Russia Sanctions Tracker - UK

General Trade Licence: Acquisition of Russian Metals - amendment

Press release

The LME has issued updated guidance and a new guidance note

The General Licence has been amended to reflect changes to the circumstances where metals, and warrants for metals, may be acquired in relation to their trade on global metals exchanges, and to the relevant reporting requirements and definitions.

The General Licence now permits the direct or indirect acquisition of a warrant on a global metal exchange by the persons described below, so far as otherwise prohibited by regulation 46IH(1)(a) of the Russia Regulations, provided that:

a) such persons do not cancel or withdraw (or request or order the cancellation or withdrawal of) such a warrant from a global metal exchange in order to take physical delivery of metal for their own account;

b) such persons do not change the location of the metal to which the warrant relates; and

c) the metal to which the warrant relates was produced before 23:59 on 12 April 2024.

The conditions in paragraph a) and b) do not apply where a person acquires a warrant in relation to metal which was under warrant on a global metal exchange as at 23:59 on 12 April 2024.

Where a person acquired a warrant which was issued before 23:59 on 12 April 2024, such a person is authorised to:

• cancel or withdraw (or request the cancellation or withdrawal of) that warrant from a global metal exchange in order to take physical delivery of the metal; and
• change the location of the metal to which the warrant relates.

The description of persons to whom the above applies remains unchanged: LME Clear Limited; the London Metal Exchange; global metal exchange members; and clients of global metal exchange members.

The amendments also introduce new record-keeping and reporting requirements.

The General Licence remains of indefinite duration.

General licence: Active Denizcilik and Beks Ships Transit to Port and Wind Down – amendment

[INT/2024/4576632]

The General Licence has been amended to remove the language prohibiting funds or economic resources from being made available for the benefit of any designated person.

General licence: Payments to Companies House – amendment

[INT/2023/3626884]

The General Licence has been amended to add the following permissions to the list of Permitted Payments:

• The payment of fees owed by or due from UK designated persons to Companies House for filing an Overseas Entity Update Statement in respect of entities on the Register of Overseas Entities.
• The payment of penalties owed by or due from UK designated persons to Companies House incurred as a result of failure to register as an entity on the Register of Overseas Entities or failure to provide an Overseas Entity Update Statement in respect of entities on the Register of Overseas Entities.

General licence: Active Denizcilik and Beks Ships Transit to Port and Wind Down

[INT/2024/4576632]

Publication Notice

 OFSI has issued a new General Licence which permits:

• insurers and other service providers to provide insurance and certain other services to Active Denizcilik for the purpose of allowing certain vessels managed by Active Denizcilik to reach their port of discharge or other safe port to discharge their cargo, and for payments to be made to insurers / service providers up to a certain amount in respect of the same; and
• the wind-down of any transactions involving Active Denizcilik (and relevant vessels) or Beks Ships Transit, provided that no funds or economic resources are made available to or for the benefit of any Designated Person.

"Active Denizcilik" means Active Denizcilik ve Gemi Isletmeciligi Anonim Sirketi (consolidated list group ID: 16428) (DP)
"Beks" means Beks Gemi Isletmeciligi Ve Ticaret Anonim Sirketi OR Beks Ship Management And Trading Joint Stock Company (consolidated list group ID: 16411) (DP)

Certain permissions in the General Licence are subject to reporting requirements. Please consult the General Licence for its full terms.

The licence took effect from 14:30 on 28 March and expires at 23:59 on 11 June 2024.

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Igor Viktorovich Makarov

A General Trade Licence has been granted which provides authorisation for Russian diamonds processed in a third country ("relevant processed diamonds") outside of Russia since before 1 March 2024, subject to the following conditions:

• the relevant processed diamond is equal to or larger than 1 carat;
• any diamond processed to produce the relevant processed diamond has not been located in Russia at any time beginning with 1 March 2024; and
• the relevant processed diamond has not been located in Russia at any time beginning with 1 March 2024.

This General Trade Licence took effect from 1 March 2024 and has no expiry date.

General Licence: Court Funds Office payments

[INT/2024/4398024]

Publication Notice

OFSI has issued a new General Licence which permits Persons who owe monies to a designated person as a result of a Court Order to pay these to the Court Funds Office and for the Court Funds Office to receive these payments.

This General Licence took effect from 29 February 2024 and has no expiry date.

 28 February 2024

(in force on 1 March 2024)

Trade restrictions – diamonds processed in a third country

(new Chapter 4JC, Regulations 46Z16Q – 46Z16U)

Introduction of a new prohibition on the import of "relevant processed diamonds", being diamonds which originate in Russia and have been processed in a third country. 

For the purposes of this restriction, "diamonds" means anything falling within:

• The following commodity codes:
  • 7102 10 (unsorted diamonds);
  • 7102 39 (non-industrial diamonds, other than unworked or simply sawn, cleaved or bruted); and 
• Both commodity code ex 7102 31 and the description "non-industrial diamonds, simply sawn, cleaved or bruted".

Includes a prohibition of the provision of associated technical assistance, financial services and funds and brokering services.

The prohibition takes effect on:

• 1 March 2024 in relation to any diamonds which are equal to or larger than 1 carat;
• 1 September 2024 in relation to any diamonds which are equal to or larger than 0.5 carats

OFSI has published guidance on the principles its licensing caseworkers follow to assess licence applications and refer to for a licensing decision to be made. Alongside this, it has published the frameworks that govern who makes a decision in regard to that licence application.

OFSI has also published a blog to explain in more detail the licensing process and principles. 

