Government announces advertising sanctions on Russia

Update, 16 December 2022: A Statutory Instrument (SI) has been laid in Parliament to deliver the Government’s announcement of 30 September to ban the UK’s export of professional services to Russia. The legislation introduces a ban on the export of professional services including advertising services, architectural and engineering services, auditing services, and IT consultancy and design services. The SI came into force today (Friday 16 December) at 00:01am. 

The legislation applies to the direct or indirect provision of advertising services to persons connected with Russia - namely individuals or an association of individuals who are ordinarily resident in Russia or located in Russia, or persons other than individuals incorporated or constituted under the law of Russia, or which are domiciled in Russia. 

The definition of ‘advertising services’ for the purposes of the legislation includes the planning, creation and execution services of all or part of advertising campaigns; direct mail advertising and the provision of advertising space or time (both on commission and not on commission) such as the sale of advertising space in print media, TV/radio advertising, and internet advertising space; and other advertising services such as aerial advertising services and the delivery services of free samples and other advertising material.   

There will be a winding down exception to the advertising sanctions until 15 March 2023. This means that if UK service providers entered into contracts before 16 December 2022, they can honour these until 15 March 2023. After this date, the exception will not apply. You can find more information in Amendment 14.  

The SI is supported by statutory guidance - you can access full details of this action and guidance here. You can also find useful resources and support at the bottom of this article.   

October 2022: The sanctions, which the UK Government says are targeted at vulnerable areas of the Russian economy, include prohibitions on advertising services, IT consultancy, architectural services, engineering services, and transactional legal advisory services for certain commercial activity. The export of almost 700 goods from the UK to Russia are also being banned.

This means that anyone providing any advertising or marketing services to Russia, or trading in these services with Russia, will be in breach of sanctions. Planned timings are for the sanctions to be introduced into Parliament by Statutory Instrument in November, which will come into effect in December. There will be a six month period following this for companies to ‘wind down and withdraw’, with sanctions fully effective from around May 2023. Our advice to IAB UK members is therefore to urgently review your current operations in line with Government’s statutory guidance outlined in the resource below. 

According to Government guidance, the prohibitions and requirements imposed by the trade sanctions apply within the territory of the United Kingdom (UK) (including Northern Ireland) and in relation to the conduct of all UK persons wherever they are in the world. This includes all companies established in any part of the UK, and branches of UK companies operating overseas.

Commenting on the sanctions, Foreign Secretary James Cleverly said: “The UK utterly condemns Putin’s announcement of the illegal annexation of Ukrainian territory. We will never recognise the results of these sham referendums or any annexation of Ukrainian territory.

“The Russian regime must be held to account for this abhorrent violation of international law. That’s why we are working with our international partners to ramp up the economic pressure through new targeted services bans.”

Helpful resources for companies involved in the provision or trade of advertising services include:

• The Government’s statutory guidance on Russian sanctions
• Government guidance on the import and export restrictions that apply due to sanctions for UK companies when trading with Russia
• If you have a specific enquiry relating to sanctions, you can use the Government’s dedicated online service here, or call 0300 303 8955