(9 months, 2 weeks ago)
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The Minister of State, Foreign, Commonwealth and Development Office (Anne-Marie Trevelyan)
I beg to move,
That the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (SI, 2023, No. 713), dated 27 June, a copy of which was laid before this House on 29 June, be approved.
The regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019. The instrument was laid on 29 June 2023 under powers in the Sanctions and Anti-Money Laundering Act 2018. The measures in the instrument, which entered into force on 30 June 2023, have been co-ordinated with our international partners, while refining the approach to accommodate the particular circumstances of the UK’s legal sector. By restricting access to additional services from the UK, they will contribute to increasing the pressure on Putin for waging his illegal and brutal war against Ukraine. The measures place further constraints on the Russian economy, and therefore Putin’s war machine. They add force to the largest, most substantial package of economic sanctions that Russia has ever faced.
The instrument delivers on the commitment made by the UK Government to ban legal advisory services on specified commercial activities. That will further hamper the ability of Russian businesses to operate internationally. The legislation will make it illegal for any person working in the UK, as well as all British nationals working abroad, to advise on or facilitate certain commercial activities that would be sanctioned by the UK Government if they involved a British national or entity, or were taking place in the UK. In practice, that will make it harder for Russia to benefit from the UK’s world-class legal expertise. That goes beyond prohibitions already in place, which cover a range of professional services, including accountancy, architecture and management consultancy. This latest measure demonstrates our determination to ratchet up pressure on Putin for continuing his illegal war.
Although the legislation will close down opportunities for Putin’s associates and supporters to benefit commercially from the UK’s legal expertise, it is important that we ensure that legal services can continue to be provided where they contribute to upholding the rule of law and compliance with our sanctions framework. By protecting the fundamental right to legal representation, we distinguish ourselves from Putin’s oppressive regime. By ensuring that legal advice can continue to be provided for the purposes of compliance with our sanctions framework, we enhance the effectiveness of our regulations and intensify the pressure on Putin.
Legal professionals are under a strict obligation to ensure that their services support their clients to be sanctions-compliant, and do not stray into enabling them to circumvent restrictions. It has become apparent, however, that the legislation can be interpreted as having the unintended consequence of prohibiting persons in the UK and British nationals abroad from providing legal advice to clients seeking to comply with the sanctions regimes of our international partners. It is not the intent of these regulations to prohibit that type of legal service. UK lawyers should be able to support their clients to be sanctions-compliant beyond UK law as we work closely with our allies to tighten the net on Russia’s economy.
We have looked at this issue thoroughly and, as an immediate response, we are working across Government and alongside representatives of the legal sector to implement a general licence that will make it clear that that type of activity can continue.
Sir Chris Bryant (Rhondda) (Lab)
The Minister is addressing a point that the Law Society has made to quite a few of us, and I guess quite a few of us will be referring to it later in the debate. If this had been primary legislation, we would have tabled an amendment. Is it not normally better for us to do all the scrutiny of this kind of work on primary rather than secondary legislation? Then we can always help the Government to get it right first time.
Anne-Marie Trevelyan
The hon. Gentleman is generous as ever in offering to assist us to make progress. I hope that, as we bring in the secondary legislation, it will be another step towards tightening the pressure on those who would wish to use legal representation for the wrong things.
Sir Robert Neill (Bromley and Chislehurst) (Con)
I welcome the Minister’s willingness to engage on the general licence; it is very important to the Law Society, and for good and sound reasons. We all share the policy objective, so will she perhaps agree to meet, at both official and ministerial level, with representatives of the Law Society so we can thrash out the exact detail and get it right?
Anne-Marie Trevelyan
I will be happy to do so. I know that we aim to have this in place in the coming days. As I said, we are working closely with the legal sector and are grateful for its constructive engagement on this important issue. I am happy to commit to my officials meeting the Law Society to hear its particular concerns and indeed, I have no doubt, offers of its views on how we can make the scheme as effective as possible.
Once we have issued the licence, we will consider whether amendments to the SI to address the issue are appropriate and necessary. We will do that in conjunction with the legal sector and bring such amendments forward, if needed, at the earliest opportunity.