This guidance applies to all UK financial sanctions – it is not Russia-specific

General Licence: payments to Companies House

[INT/2023/3626884]

Asset freeze – additions

Press release

50 individuals and entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions. The list of those sanctioned includes:

• 14 individuals and entities linked to manufacturing munitions
• A number of foreign entities and individuals including a Turkish company and three Chinese companies
• Oil trader Niels Troost and his company Paramount Energy & Commodities SA
• Fractal Marine DMCC, Beks Ship Management, and Active Shipping, which carry on business in the Russian energy sector
• Arctic LNG 2 and associated individuals
• Two Russian diamond companies, OJSC Almazny Mir and JSC AGD Diamonds, and a number of individuals linked to Alrosa, Russia’s state-owned diamond company
• A number of Russian metals companies (Ural Mining and Metallurgical (UMMC), Samara Metallurgical Company and Kamensk-Uralskiy Metallurgicheskiy Zavod) and associated individuals

Belarus: Asset freeze – additions

Press release

2 entities have been added to the consolidated list and are now subject to an asset freeze:

• JSC Planar
• Precise Electro-Mechanics Plant

Guidance: Common High Priority Items List (Russia Regime) – update

Access the Common High Priority List

The UK's list has been now been expanded to include 5 new codes related to Computer Numerical Control (CNC) machines which are crucial to the manufacture and maintenance of vital military equipment.  

The Common High Priority List contains items that Russia is using in its weapons systems. It is composed of Western items critical to Russian weapons systems and its military development. They include electronic components such as integrated circuits and radio frequency (RF) transceiver modules and items that are essential for the manufacturing and testing of the electronic components and circuits retrieved from the battlefield.

Asset freeze – additions

Press release 

The Global Human Rights Sanctions Regulations 2020

6 individuals have been added to the consolidated list and are now subject to an asset freeze:

• Colonel Vadim Konstantinovich Kalinin
• Lieutenant Colonel Sergey Nikolaevich Korzhov
• Lieutenant Colonel Vasily Alexandrovich Vydrin
• Lieutenant Colonel Vladimir Ivanovich Pilipchik
• Lieutenant Colonel Aleksandr Vladimirovich Golyakov
• Colonel Aleksandr Valerievich Obraztsov

These individuals are responsible for the custody of Alexei Navalny in their positions as Head or Deputy Head of Arctic Penal Colony IK-3. They have been designated under the UK's Global Human Rights sanctions regime.

OFSI has updated its Russia Guidance FAQ by adding FAQ number 56, explaining when a designated person is required to report to OFSI under regulation 70A(5). 
A designated person must report to OFSI:

• when the value of their funds or economic resources, when taken together, has changed by an amount exceeding £10,000 compared with the previous report filed with OFSI. 
• if there has been a change to the nature or location of funds or economic resources where those funds or economic resources exceeds the value of £10,000. This also applies where multiple funds or economic resources of the same type taken together exceed £10,000.

OFSI has published updated guidance for the Maritime Services Ban and Oil Price Cap, to provide additional clarity and detail on the following:

• Attestations: The changes to the attestation model announced on 20 December 2023 will come into effect on 19 February 2024. The updated model requires 1) attestation forms to be provided on a per-voyage basis and 2) itemised ancillary costs to be recorded by Tier 1 entities and provided to Tier 2 and Tier 3A contractual counterparties upon request. The tier system has been amended and Tier 3 has been split into Tier 3A and Tier 3B.
• Attestation and cost information deadlines: The deadline for providing additional attestations or itemised ancillary costs has been reduced from 30 days to 28 days.
• Ceasing doing business: The requirement to cease doing business with actors who refuse or fail to provide information has been clarified as being contract-specific and only applying to policies relating to the seaborne transportation of Russian oil and oil products.

General Licence – "new" oil price cap General Licence

(INT/2024/4423849)

Effective from 19 February 2024

Publication notice

This new General Licence replaces the previous General Licence Oil Price Cap INT/2022/2469656 which expires on 18 February 2024.

This new General Licence permits the supply or delivery by ship of Russian crude oil and oil products, as well as provision of associated services, so long as the price paid for Russian oil or oil products is at or below the price cap. This General Licence sets the price at USD $60 per barrel for crude oil, USD $100 for “premium to crude”, and USD $45 for “discount to crude”.

Subject to the stated exclusions and conditions and provided that no supply or delivery by ship of Russian oil or Relevant Services are provided to a Designated Person:

1. A person may supply or deliver Russian oil by ship from a place in Russia to a third country or from one third country to another third country provided that the Unit Price of the Russian oil concerned is at or below the Price Cap.
2. A service provider may provide relevant services to any person provided that the unit price of the Russian oil being supplied or delivered by ship from a place in Russia to a third country or from one third country to another third country is at or below the Price Cap. 
3. A Relevant Institution may process payments in relation to the activities authorised by paragraphs 1 and 2.

This new General Licence utilises an attestation process – on a per-voyage basis – which is designed to put different levels of requirement onto different actors in the oil supply chain, depending on whether they routinely know the price paid in their ordinary course of business and how often they transact. An attestation means a document:

• demonstrating that the Price Information of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
• demonstrating that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
• attesting that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
• attesting that the Russian oil was purchased pursuant to a Licence issued under Part 4 of Schedule 5 of the Russia Regulations for example to enable anything to be done to deal with an extraordinary situation
• which, for Tier 3A and Tier 3B Providers, contains a clause within contractual terms and conditions that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap.

Tier 1 Providers (and Tier 2 Providers with access to the information) are required to record itemised ancillary costs information – on a per-voyage basis – and provide them to other Tier 1, Tier 2 and Tier 3A contractual counterparties upon request.

General Licence – Permitted Payments to UK Insurance Companies – amendment

(INT/2022/2009156)

Publication notice

This General Licence has been amended such that: 

• Reference to frozen UK bank accounts has been removed from paragraphs 4.1, 4.3.1, and 6.1 to make clear that payments by DPs are not restricted to those made from frozen funds; and
• The language in paragraphs 5.1 and 6.6 has been clarified.

OFSI has published a blog post explaining the two new reporting requirements that came into force in December 2023 through the Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023:

• the immobilised assets reporting measure; and
• the Designated Persons asset reporting measure.

