Government Sanctions on Advertising Exports Come into Force Against Russia

The Government has announced via a Statutory Instrument that, from 00.01 16 December 2022, it will prohibit the export of advertising services, alongside some other professional services, to Russia.   

As the industry’s trade body, we fully support these measures, as well as the decision of many companies who have already ceased trading with Russia.  

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.   

Today’s announcement follows the Government’s previous announcement at the end of September in which it set out its intention to extend the list of export service sanctions to Russia that were already in place, including PR services.  

You can find the Government’s press release here which includes a full list of other professional services within the scope of the sanctions. The Advertising Association commented on this at the time, which you can find here. 

Below is a summary of our understanding of the sanctions and their applicability to advertising services. This is not intended to be legal advice – if you feel the sanctions apply to you, we recommend seeking your own legal advice.  

The scope of the advertising sanctions:  

The legislation will apply to the direct or indirect provision of advertising services to Russia or persons connected with Russia.  

 Code 836 of the 2002 Central Product Classification is being used to define advertising services to which the export sanctions apply.

This covers:  

a) Planning, creating and placement of advertising services;  

b) Purchase or sale of advertising space or time, on commission;  

c) Sale of advertising space in print media (except on commission);  

d) Sale of TV, radio advertising time (exception on commission);  

e) Sale of internet advertising space (except on commission);  

f) Sale of other advertising space or time (except on commission); and  

g) Other advertising services.  

Licences :

Licences may be issued for certain trade activities that would otherwise be prohibited by the sanctions. However, these activities are very limited. More information can be found here.  

  Helpful information:  

• The Statutory Instrument giving effect to the latest sanctions  
• The applicable Regulations and Guidance (both to be updated shortly)  
• Parliament published a research briefing which provides a consolidated and brief overview of the Russian sanctions regime, including the ban on exports of certain professional services (see pages 25, 26). This document was last updated on 16th November – we expect that this will be updated again in time.