As with all other sanctions, this latest package has been developed in co-ordination with our international partners. We will continue to work with the legal community to monitor the effects of the legislation to ensure that it is achieving its objectives. We will also continue to co-ordinate with our international allies to identify and address any gaps or loopholes that emerge in our respective sanctions regimes.
To conclude, this latest measure demonstrates our determination to target those who participate in or facilitate Putin’s illegal war of choice. Through our sanctions regime and those of our allies, Russia is increasingly isolated, cut off from western markets, services and supply chains. Key sectors of the Russian economy have taken a significant hit and its economic outlook is bleak. The UK Government will use actions to intensify the military and economic pressure on Russia until Putin ends his brutal invasion of Ukraine. We welcome the clear and continued cross-party support for this action and for the sanctions regime. I commend the regulations to the House.
Stephen Doughty (Cardiff South and Penarth) (Lab/Co-op)
I thank the Minister for setting out the measures we are debating. As the House rises for recess later this week, I am pleased we are able to meet before that, not only to debate new and welcome sanctions measures, but to reiterate our unwavering commitment to and solidarity with Ukraine, its people and its sovereignty. The NATO Vilnius summit last week underscored the strength of feeling across our diplomatic and military alliances that we must stand with Ukraine in all measures—economic, military, humanitarian and diplomatic—until this war is won and provide the guarantees that it needs.
I am also pleased that the House had the opportunity last week to explore and debate the Foreign Affairs Committee’s report on illicit finance, the Government’s response, the need to crack down on dirty Russian money within our economy and the serious problems we have had with London as a location for that and the whole ecosystem that has facilitated it over many years. On these measures, I want to make it clear, as I have on many occasions, that we will support the Government where we think they have got things right on sanctions and we will not seek to divide this House on this measure.
However, I do have some questions for the Minister. More than 500 days into this conflict, it should not be potentially lawful for a UK legal services provider to support commercial activities that advance Russian state interests and the interests of those who support the egregious and barbaric war in Ukraine, just because said activity does not have a sufficiently tangible connection to the UK, due to the territorial application of the Russia (Sanctions) (EU Exit) Regulations 2019. It must be the case that no UK person, or person in the UK, can provide legal advisory services to an activity that would be prohibited under our regime.
I hope the Minister can say why it has taken so long to bring forward this measure. I accept that the sanctions regime is a constantly evolving feast, and we have had this debate many times, but that is obviously a significant potential risk, so I hope she can explain what has happened with the timing.
I welcome the Minister’s clarification regarding a general licence and the discussions that will be had. I know that other right hon. and hon. Members have expressed, and will express, concerns about the ability to access legal advice for positive purposes, if I may put it that way. On the other hand, I have some questions regarding licences and exemptions that have been granted in the past, including for access to legal services, and the ministerial oversight of those.
One particular case was in January this year, when it came to light that the Treasury had issued special licences that allowed Prigozhin, the leader of the brutal Wagner Group, exemptions and licences to acquire legal support—in fact, I believe it was flown to him in Russia at the time—to sue his critics here in the UK. That is obviously completely unacceptable. I hope that the Minister can explain, given the questions that I and others have asked about that, what role Ministers are now taking in the issuing of exemptions and licences.
The Minister will be involved in developing the general licence that she talked about for legitimate purposes, but at the other end of the spectrum there are an awfully large number of licences that have been granted. Perhaps she could write to me and to the House with a full list of licences and exemptions that have been granted and for what purposes, and clarify whether Ministers, particularly in her Department, now have oversight of those, or whether that is just being done by officials. These are significant matters and we do not want to see anything sneak through that is going to facilitate or aid Russian activities.
I would also like the Minister to explain how the Office of Financial Sanctions Implementation is monitoring the utility of the various exemptions issued under the sanctions regime, and whether they are enhancing the regime or potentially, in some instances—I hope this is not the case—undermining it. The OFSI should be undertaking constant reflection on and refinement of the regime and ensuring that, while we have the strongest text for the sanctions, their actual application is being done in the most effective way to tackle the aggressor in this case.