General Licence – Oil Price Cap – amendment

(INT/2022/2469656)

Publication notice

THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/4423849

This General Licence has been amended to include an expiration date of 18 February 2024. 

General Licence – Permitted Payments to UK Insurance Companies – amendment

(INT/2022/2009156)

Publication notice 

 This General Licence has been amended such that:

• Permitted Payments can only be made for UK properties and UK vehicles;
• Insurance Brokers may make all types of Return Payments to a DP’s frozen bank account including payments due from successful claims;
• The language in 5.2 and 6.5 has been clarified;
• The definition of Return Payments was expanded to include other types of refunds;
• The reporting and record-keeping requirements also apply to Insurance Brokers; and
• Those reporting must now report to HM Treasury within 10 working days.

The Oil Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) have issued an enforcement alert to support governments and strengthen oil price cap (OPC) compliance.

The coalition has two key objectives: 1) constraining Russian revenues that could otherwise be used to fund Russia’s war of aggression against Ukraine; while 2) maintaining global oil flows and protecting energy security.

The alert includes an overview of key OPC evasion methods and recommendations for identifying such methods and mitigating their risks and negative impacts. The alert also includes information on how to report OPC suspected breaches across the Price Cap Coalition.

The OPC evasion methods covered in this alert are related to:

• falsified documentation and attestations;
• opaque shipping and ancillary costs;
• third country supply chain intermediaries and complex and irregular corporate structures;
• flagging;
• the “shadow” fleet; and
• voyage irregularities.

The National Crime Agency has issued an Amber Alert highlighting the sanctions evasion and money laundering risks presented to UK industries linked to the art storage sector, and to serve as a reminder on due diligence checks and reporting obligations.

The Alert includes key indicators and useful questions, as well as case studies.

The Alert is not specific to Russian sanctions, but identifies Russia as a jurisdiction of high risk.

Asset freeze – addition

The Cyber (Sanctions) (EU Exit) Regulations 2020

Press release

1 individual has been added to the consolidated list and is now subject to an asset freeze:

• Aleksandr Gennadievich Ermakov

The individual has been sanctioned for his involvement in the cyber-attack on Medibank Private network that resulted in 9.7 million medical records being stolen. This designation has been made under the UK's cyber sanctions regime.

Permits the provision of technical assistance, financial services and funds, and brokering services relating to vessels, aircrafts and aero gas turbine engines / their component parts / associated technology, where;

• the goods are:

• vessels and their component parts controlled under 8A992f of Schedule 2A to the Regulations and the restricted technology is technology related to such vessels controlled under 8E992 of Schedule 2A to the Regulations,
• aircraft and their component parts controlled under Schedule 2C to the Regulations and the restricted technology is technology related to such aircraft controlled under Schedule 2C to the Regulations, but in each case not including anything defined under Part 5 of the Regulations as military goods or military technology, or
• aero gas turbine engines and specially designed components therefor controlled under 9A991c of Schedule 2A of the Regulations and the restricted technology is technology related to such engines and components controlled under 9E991 of Schedule 2A to the Regulations,

• the aircraft or vessel is moving from a third country to Russia, or to the UK or a third country from Russia, or transiting Russian territorial waters or airspace or moving between two third countries,
• in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers,
• the aircraft or vessel is moving under its own power, and
• the movement of the aircraft or vessel is not for the purpose of: (i) transfer of ownership of the aircraft or vessel or any of its component parts or (ii) a change of the operator of the aircraft or vessel.
• an aero gas turbine engine and specially designed components form part of an aircraft specified above which is undertaking an activity in accordance with the above.,
• technical assistance and brokering services are not being provided to a person connected with Russia; and
• in the case of insurance and reinsurance services under Article 29A, they are not being provided to a person connected with Russia.

The General Licence also contains a number of conditions relating to insurance/reinsurance in respect of the above.

Use is subject to a notification requirement.

This replaces the previous licence dated 1 August 2022 (now revoked).

The Export Control Joint Unit has updated its guidelines on complying with professional and business services sanctions related to Russia by:

• adding a section on "aims" which explains why certain services activities are targeted and that the prohibition's aim is "to increase the economic pressure on the Russian regime to stop its activities in Ukraine"; and
• revising the compliance section to cover "compliance and scope" and explaining that "UK services sanctions are export bans that are applied in relation to the activity being undertaken rather than by service sector."

General Licence – Evraz – amendment

(INT/2022/1710676)

The General Licence permitting the continuation of business operations involving the North American subsidiaries of Evraz plc has been extended and will now expire at 23:59 on 30 September 2024.

In addition, the definition of North American Subsidiaries under the General Licence was amended on 22 December 2023 to make clear that the definition also covers the subsidiaries of those subsidiaries.

See entry at 5 May 2022 for more information on this General Licence.

OFSI updated its General, Russia and Enforcement & Monetary Penalties guidance documents to reflect changes to sanctions legislation introduced through the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 (see entries below for more details). Specifically, the guidance has been updated to reflect the following changes:

• new reporting requirements on relevant firms under Regulation 70 (as amended)
• new reporting requirement on designated persons under Regulation 70A
• new licensing ground for divestment purposes
• amendments to regulations 17A and 59A covering the prohibitions on and exceptions to the processing of payments and correspondent banking relationships

The guidance documents have also been updated to reflect the clarifications made by the Economic Crime and Corporate Transparency Act 2023 to OFSI's monetary penalty powers under the Policing and Crime Act 2017.

Along with these updates, reporting forms are now available on OFSI's website for the new reporting measures now in place.

Following amendments to regulation 17A, a blog has also been issued explaining the new payment processing restrictions.

