ukrainian territoryChapter 6 Other services relating to non-government controlled Ukrainian territory (reg. 54)Regulation 54 Prohibition on providing certain services relating to non-government controlled Ukrainian territoryChapter 6A Internet services (reg. 54A)Regulation 54A Preventing provision of internet services to or for the benefit of designated personsChapter 6B Professional and Business Services (regs. 54B-54D)Regulation 54B Interpretation of this ChapterRegulation 54C Professional and business servicesRegulation 54D Legal advisory servicesChapter 7 Further provision (regs. 55-56)Regulation 55 Circumventing etc. prohibitionsRegulation 56 DefencesPart 6 Ships (regs. 57-57L)Regulation 57 Crimean ports direction, Donetsk ports direction or Kherson and Zaporizhzhia ports directionRegulation 57A Prohibition on port entryRegulation 57B Directions prohibiting port entryRegulation 57C Movement of shipsRegulation 57D Detention of shipsRegulation 57E Registration of ships in the United KingdomRegulation 57F Specification of shipsRegulation 57G Notification and publicity where specification power usedRegulation 57H Directions under this Part: generalRegulation 57L Interpretation of Part 6Part 6A Aircraft (regs. 57J-57O)Regulation 57J Movement of aircraftRegulation 57K Directions under regulation 57JRegulation 57L Directions under regulation 57J: supplementaryRegulation 57M Registration of an aircraft in the United KingdomRegulation 57N OffencesRegulation 57O Interpretation of Part 6APart 7 Exceptions and licences (regs. 58-69)Regulation 58 Asset-freeze etc.: exceptions from prohibitionsRegulation 58A Asset-freeze etc.: exception from prohibitions for required paymentsRegulation 59 Exceptions relating to loans and credit arrangementsRegulation 59A Exceptions relating to processing paymentsRegulation 60 Exceptions relating to investments in relation to non-government controlled Ukrainian territoryRegulation 60ZZA Exceptions relating to investments in relation to RussiaRegulation 60ZZB Exceptions relating to trust servicesRegulation 60ZA Trade: exceptions relating to non-government controlled areas of the Donetsk and Luhansk oblastsRegulation 60A Trade: exceptions in relation to personal effects etc.Regulation 60B Trade: exceptions in relation to consumer communication devices and software updatesRegulation 60C Trade: exceptions in relation to aircraft and vesselsRegulation 60D Trade: exception relating to the safety of aircraft and shipsRegulation 60DA Trade: exceptions relating to professional and business servicesRegulation 60DB Trade: exceptions relating to legal advisory servicesRegulation 60E Trade: exceptions in relation to maritime goods and maritime technologyRegulation 60F Trade: exceptions in relation to banknotesRegulation 60G Trade: exception in relation to certain goods consigned from RussiaRegulation 60GA Trade: exception in respect of the acquisition of iron and steel products and metalsRegulation 60GAA Trade: exception in respect of iron and steel products, relevant processed iron or steel products and metals exported from Russia before the relevant dayRegulation 60GAB Trade: exception relating to ancillary services relating to acquisition when iron and steel products are in third countriesRegulation 60GB Trade: exception in respect of the acquisition of Schedule 3DA revenue generating goodsRegulation 60GC Trade: exception in respect of the acquisition of diamonds and diamond jewelleryRegulation 60H Trade: exception in relation to oil and oil productsRegulation 60HA Trade: exception in relation to maritime transportation of certain oil and oil productsRegulation 60I Trade: exceptions in relation to Energy-related GoodsRegulation 61 Trade: exception for emergencies in certain casesRegulation 61ZA Trade: exception for humanitarian assistance activity in non-government controlled areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblastsRegulation 61A Ships: exceptions from prohibition on port entryRegulation 61B Aircraft: exceptions from prohibitionsRegulation 62 Exception relating to trade restrictions in relation to non-government controlled Ukrainian territoryRegulation 62A Exception for authorised