While I am on the subject of exemptions and loopholes, in the last Committee debate that we had on such measures the Minister committed to write to me regarding some serious concerns I raised about third countries being used to avoid our sanctions regimes in a number of product areas. That would be interesting in terms of the services sector and the legal services we are referring to in this debate, but it also applies to a number of goods. I hope she can write to me before the recess with answers to those questions, because they are significant.
As the House is about to rise for recess, I reiterate the position of the official Opposition, the Labour party, to work with the Government in support of Ukraine, its security, its prosperity and its future, and to co-operate on measures against Russia and those who would aid and abet Putin’s regime. We must continue to do that and to see that Russia and all those who support Putin lose. Our sanctions regimes and the way they are applied are crucial to that. We must never again allow London to be part of an ecosystem of lawyers, accountants, company formation agents and others who have facilitated the very people behind the Russian regime and are ultimately aiding and abetting Putin.
Madam Deputy Speaker (Dame Eleanor Laing)
I call the Chair of the Justice Committee.
Sir Robert Neill
I welcome the tone and approach of the Minister’s remarks, and I fully understand and support the policy objectives of the regulation, as does every decent lawyer in this country. For completeness, I refer the House to my entry in the Register of Members’ Financial Interests. We want the UK legal system to retain its reputation as an able, efficient and honest jurisdiction, which it is. However, it is important that we get the detail right, so, with apologies from one lawyer to another, Madam Deputy Speaker, you will know that, if I say the detail matters sometimes, there may be a little detail to raise with the Minister in the context of her very welcome assurance that she will meet, and have officials meet, to discuss what comes next. I appreciate that the regulations have—rightly—had to be developed at pace, and that we have sought to be aligned with our allies, but there are some bits to which further attention needs to be paid.
I am grateful to the Law Society of England and Wales for the briefing that it has sent to a number of hon. Members. Given that we all endorse the policy objective that Russia must never be allowed to gain from its barbaric and disgraceful invasion of Ukraine, and that Russian entities must never be able to gain from it, we must do it in a way that retains the ability of UK-based international law firms to advise, with the highest level of professionalism, on the way in which clients may wish to divest themselves of interests in Russia, for example, or on the risks or otherwise of potential transactions that might involve an element of a Russian entity of one kind of another. It is in everybody’s interest that they are able to do that, but I am concerned, as is the Law Society, that the wording of the regulations, however well intended—I think that they are totally well intended—may have the unintended effect of limiting it.
In particular, there is concern that the very broad language of the regulations is broader than that of our counterparts in the United States and the EU in terms of limitations. The Minister is absolutely right that we should align, so that is something we perhaps now need to revisit. Licensing may be one way, and a revised statutory instrument may be another—perhaps the two go together—to align the language
I will set out one or two of the practical consequences. The language of new paragraph 8A(1)(a)(i) to schedule 3J —I think I have got that right; it is all in the detail, Madam Deputy Speaker—is quite important. Essentially, it prohibits advice that facilitates or enables activity that would be prohibited if it were conducted in the UK or by a UK person—let us call it “UK-prohibited activity”. It then goes on to prohibit any advice in relation to, or in connection with, UK-prohibited activity. In that context, “advice” includes the provision of legal advice that involves—here is the rub—
“the application or interpretation of law”.
Well, that is pretty much what lawyers do, hopefully: they advise people about the application and interpretation of the law. Early advice is the best way to prevent people from getting into legal problems and prevent needless litigation. There is, I accept, an exemption covering advice, but, as the Minister will know, there is real concern that the exemption is narrowly drawn—too narrow, I would argue.
On the face of it, that means in practical terms that British companies cannot get advice from English and Welsh lawyers on whether their activity will comply with international sanctions regimes, for example. They could go to American lawyers for that. Many American-based law firms have entered the UK legal markets. It would be a bizarre situation if one could not go to the UK law firm for that advice but could go to the New York office of the American law firm. I do not think that was the intention behind the policy. We must ensure that the language reflects the intention.