OFSI has published updated guidance for the Maritime Services Ban and Oil Price Cap to provide additional clarity and detail on the following:

• Attestations: upcoming changes to the existing model will require 1) attestation forms to be provided on a per-voyage basis and 2) itemised ancillary costs to be recorded by Tier 1 entities and provided by Tier 2 and Tier 3A contractual counterparties upon request. The tier system has also been amended. These requirements will apply from 19 February 2024 and will be implemented through a new general licence.
• UK Nationals: clarification on reporting requirements for UK nationals in third countries
• Reporting timelines: clarification on deadlines and requirements for record keeping and reporting activity under the general licences.

Bespoke reporting forms for required reporting, reporting suspected breaches, and specific licence applications are on OFSI's website.

Any reporting or queries should be directed to oilpricecap.OFSI@hmtreasury.gov.uk

Two General Licences have been revoked: Refined Products Oil Price Cap Wind-down (INT/2023/2660772) and Oil Price Cap Wind-down (INT/2022/2470256).

General Trade Licence:
Iron and steel products – amendment

General Licence webpage

The iron and steel products General Trade Licence was varied on 18 December 2023 to reflect amendments made by the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023.

The changes to the Licence have not affected what is permitted by the Licence. The changes updated the name of the title of Chapter 4CA, and how iron and steel products processed in a third country is defined. The changes take effect at 00:00 on 20 December 2023.

See entry at 11 December 2023 below for more information on this General Trade Licence.

General Trade Licence: Acquisition of metals

General Licence webpage

A General Trade Licence has been granted which authorises the direct or indirect acquisition of a warrant on a global metal exchange by the persons described below, so far as otherwise prohibited by regulation 46IH(1)(a) of the Russia Regulations, provided that such persons:

• do not cancel or withdraw (or request or order the cancellation or withdrawal of) such a warrant from a global metal exchange in order to take physical delivery of metal for their own account; and
• do not change the location of the metal to which the warrant relates.

The description of persons to whom the above applies are:

• ME Clear Limited;
• The London Metal Exchange;
• global metal exchange members; and
• clients of global metal exchange members.

This General Trade Licence took effect from 15 December 2023 and has no expiry date.

The following 26 entities have been designated for the purposes of Regulation 17A and are now subject to the prohibition on correspondent banking relationships etc:

• Bank Rossiya
• Black Sea Bank For Development And Reconstruction
• Joint Stock Company Genbank
• PJSC JSCB Metallinvestbank
• Russian Regional Development Bank
• Tinkoff Bank
• RF Bank
• IS Bank
• Joint Stock Company Moscow Industrial Bank
• SMP Bank
• Ural Bank For Reconstruction And Development
• Bank Otkritie Financial Corporation PJSC
• Public Joint Stock Company PROMSVYAZBANK
• Bank Uralsib PJSC
• MTS Bank Public Joint-Stock Company (PJSC)
• LLC Commercial Bank – International Settlements Bank
• Bank Zenit PJSC
• RF
• Bank St Petersburg PJSC
• PJSC Sovcombank
• Gazprombank
• VTB Bank (Public Joint-Stock Company)
• Rosbank PJSC
• Alfa-Bank JSC
• Credit Bank Of Moscow
• Russian Agricultural Bank
• PJSC Sberbank (Public Joint-Stock Company Sberbank)

Previously, Sberbank was the only entity designated for the purposes of Regulation 17A. The above entities were already designated for the purposes of the asset freeze measures and the trust services restrictions.

General Licence: Payment Processing Wind Down

[INT/2023/4078352]

Publication Notice

The General Licence permits processing payments that would otherwise breach Regulation 17A(2) following amendments to the regulation (see entry for 14 December below).

Under this General Licence UK credit or financial institutions may process

• payments from or via a Newly Designated Bank; and
• non-sterling payments from or via Sberbank.

For the purposes of this General Licence, "Newly Designated Bank" means any credit or financial institution designated for the purposes of regulation 17A after 13 December 2023, and any UK or non-UK financial institution which is owned or controlled by that institution.

(Prior to 15 December 2023, Sberbank was the only person designated for the purposes of regulation 17A.)

This General Licence takes effect from 12am (midnight) on 15 December 2023 and expires at 23:59 on 22 December 2023.

OFSI has updated the following General Licences to also permit activity that would otherwise breach the prohibitions in Regulation 17A of the Russia Regulations:

• INT/2022/2349952 – Transactions Related to Agricultural Commodities Including the Provision of Insurance and Other Services
• INT/2022/2300292 – Payments to Utility Companies for Gas and Electricity by UK Designated Persons who Own or Rent Properties in the UK
• INT/2023/3626884 – Payments to Companies House
• INT/2022/2009156 – Permitted Payments to UK Insurance Companies
• INT/2022/1834876 – Charities and Interim Managers and Trustees
• INT/2022/1839676 – Russia Travel for UK Nationals
• INT/2022/1322576 – Provision of Navigational Data to Civilian Aircrafts for Flight Safety
• INT/2023/3024200 – Prior Obligations
• INT/2022/1552576 – LCIA Payments
• INT/2023/3179120 – Payment to Water Companies for Water and Sewage
• INT/2023/3744968 – Legal Services
• INT/2021/554388 – Emergency Payment(s) Directly or via an Intermediary to Belaeronavigatsia for Air Traffic Services

General Licence INT/2022/2009156 (Permitted Payments to UK Insurance Companies) also has a number of changes in relation to definitions and use.

1 entity has been added to the consolidated list and is now subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions:

• Joint-Stock Commercial Bank Novikombank

 14 December 2023

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023

Financial sanctions: Correspondent banking relationships - amendment

(amendment to Regulations 17A, 59A)

See also OFSI blog post

The existing prohibition on "processing" payments to/from entities designated for the purpose of Regulation 17A has been amended as follows :

• The prohibition now applies to all payments, not just to sterling payments; and
• The prohibition does not include the act of crediting a payment, for the first time, to a UK credit or financial institution ("C") (the correspondent) where that payment is credited to an account which is (i) in the name of C; and (ii) not held on behalf of, or for the benefit of, a customer of C.