conduct in a relevant countryRegulation 63 Exception for acts done for purposes of national security or prevention of serious crimeRegulation 64 Treasury licencesRegulation 64A Director disqualification licencesRegulation 65 Trade licencesRegulation 65A Aircraft licencesRegulation 66 Licences: general provisionsRegulation 67 Finance: licensing offencesRegulation 67A Director disqualification: licensing offencesRegulation 68 Trade: licensing offencesRegulation 68A Aircraft: licensing offencesRegulation 69 Section 8B(1) to (3) of Immigration Act 1971: directionsPart 8 Information and records (regs. 70-79)Regulation 70 Finance: reporting obligationsRegulation 70ZA Finance: reporting obligations for required paymentsRegulation 70A Designated persons: reporting obligationsRegulation 71 "Relevant firm"Regulation 72 Finance: powers to request informationRegulation 73 Finance: production of documentsRegulation 74 Finance: information offencesRegulation 75 Trade: application of information powers in CEMARegulation 76 General trade licences: recordsRegulation 77 General trade licences: inspection of recordsRegulation 77A Internet services: power to request information and produce documentsRegulation 77B Internet services: information offencesRegulation 78 Disclosure of informationRegulation 78A Finance: disclosure to the TreasuryRegulation 79 Part 8: supplementaryPart 9 Enforcement (regs. 80-88D)Regulation 80 Penalties for offencesRegulation 81 Liability of officers of bodies corporate etc.Regulation 82 Jurisdiction to try offencesRegulation 83 Procedure for offences by unincorporated bodiesRegulation 84 Time limit for proceedings for summary offencesRegulation 85 Trade enforcement: application of CEMARegulation 86 Trade offences in CEMA: modification of penaltyRegulation 87 Application of Chapter 1 of Part 2 of Serious Organised Crime and Police Act 2005Regulation 88 Monetary penaltiesRegulation 88A OFCOM: power to impose monetary penaltiesRegulation 88B OFCOM: monetary penalties: procedural rightsRegulation 88C Treasury: power to impose monetary penaltiesRegulation 88D Treasury monetary penalties: procedural rightsPart 10 Maritime enforcement (regs. 89-94)Regulation 89 Exercise of maritime enforcement powersRegulation 90 Maritime enforcement officersRegulation 91 Power to stop, board, search etc.Regulation 92 Seizure powerRegulation 93 Restrictions on exercise of maritime enforcement powersRegulation 94 Interpretation of Part 10Part 11 Supplementary and final provision (regs. 95-103)Regulation 95 NoticesRegulation 96 Article 20 of the Export Control Order 2008Regulation 97 Trade: overlapping offencesRegulation 97A Disapplication of Banking Act 2009 requirement to recognise third-country resolution actionsRegulation 98 Revocations of relevant retained EU lawRegulation 99 Other revocations and amendmentsRegulation 100 Transitional provision: Treasury licencesRegulation 101 Transitional provision: trade licencesRegulation 102 Transitional provision: pending applications for trade licencesRegulation 103 Transitional provision: prior obligationsSchedulesSchedule 1 Rules for interpretation of regulations 7(2) and 16(7)Schedule 2 Persons named in relation to financial restrictionsSchedule 2A Critical-industry goods and critical-industry technologySchedule 2A, Part 1 InterpretationSchedule 2A, Part 1A Special materials and related equipmentSchedule 2A, Part 1B Material processingSchedule 2A, Part 2 ElectronicsSchedule 2A, Part 3 ComputersSchedule 2A, Part 4 Telecommunications and information securitySchedule 2A, Part 5 Sensors and lasersSchedule 2A, Part 6 Navigation and avionicsSchedule 2A, Part 7 MarineSchedule 2A, Part 8 Aerospace and PropulsionSchedule 2A, Part 9 Miscellaneous itemsSchedule 2B Consumer communication devicesSchedule 2C Aviation and space goods and technologySchedule 2D Oil refining goods and technologySchedule 2D, Part 1 (para. 1)Schedule 2D, Part 2 (paras. 2-5)Schedule 2E Quantum computing and advanced materials goods and technologySchedule 2E, Part 1 (para. 1)Schedule 2E, Part 2 (paras. 2-12)Schedule 3 Energy-related goods and infrastructure-related goodsSchedule 3, Part 1 General (para. 1)Schedule 3, Part 2 Energy-related goods (paras. 