In the same way, if, for example, an international company wants to know whether a specific activity that it is contemplating for perfectly good and legitimate commercial purposes is prohibited by UK, EU or US sanctions—all of which vary somewhat—the UK lawyers can answer on whether or not that activity is prohibited by UK sanctions, but once the lawyer has said, “Yes it is,” they are not then allowed to advise on whether it is prohibited by EU or US sanctions. That cannot be a sensible or practical approach, and it cannot be what the Government actually want to achieve.
The whole advantage of UK international law firms is, of course, that they have many multidisciplinary lawyers and people qualified in many jurisdictions. Our strength is that people come to us because we can advise on a range of law in a range of jurisdictions. At the moment, however, a lawyer would be committing an offence if they took the obvious step. Instead, they have to say, “Okay, it is illegal in the UK, but I cannot tell you whether it is illegal in the EU or the US.” That is clearly not a situation that anybody wants to see. The difficulty is that the language does not reflect the intention. Surely, giving such advice does not enable or facilitate unlawful activity. It allows a company to know whether, if it does the activity, it might infringe the law, and whether the law is applicable to it. The language does not reflect that policy intention as it stands.
Another example is that the advice exception in regulation 60DB(3) is limited to advice on compliance with sanctions, and not to other forms of compliance advice. The logic is that one seeks advice from one’s lawyer on the whole range of potential legal risks that one might run in taking a particular course of commercial activity. The facts will be the same, and may raise questions about sanctions compliance, but as it stands—this is of real concern to the Law Society—a UK lawyer could supply the client only with advice on sanctions, not on whether they comply with other criminal offences. The strict wording of that regulation would, on the face of it, criminalise lawyers giving advice on whether that same form of action falls foul not just of sanctions, but of anti- money-laundering, anti-bribery and export control laws.
Surely we want any UK lawyer to be able to give one-stop-shop, rolled-up advice on all the legal risks that might arise from that activity, but at the moment, once they have established the first part—that it falls foul of the UK sanctions regime—they cannot go on and do the obvious and common sense thing of saying, “And, by the way, you also fall foul of this, that and the other.” That cannot be the intention, but as it stands, that is where we could end up.
That is why the general licence is, in the short term, so important. Individual licences, which were referred to by the shadow Minister, the hon. Member for Cardiff South and Penarth (Stephen Doughty), have been tried in the past. Not only is there difficulty in how effective they are in policy terms, but there are practical difficulties as well.
That is where advice about disinvestment comes in, for example, because UK companies might very properly want to withdraw from transactions involving Russian entities or individuals. Surely we want UK lawyers to be able to advise them fully and frankly on how best to disinvest. But if they have either to be caught by the risk of a criminal sanction or to get an individual licence, we know that Russia—not a rule-of-law country, to put it mildly—is well able to take actions to sequester property and prevent the return of assets to British nationals and British companies in a way that we would never countenance in this House. When dealing with people of that kind, we do not have that leisure, frankly. Once a company has taken the decision to disinvest, they want to get the assets out quickly. Waiting for an individual licence would not make that possible. That is why a general licence, rather than individual licences, is important.
That is why it is important to sit down with the Law Society, hear the lived experience of law firms in the UK, and get the regime right so that it sticks. Regrettably, this war, and therefore the sanctions, may go on for longer than any of us would wish—however long it takes to get Ukraine its freedom and to get rid of that wretched regime in the Kremlin—so we must have something that will stand the test of time. That is why I am so anxious for the Minister to engage in detail with the Law Society about this.
I have a final example. We could have a situation in which an EU firm based in the UK can go to their Paris office for advice on different terms of legal trade from the UK office. That cannot be to the advantage of the UK legal system, and it does not help us to align with our allies.
I have greatly shortened the briefing that I received because everyone wants to get away for the summer recess. I hope I have flagged up some serious practical points. There is an issue of principle, but the detail matters. If we can work together to get that right, I hope we can come back to the House after the recess with the general licence and a revised approach to the SI, which will give us a permanent system through which to bear down on the evil of the Russian regime while enabling British lawyers, with their expertise, to play their part in that fight. At the moment, they would have one hand tied behind their back, which was not the Government’s intention.