A new exception has also been introduced: the prohibition in regulation 17A(2) is not contravened by a transfer/transfer of funds by C from account A to account B where: (a) neither account A nor account B are held in the name of a customer of C; (b) both account A and account B are held within the UK; and (c) the transfer(s) from account A to account B is/are carried out for the purpose of compliance with regulation 17A(2).

Trade restrictions: luxury goods – amendment

(new Regulations 46BA, 46BB, 46BC; amendments to Regulation 85)

Introduction of new prohibitions on providing technical assistance, financial services and funds, and brokering services in respect of luxury goods (as specified in Schedule 3A).

Consequential amendments have been made to Regulation 85 (application of CEMA).

Trade restrictions: Russian metals

(new Chapter 4CB, Regulations 46IF – 46II; new Schedule 3BA)

Introduction of a new prohibition on:

• the import or acquisition of "metals" which originate in Russia; and
• the supply/delivery of "metals" which originate in Russia from a place in Russia to a third country.

"metals" means anything specified in Schedule 3BA;

"third country" means a country that is not the United Kingdom, the Isle of Man or Russia.

Schedule 3BA includes: copper, nickel, aluminium, lead, zinc, tin, tungsten, magnesium, cobalt and various other metals

The following exceptions have been amended:

• Regulation 60A (trade: exceptions in relation to personal effects etc.)
• Regulations 60B (trade: exceptions in relation to consumer communication devices and software updates)
• Regulation 60G (trade: exception in relation to certain goods consigned from Russia) – in particular to specify that certain prohibitions do not apply to certain products which are consigned from Russia before 15 December 2023; and imported into the UK before 14 January 2024.
• Regulation 60GA (trade: exception in respect of the acquisition of iron and steel products)

Trade restrictions: iron and steel products – new exceptions

(new regulations 60GAA and 60GAB)

Introduction of new exceptions to a number of the restrictions on Russian iron and steel products (Chapter 4C, Regulation 46C – 46I) where those goods:

• were exported from Russia before the relevant day (being the day on which the restriction in question came into force); and
• (in some cases) are not to be released for free circulation in the UK or the Isle of Man.

Reporting obligations: relevant firms

(amendment to Regulation 70)

Introduction of an additional reporting requirement requiring "relevant firms" to inform the Treasury:

• if it knows, or has reasonable cause to suspect, that it holds funds or economic resources for a prohibited person; and that information came to it in the course of carrying on its business; and
• by no later than 31 October in each calendar year, as to the nature and amount or quantity of funds or economic resources held by that firm for a prohibited person as of 30 September in that calendar year.

"prohibited person" means a person to whom financial services must not be provided by virtue of regulation 18A(1) (Provision of financial services relating to foreign exchange reserve and asset management).

Reporting obligations: designated persons

(new Regulation 70A; amendments to Regulations 88 and 88C)

From 26 December 2023, there are new reporting requirements for designated persons, as follows:

• a designated person who is a UK person must inform the Treasury of the nature and value of any funds or economic resources which that person owns, holds or controls in any jurisdiction; and the location of those funds or economic resources.

• a designated person who is not a UK person must inform the Treasury of the nature and value of any funds or economic resources which that person owns, holds or controls in the UK; and the location of those funds or economic resources.

• a designated person who has reported the above information to the Treasury must also inform the Treasury as soon as practicable of any change to the nature, value or location of the funds or economic resources.

The deadline for making any such reports is:

• 10 weeks from when the above Regulation comes into force (see above)
• 10 weeks after the person became a designated person (if they were not a designated person when the above Regulation came into force)

Consequential amendments have been made to Regulations 88 and 88C in respect of the Treasury's ability to impose monetary penalties for breach of the above.

Trade restrictions amendments to existing restrictions

(various)

Further amendments to existing trade restrictions:

• additions to Schedule 2A (critical-industry goods and critical-industry technology)
• additions to Schedule 3A (luxury goods)
• amendments to Schedule 3B (iron and steel products)
• additions to Schedule 3C (defence and security goods and defence and security technology)
• amendments to Schedule 3E (G7 dependency and further goods)

Treasury Licences: purposes – amendment

(amendment to Schedule 5 – addition of a new Part 1ZA)

Addition of three new purposes to Schedule 5 for which the Treasury can issue a licence:

• to enable a UK entity to divest itself of funds or economic resources located in Russia (subject to certain conditions)
• to enable anything to be done by a UK entity to enable another person to divest itself of funds or economic resources located in Russia (subject to certain conditions)
• to enable anything to be done in connection with a licence which the Treasury has decided to issue for another purpose specified in this Schedule

 14 December 2023

The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023

Prohibition on the following in respect of "diamonds" and "diamond jewellery" from 1 January 2024:

• imports of diamonds and diamond jewellery which originate in Russia
• direct or indirect acquisition of diamonds and diamond jewellery which originate or are located in Russia
• direct or indirect supply or delivery of diamonds or diamond jewellery from a place in Russia to a third country
• associated technical assistance, financial services and funds, and brokering services in respect of the above.

"diamonds" means anything specified in Part 2 of Schedule 3GA

"diamond jewellery" means anything specified in Part 3 of Schedule 3GA

"third country" means a country which is not the United Kingdom, the Isle of Man or Russia.

Exception for diamonds and diamond jewellery located in the United Kingdom or the Isle of Man having been lawfully imported there (Regulation 60GC).

Minor consequential amendments to: regulation 60A (trade: exceptions in relation to personal effects etc.); regulation 85 (trade enforcement: application of CEMA); and Schedule 3DA (revenue generating goods).