2-3A)Schedule 3, Part 3 Infrastructure-related goods (paras. 4-5)Schedule 3A Luxury goodsSchedule 3A, Part 1 (para. 1)Schedule 3A, Part 2 (paras. 2-23)Schedule 3B Iron and steel productsSchedule 3B, Part 1 (para. 1)Schedule 3B, Part 2 (para. 2)Schedule 3B, Part 3 Specified products for the purposes of Part 3 (para. 3)Schedule 3B, Part 4 Specified products for the purposes of Part 4 (para. 4)Schedule 3BA MetalsSchedule 3BA, Part 1 Interpretation (para. 1)Schedule 3BA, Part 2 Specified products for the purposes of this Schedule (para. 2)Schedule 3C Defence and Security Goods and Defence and Security TechnologySchedule 3C, Part 1 PreliminarySchedule 3C, Part 2 Interception and monitoring goods and interception and monitoring technologySchedule 3C, Part 3 Internal repression goods and internal repression technologySchedule 3C, Part 4 Chemicals and equipmentSchedule 3D Revenue generating goodsSchedule 3DA Revenue Generating GoodsSchedule 3DA, Part 1 InterpretationSchedule 3DA, Part 2Schedule 3DA, Part 3Schedule 3E G7 dependency and further goodsSchedule 3E, Part 1 General (paras. 1-1A)Schedule 3E, Part 2 G7 dependency and further goods (paras. 2-2A)Schedule 3E, Part 3 Additional G7 Dependency and Further Goods (para. 3)Schedule 3E, Part 4 Further goods with potential military and industrial uses (para. 4)Schedule 3F Oil and Oil ProductsSchedule 3F, Part 1 General (para. 1)Schedule 3F, Part 2 Oil and Oil Products (para. 2)Schedule 3G Gold and Products Related to GoldSchedule 3G, Part 1 General (para. 1)Schedule 3G, Part 2 (paras. 2-3)Schedule 3G, Part 3 (para. 4)Schedule 3GA Diamonds and diamond jewellerySchedule 3 GA, Part 1 GeneralSchedule 3 GA, Part 2 DiamondsSchedule 3 GA, Part 3 Diamond jewellerySchedule 3H Coal and Coal ProductsSchedule 3I Russia's vulnerable goodsSchedule 3J Professional and business servicesSchedule 4 Persons named in relation to dual-use items restrictionsSchedule 5 Treasury licences: purposesSchedule 5, Part A1 Interpretation (para. A1)Schedule 5, Part 1 Asset-freeze etc. (paras. 1-9D)Schedule 5, Part 1ZA Divestment etc. (paras. 9DA-9DC)Schedule 5, Part 1ZB Insolvency (para. 9DD)Schedule 5, Part 1A Loans and credit arrangements (paras. 9E-9J)Schedule 5, Part 1B Correspondent banking relationships and processing payments (paras. 9K-9O)Schedule 5, Part 1C Processing payments (paras. 9P-9TA)Schedule 5, Part 1D Foreign exchange reserve and asset management services (paras. 9U-9Y)Schedule 5, Part 2 Investment in non-government controlled Ukrainian territory (paras. 10-13)Schedule 5, Part 3 Investments in relation to Russia (paras. 14-20)Schedule 5, Part 3A Trust services (paras. 20A-20I)Schedule 5, Part 4 Maritime transportation of certain oil and oil products (para. 21)SignatureExplanatory NoteExplanatory Memorandum
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Version status: In force | Document consolidation status: Updated to reflect all known changes
Version date: 15 July 2022 - onwards
Regulation 60F Trade: exceptions in relation to banknotes
(1) Subject to paragraph (2), the prohibitions in Chapter 4E of Part 5 do not apply to the making available, supply, export or delivery of banknotes where the making available, supply, export or delivery is necessary for the personal use of natural persons travelling to Russia or members of their immediate families travelling with them.
(2) The exception in paragraph (1) applies only to banknotes up to the value of £10,000 or its equivalent in any official currency of the European Union.
(3) The prohibitions in Chapter 4E of Part 5 do not apply to the making available, supply, export or delivery of banknotes where the making available, supply, export or delivery is necessary for the official purposes of diplomatic missions, consular posts or international organisations in Russia enjoying immunities in accordance with international law.
(4) The prohibitions in Chapter 4E of Part 5 do not apply to anything done by a person who did not know and had no reasonable cause to suspect that the banknotes were ultimately -
(a) to be exported, supplied, delivered or made available to a person connected with Russia; or
(b) for use in Russia.