Drew Hendry (Inverness, Nairn, Badenoch and Strathspey) (SNP)
It is always a pleasure to follow the knowledgeable hon. Member for Bromley and Chislehurst (Sir Robert Neill). Given his legal expertise, I can now take three pages out of the speech I was going to deliver, and I hope the Minister was listening.
This is a serious issue. For the Scottish National party, our stance has always been clear, unambiguous, and unwavering: we vehemently support the principles of democracy, peace, and the rule of law, and we unyieldingly oppose any entity or individual that would act to undermine those bedrock principles. It is worth recollecting the context here. The Russian invasion of Ukraine in February 2022 was a blatant breach of those principles and an affront to the international community. The unjust and unprovoked aggression caused immense pain, loss, and destruction to the people and the critical infrastructure of Ukraine.
There is much more that the UK Government could and should do. We have heard from the Labour spokesman about the lack of action, in my view, about Progozhin, and the issue of dealing with third countries. As we have just heard, the details are important. The issue needs to be properly scoped, and the detail needs to be agreed as quickly as possible. Speed has been lacking in delivering some of the sanctions that are so greatly needed.
It is in that context that we put our support behind the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023, which further the United Kingdom’s stance that Russia bears full responsibility for the damage it has wrought in Ukraine. This is not a matter of politics: it is a matter of basic human rights and justice. We believe that those who cause harm should be held accountable and be made to pay restitution. By supporting the regulations, we are not just voting for sanctions: we are voting, ultimately, for justice for Ukraine.
We note and support the provision for a defence under section 68(1) of the Customs and Excise Management Act 1979 relating to the prohibition on exportation of certain goods to non-government controlled areas. That thoughtful addition will ensure that sanctions do not inadvertently penalise innocent parties, and provides a fair balance in extraordinary circumstances. Again, we await the legal details.
Since the start of Putin’s invasion of Ukraine, the SNP has consistently backed the UK Government’s sanctions regime against the Kremlin. We see the regulations as a natural, necessary and meaningful extension, albeit more can and should be done. In conclusion, the SNP supports the regulations. We stand for justice, for peace, and for holding those accountable who disregard those values. We stand with Ukraine and will, as indicated, support the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023.
John Howell (Henley) (Con)
I want to comment briefly on the Minister’s remarks about international partners and our relationship with them. The Council of Europe recently held a summit in Reykjavik, which the UK attended, and we also signed the resulting declaration. The Council of Europe has always seen sanctions as a rule of law issue, because Russia has acted illegally in invading Ukraine. The Council of Europe has had a tremendously robust response, not least from me: I was the first member to call for Russia to be expelled from the Council.
The Reykjavik summit asked member states to support it on the rule of law issue, by bringing legislation to make sure that the changes happened. I am glad to see that we have done that, and we are making a very good change. I hope that the Minister will include the Council of Europe among the international partners with which she will maintain contact, because it has a vast amount of expertise. It is not just me, there are many distinguished members who have enormous expertise in dealing with Russia and these issues. I hope that she will both use that and feed into it, because there is a lot we can do—subject to what we have just heard—to set a model that other countries can use.
Sir Chris Bryant (Rhondda) (Lab)
It is a joy to follow the hon. Member for Henley (John Howell). Since we have been in valedictory mood today, with the Secretary of State for Defence earlier, it is a sadness that the hon. Gentleman will not be with us in the next Parliament. Obviously, I want Labour to take every seat in the land, so I would not want to go too far in that. None the less, the hon. Gentleman has been admirable in his work in the Council of Europe in this regard and on human rights generally across the continent. Our membership of the Council of Europe is an important part of the structure of human rights across Europe. It is one of the reasons I support our remaining in the European convention on human rights and adhering to the European Court of Human Rights, which I understand to be a necessary aspect of our membership.
John Howell
I reassure the hon. Gentleman that I hope to stay in the role for another year.
Sir Chris Bryant
Long may he persist.
I support the measure before us today. The Minister knows that I and other Members have campaigned for as robust a set of sanctions as possible. I have been critical sometimes of the processes we have used to get there. Oliver Bullough wrote a splendid book that lays out why it is important to deal not only with financial instruments but with some of the people who have effectively enabled others to bypass sanctions regimes and hide their money from prying eyes in the UK.