A General Trade Licence has been granted which authorises activity in respect of certain iron and steel products which would otherwise be prohibited under Chapter 4C (Regulations 4D to 46I), as follows:

• Reusable packaging (pallets and similar platforms for handling goods): products falling under commodity code 7326904000 (pallets and similar platforms for handling goods); is imported into the United Kingdom for the purpose of facilitating the international trade of other goods, whether or not filled with other goods when imported; and is not consigned from Russia
• Relevant processed iron or steel products manufactured or produced before 21 April 2023: a product which is a relevant processed iron or steel product; was manufactured or produced before 21 April 2023; and has not been located in Russia at any time since 21 April 2023.
• Relevant processed iron or steel products previously in the UK: a product which is a relevant processed iron or steel product; has previously been in free circulation in the UK; falls within the same commodity code as it did when it was exported from the UK; and has not been located in Russia at any time since 21 April 2023

This General Trade Licence took effect from 11 December 2023 and has no expiry date.

Trade sanctions: Introduction of a new unit to enforce trade sanctions – the Office of Trade Sanctions Implementation

Press release

The UK Government has announced the introduction of a new unit - the Office of Trade Sanctions Implementation (OTSI) - which will be responsible for the civil enforcement of trade sanctions, including those against Russia.

OTSI will help businesses comply with sanctions, investigate potential breaches, issuing civil penalties and referring cases to HMRC for criminal enforcement where needed.

OTSI will launch in early 2024 once the new legal requirements are in place.

General Licence: Local Authorities Payments

[INT/2023/3781228]

Publication notice

The General Licence permits the payment of (i) Council Tax or rates charged on domestic properties; (ii) non-domestic rates, and (iii) any associated late penalties or fees, to Local Authorities in the UK by or on behalf of a Designated Person (Permitted Payments).
Under this General Licence:

• A DP, or a person acting on behalf of a DP, may make Permitted Payments to Local Authorities.
• Where a Local Authority payment is made by a person acting on behalf of a DP, the General Licence permits that permits (i) the DP to repay that person the same amount as the Permitted Payment; and (ii) the Person may receive that amount from the DP.
• UK financial institutions may process payments made in accordance with the above.

For the purposes of this General Licence "DP" does not include persons sanctioned by the United Nations.

DPs and persons acting on their behalf must report any payments made under this General Licence within 14 days. DPs must also keep records of the same.

This General Licence took effect from 00:01 am on 9 December 2023 and has no expiry date.

Belarus: Asset freeze – additions

Press release

The UK, US and Canada announced a package of sanctions targeting individuals linked to human rights abuses around the world, ahead of the 75th anniversary of the Universal Declaration of Human Rights on 10 December.

The list of those targeted by the UK includes 17 Belarusian individuals including judges, prosecutors and an investigator involved in politically-motivated cases against political activists, independent journalists and human rights defenders. They have been added to the consolidated list and are now subject to an asset freeze:

• Petr Aleksandrovich Orlov
• Sergei Aleksandrovich Epikhov
• Vyacheslav Ivanovich Tuleyko
• Valentina Nikolaevna Zenkevich
• Svetlana Aleksandrovna Bondarenk
• Roman Ivanovich Bizyuk
• Aleksandr Vladimirovich Karol
• Sergey Fedorovich Khripach
• Anton Vladimirovich Kolyago
• Marina Sviatoslavovna Zapasnik
• Mikhail Kavaliou
• Valentina Gennadevna Kulik
• Igor Viacheslavovich Liubovitski
• Mikhail lvanovich Dola
• Tatyana Alexandrovna Grakun
• Sergei Sergeevich Girgel
• Denis Alexandrovich Mikushev

Designations were also made under a number of the UK's other sanctions regimes but these are outside the scope of this tracker.

Asset freeze - additions

The Cyber (Sanctions) (EU Exit) Regulations 2020

Press release

2 individuals have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• Ruslan Aleksandrovich Peretyatko
• Andrey Stanislavovich Korinets

The individuals have been sanctioned in connection with their role in cyber operations by the Russian Security Service (FSB) intended to interfere in UK political processes. These designations have been made under the UK's cyber sanctions regime.

25 individuals and 20 entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions.

These designations include:

• 31 Russian individuals and entities who are linked to designing and manufacturing drones and missile parts and importing and supplying key electronic components
• third country suppliers to Russia's military
• 3 entities and individuals linked to the Wagner Group's wider network
• 4 UAE-based entities using opaque corporate structures and deceptive shipping practices to facilitate unfettered trade in Russian oil.

The individuals sanctioned are:

• Vladimir Nikolaevich Anyurov
• Zorair Artyushevich Apresyan
• Mkrtich Stepanovich Arakelyan
• Dmitriy Vladimirovich Baban
• Vitalii Yuryevich Babenkov
• Arutyunov Alexander Borisovich
• Mikhail Nikolaevich Bychkov
• Kamo Stepanovich Gukasyan
• Oganez Stepanovich Gukasyan
• Stepan Kamoevich Gukasyan
• Vasilii Yuryevich Kristkii
• Mkrtich Okroevich Okroyan
• Andranik Mkrtichovich Okroyan
• Anna Mkrtichevna Okroyan
• Arutyun Okroevich Okroyan
• Vaso Mikhakovich Okroyan
• Yan Igorovich Petrovskiy
• Semyon Mkrtychovich Simonyan
• Dmitriy Stepanovich Strezhnev
• Sergei Sergeevich Tregub
• Alexander Vyacheslavovich Zakharov
• Nikita Aleksandrovich Zakharov
• Lavrentiy Aleksandrovich Zakharov
• Svetlana Nikolaevna Zakharova
• Mariya Aleksandrovna Zakharova

The entities sanctioned are:

• Aeroscan
• Asia Pacific Links Limited
• Aviochem
• Joint-Stock Company Ratep
• JSC Radiotechkomplekt
• JSC Research and Production Enterprise Radar MMS
• JSC Joyuz
• JSC Votkinsk Machine Building Plant
• K&O Ship Management
• Limited Liability Company ID Solution
• LLC Charter Green Light
• Nauchno-Tekhnicheskii Tsentr Orion
• Oil Tankers (SCF) Management
• OOO Mvizion
• Radiating World Shipping Services LLC
• Rusich Military Group
• Sinno Electronics Co., Limited
• Smart Trading Limited STI
• Star Voyages Shipping Services L.L.C
• Xinghua Co., Limited

Belarus: Asset freeze – additions

Press release

NCA Red Alert: Exporting High Risk Goods

Press release

The National Crime Agency has issued a Red Alert to financial institutions and other members of the regulated sector informing UK businesses about common techniques suspected to be in use to evade sanctions on the export of high-risk goods, which Russia is using on the battlefield in Ukraine.

The primary audience for this alert is the UK’s financial sector, including banks, credit card operators, foreign exchange dealers and non-bank payment service providers. It may also be relevant to business sectors outside the regulated sector for anti-money laundering, in particular customs brokers, freight forwarders and other transportation and logistics providers.

The G7 leaders published a statement following a (virtual) meeting on 6 December 2023. As part of that statement, they provided further details regarding their intention to introduce sanctions on Russian diamonds, which will comprise:

• import restrictions on non-industrial diamonds, mined, processed, or produced in Russia, by 1 January 2024,
• further phased restrictions on the import of Russian diamonds processed in third countries targeting 1 March 2024; and
• the establishment of a robust traceability-based verification and certification mechanism for rough diamonds within the G7 by 1 September 2024 by G7 members who are major importers of rough diamonds.

The G7 leaders repeated their call for third parties to immediately cease providing material support to Russia’s aggression, or face severe cost.

In respect of other future sanctions measures, the G& leaders stated that they would:

• work to further curtail Russia’s use of the international financial system to further its war in Ukraine, including Russia’s efforts to use the international financial system to facilitate its expansion of its military industrial base;
• step up efforts against evasion and circumvention of sanctions and export controls measures;
• tighten compliance and enforcement of the price cap policy on Russian oil, including by imposing sanctions on those engaged in deceptive practices and by updating compliance rules and regulations as necessary; and
• continue efforts to curtail Russia’s revenue from other relevant sectors, including from metals.

On Friday, 1 December, HMRC issued a Notice to Exporters regarding recent fines for unlicensed exports of Dual Use goods. Between August and November 2023, HM Revenue and Customs (HMRC) issued compound settlement offers to three UK exporters totalling in excess of £77,000.00.
These settlements relate to unlicensed exports of Dual Use goods and related activity controlled by The Export Control Order 2008 and a breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
The three settlements made by UK companies were:

• August 2023 - £67,001.31 was paid in relation to the attempted export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019
• September 2023 - £1,000 was paid relating to the attempted export of Dual Use goods controlled by Retained Regulation 428/2009
• September 2023 - £9,088.99 was paid relating to the unlicensed exports of Dual Use goods controlled by Retained Regulation 428/2009

General Licence: Correspondent Banking Payments – amendment

[INT/2023/3566356]

Publication Notice

The General Licence permitting a Credit or Financial Institution to return a Relevant Payment to the Credit or Financial Institution which sent the Relevant Payment directly to it, so long as neither the sending or receiving Credit or Financial Institution are a designated person, has been extended and will now expire at 23:59 on 14 December 2023.

See entry at 29 September 2023 for more information.

The Foreign Commonwealth and Development Office (FCDO) and the Office of Financial Sanctions Implementation (OFSI) have issued joint guidance relating to ownership and control in UK sanctions regimes. This guidance is applicable to all sanctions regimes, including the Russia (Sanctions) (EU Exit) Regulations 2019. In summary, that guidance provides that:

• FCDO does not generally consider designated public officials to exercise control over a public body in which they hold a leadership function, such that the affairs of that public body should be considered to be conducted in accordance with the wishes of that individual.
• FCDO does not intend for sanctions measures targeting public officials to prohibit routine transactions with public bodies, including (but not limited to) the payment of taxes and fees, such as import duties.
  If FCDO considered that a public official was exercising control over the public body under UK sanctions regulations, FCDO would look to designate the public body where possible when designating the relevant public official.
• There is no presumption on the part of the UK government that a private entity is subject to the control of a designated public official simply because that entity is based or incorporated in a jurisdiction in which that official has a leading role in economic policy or decision-making.
• Specifically, for the purposes of regulation 7(4) of the Russia (Sanctions) (EU Exit) Regulations 2019, the UK government does not consider that President Putin exercises indirect or de facto control over all entities in the Russian economy merely by virtue of his occupation of the Russian Presidency.

OFSI has amended this General Licence to remove the Annex 1 schedule of arbitration costs, and changes the definition of arbitration costs to reflect the relevant Schedule of Costs for LCIA arbitration.

See the original entry for this general licence dated 17 October 2022 for further detail.

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Sergey Stognienko

 Asset freeze - additions

Press release

20 individuals and 9 entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions. These entities / individuals are operating in and supporting Russia's gold, oil and strategic sectors, and include both Russian oligarchs and businesses, and third country enablers fuelling Russia's war revenues.
The individuals sanctioned are:

• Howard Jon Baker
• Mariya Vladimirovna Chekadanova
• Yury Anatolyevich Chikhanchin
• Vadim Sergeevich Dobrov
• Maksim Yuryevich Ermakov
• Kresimir Filipovic
• Evgenii Vasilyevich Istomin
• Aleksandr Sergeevich Kotov
• Leonid Viktorovich Lavrentyev
• Francois Edouard Mauron
• Marina Aleksandrovna Mordashova
• Walter Moretti
• Natalya Aleksandrovna Rubtsova
• Sergei Vladilenovich Shcherbakov
• Georgy Valeryevich Smirnov
• Konstantin Ivanovich Strukov
• Vladislav Vladimirovich Sviblov
• Sergei Vadimovich Tregub
• Vadym Oleksandrovich Tregub
• Aleksandr Aleksandrovich Vyalov

The entities sanctioned are:

• Highland Gold Mining Limited
• JSC Krastsvetmet
• Limited Liability Company Technological Company Fly Bridge
• Nord Gold plc
• OJSC Ural Mining and Metallurgical Company
• Paloma Precious DMCC
• Paramount Energy & Commodities DMCC
• Russian National Reinsurance Company
• The Russian Union of Industrialists and Entrepreneurs

NCA Red Alert: Gold-based Financial and Trade Sanctions Circumvention

Press release

The National Crime Agency has issued a Red Alert to financial institutions and other members of the regulated sector warning that Russia is using gold as a means to undermine the impact of the UK sanctions regime.