It was a joy to hear the extremely learned hon. Member for Bromley and Chislehurst (Sir Robert Neill), not least because he referred to “every decent lawyer”. I detected a characteristic wink at that point, because not every lawyer is decent, m’lud. I gently suggest—
Sir Robert Neill
I have prosecuted some less than decent lawyers over the years, so I take the hon. Gentleman’s point. But he knows just how good the English legal system is collectively, and I know he will want to recognise that.
Sir Chris Bryant
I have great admiration for lawyers, especially those who advise me, as is occasionally necessary—[Laughter.] It is a serious point: if the UK stands for anything in the world, it is the rule of law. The hon. Gentleman and I have often had to join cause on occasions when we have worried that the Front Benches have not quite seen things in exactly the same way as we do.
I will not rehearse all the arguments, which were laid out so beautifully for the hon. Gentleman and others in the Law Society’s note. He understood it better than I did. The important point is that all British businesses should be withdrawing from Russia. It is extraordinary that any British businesses are still doing significant business in Russia. I do not wish to make any partisan points, but I think it is still true that Infosys has a substantial presence and has not managed to wind down its presence in Russia. That is worrying. Mantrac is certainly still operating in Russia, and some of the money it has earned there will have made its way into its recent £5 million donation to the Conservative party. We should be doing more due diligence about these matters.
I do not understand how Unilever can still claim that it is only selling Magnum ice creams in Russia because they are an essential item. They might be an essential item for somebody who is going to watch the “Barbie” movie later this year—that sort of fits—but in all seriousness, I honestly do not think that Unilever should still have a significant presence, or any presence, in the Russian Federation. Its remaining there is a problem. I hope that the Minister will be able to respond to the point about British companies being able to advise on how to disinvest as fast as possible. If the regulations were to make that more difficult, that would be a bit of an own goal on our part.
I have some other, very minor, points to make. One is that the sanctions regime is now getting very complex. These are No. 3, the third regulations in this Session. I know that this Session of Parliament has gone on a bit—one could argue that the whole of this Parliament has gone on a bit, maybe a bit too long—but we are relying on lots of statutory instruments and secondary legislation. The amount of such legislation has grown enormously over the past 20 years, not just since 2010 but before then, and there is a danger that it is very difficult for lawyers to keep up with what the law is. Of course, there is no excuse for lawyers to say that they do not know what the law is, but none the less, these regulations came into force on 30 June—they are already in force. That is the problem with the way in which we are legislating these days. When there is a Labour Government, I hope that we will use secondary legislation much less frequently, because we need to be able to amend legislation on the Floor of the House or in Committee to make sure that Governments do not make silly mistakes.
I note the subtle difference in the exemption that exists for advice. Of course, advice can cover a multitude of sins and is sometimes designed to do so, but I note the subtle difference between the exemptions granted in the UK, those granted in the US and those granted in the EU. If I heard the Minister correctly, she attributed those to the different legal systems that exist in those jurisdictions. That may be true, but I would like her to expand on that and explain why it is necessary for us to make distinctions in that way. Otherwise, the point made by the hon. Member for Bromley and Chislehurst is absolutely right: an international law firm could just say, “All right, I’m popping over to Paris, Madrid, Berlin or wherever for the weekend, and we will do it from there.” That would be a mistake. I also think that sanctions need to be a stiletto blade, not a blunderbuss, if they are to be truly effective in peeling away support from Vladimir Putin within the Russian Federation.
In a previous debate on sanctions, I referred to the former leader of UKIP. Let me be absolutely clear: I have had no correspondence of any kind—electronic, in writing, or digital—with Coutts bank about him, or for that matter about anybody else, because I do not have many constituents who bank with Coutts. I have no idea why Coutts has closed his bank account, but I should have been more careful with the words that I used a year ago. The figure I gave was for his total income. I think he himself has stated that he was paid for his appearances on Russia Today, which is of course a part of the Russian state, and he has made clear his respect for Vladimir Putin as a nationalist. However, I do not think that the figure I gave was anywhere near the accurate figure, so I apologise if I have inadvertently misled the House. I had no intention of doing so, and I hope that puts the record straight. I had hoped that this afternoon’s debate was going to include a debate on the Procedure Committee’s report into allowing all Members of the House to correct the record, rather than just Ministers, but that option is not yet available to us. As such, Madam Deputy Speaker, I have rather stretched your generosity in making these comments.
Anne-Marie Trevelyan
I thank all hon. Members who have made contributions this afternoon. I will do my best to address the questions they have raised, and as ever, where I do not have the information to hand, I will ensure that I write to them.
This latest measure reflects the reality that legal advisory services can play a fundamental role in facilitating border trade and investment, and that by restricting those services, we will further constrain the Russian economy and Putin’s war chest. While we have worked to ensure that Russia cannot access our legal expertise in relation to certain commercial activities, we have not hindered work, but have helped to provide judicial rights and access to justice. We have also not hampered legal advice that facilitates compliance with our sanctions network and framework, and we are working to ensure that advice in relation to compliance with the sanctions laws of our international partners is also permitted.
I absolutely commit to write to the hon. Member for Cardiff South and Penarth (Stephen Doughty) about the questions he has raised, including his important point about third-party circumvention risks. Discussions and work are ongoing with a number of colleagues; I have been talking with colleagues internationally about how we tackle those risks and find tools to address the enforcement challenge they present.
As ever, my hon. Friend the Member for Bromley and Chislehurst (Sir Robert Neill) has brought his wisdom to the debate about this important piece of legislation. I will ensure that he and the Law Society are able to discuss their concerns about the detail of the general licence in the very near future, conscious—as a number of colleagues have said—of the timeframe over which we are keen to move it forward. He made the important point that access to legal advice should be taken early to reduce the risk of error or breach. We must ensure that the general licence will work in practice, providing the right support while constraining those who wish to abuse the system.
I put on record that the continued leadership of my hon. Friend the Member for Henley (John Howell) at the Council of Europe is hugely welcomed and appreciated by all Members across the House. I thank him for his offer of support and for sharing the expertise that sits in the Council of Europe. As we continue to work in what is a complex and, sadly, ever-changing and ever-developing environment, we continue to get ahead of those who wish to abuse the system.
Stephen Doughty
It was good to hear the Minister confirm again that she is going to work on the issues that have been raised about the general licence. However, can she say whether Ministers such as herself are actively involved in the issuing of all licences and exemptions in relation to our sanctions regime, or is it still just being done by officials without ministerial sign-off?
Anne-Marie Trevelyan
Obviously, the hon. Member would not expect me to discuss the detail of matters that are live and ongoing. However, we work as a team and across Government: while it is the Foreign, Commonwealth and Development Office that holds the pen, and it is me at the Dispatch Box today, the legislation, work, management and enforcement issues are covered across Whitehall. We all work together very closely on those issues, and as I say, it is a live and continually changing environment as we keep track of what we are trying to achieve. One part of that, of course, is ensuring that enforcement can be monitored. The commitment of £50 million following the integrated review refresh was an important part of that and it will help us build even stronger enforcement tools to ensure we make the most effective use of the sanctions we bring in.
This, Madam Deputy Speaker, is the latest edition of our package of sanctions. We will continue to use sanctions to keep up the pressure until Putin ends his horrific, senseless war and Ukraine is allowed its territories back to live peacefully once again.
Sir Chris Bryant
Will the Minister allow me to intervene before she sits down?
Sir Chris Bryant
I would just like to put on the record how much we respect and admire the team of roughly 150 people who work in the sanctions group. It is not easy work—it is tough to get it right—and they are magnificent. Is that in order?
Anne-Marie Trevelyan
I thank the hon. Gentleman for his kind and thoughtful intervention. They are an extraordinary team—they are working flat out all the time. Sadly, until such time as Putin loses this war, we will continue to work flat out to ensure that we have as many sanctions tools available to us as possible. In the meantime, I hope and trust that the House will support the regulations.
Question put and agreed to.
Resolved,
That the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (SI, 2023, No. 713), dated 27 June, a copy of which was laid before this House on 29 June, be approved.