The purpose of the Alert is to provide information on common techniques sanctioned individuals and entities, and their enablers, are suspected to be using to evade sanctions related to gold. The London Over the Counter (OTC) market has historically been the centre of the gold trade and attracts participants from all around the world. They are responsible for setting the twice daily global reference benchmark for gold.

Traders, financial institutions and other market participants should ensure that, as part of their due diligence, they are aware of the common circumvention techniques set out in the alert, and the risks and obligations in relation to Russia sanctions and gold.

General Licence: Continuation of Business and Basic Needs for Telecommunications Services and News Media Services – amendment

[INT/2022/1875276]

Publication Notice

OFSI has amended this General Licence to clarify that:

• PJSC MegaFon and its subsidiaries are Civilian Telecommunication DPs;
• Digital Invest Limited Liability Company (Digital Invest) is a Civilian Telecommunication DP; and

The Licence has also been extended to 30 May 2026.

See entries at 30 May 2022, 26 June 2023 and 23 August 2023 for more information on this General Licence.

General Licence: Legal Services (new)

[INT/2023/3744968]

Publication Notice

OFSI has issued a new General Licence which permits a UK legal firm or UK counsel who has provided "Legal Services" to a person designated under either the Russia or Belarus regime to receive payment from that designated person without an OFSI specific licence, provided that the terms of this General Licence are met.

This replaces the existing Legal Fees General Licence (issued on 28 April 2023) which expired on 28 October 2023 (see below)

The licence is split into two parts:

• Part A: legal services based on a prior obligation (i.e. commenced prior to the DP's designation); and
• Part B: legal services not based on a prior obligation.

Both Part A and Part B of this licence can be used in conjunction by a Person or DP if the provision of Legal Services commenced before the DP was designated and continued after designation.

Each part has its own set of conditions – consult the licence for full details.

The previous legal fees caps and expenses caps have been reset. For each part, there is a cap for legal and counsel fees (£500,000) and expenses of (the lower of 10% of legal fees or £50,000). The General Licence also contains maximum hourly rates for fee earners under Part B only.

Legal fees and expenses for cases involving defamation or malicious falsehoods are not permitted to be paid under this General Licence.

The General Licence is subject to reporting and record-keeping requirements.

This General Licence took effect from 00:01 on 29 October 2023 and expires at 23:59 on 28 April 2024.

19 October 2023

General Licence: Payments to Companies House – amendment.

[INT/2023/3626884]

Publication Notice

OFSI has amended the "Payments to Companies House" General Licence to:

• clarify that the term "Permitted Payments" relates to:

the payment of fees owed by or due from UK DPs to Companies House for filing a confirmation statement (previously known as an annual return) in respect of UK companies entities incorporated in the UK registered with Companies House; and

the payment of late filing penalty fees owed by or due from UK DPs to Companies House incurred as a result of late filing of the confirmation statement annual accounts by those UK DPs.

• The term "UK DP" relates to entities designated (or owned or controlled by a person an individual or an entity designated) for the purposes of an asset freeze by the UK under the UK Autonomous Sanctions Regulations, excluding those designated for the purpose of compliance with United Nations obligations.

The Export Control Joint Unit (ECJU) has released a technical guidance on the interception and monitoring prohibitions in UK sanctions on Russia and Belarus. This guidance provides further information on the meaning of the following 14 specific terms used in the schedules to these regulations. The schedules in the legislation cover goods and software which can perform the following functions:

• Deep Packet Inspection
• Network Interception
• Radio Frequency monitoring
• Network satellite and jamming
• Remote infection
• Speaker recognition
• IMSI, MSISDN, IMEI and TMSI interception and monitoring
• Tactical SMS, GSM, GPS, GPRS, UMTS, CDMA and PSTN interception and monitoring
• DHCP, SMTP and GTP information interception and monitoring
• Pattern recognition and pattern profiling
• Remote forensics
• Semantic processing
• WEP and WPA code breaking
• VoIP interception (proprietary and standard protocol)

The UK Foreign, Commonwealth and Development Office (FCDO) has released a statement following the Court of Appeal judgment in Mints & others v PJSC National Bank Trust & another:

"The Government is carefully considering the impact of the Court of Appeal’s judgment in Mints & others v PJSC National Bank Trust & another, in particular the Court's views that PJSC National Bank Trust is 'controlled' by Designated Persons by virtue of their political office, noting that the case was not decided on this point.
FCDO would look to designate a public body where possible when designating a public official if FCDO considered that the relevant official was exercising control over the public body.
There is no presumption on the part of the Government that a private entity based in or incorporated in Russia or any jurisdiction in which a public official is designated is in itself sufficient evidence to demonstrate that the relevant official exercises control over that entity.
In the interests of reducing any uncertainty, we are exploring the options available to the Government in clarifying this position further."

In response to that statement, OFSI stated that it "has consulted with the FCDO in its considerations following the judgement and supports this statement. OFSI will continue to work with our stakeholders to understand the impacts, particularly in respect of financial sanctions".

General Licence: Payment to Energy Companies for Gas and/or Electricity - amendment

[INT/2022/2300292]

Publication notice

OFSI has amended the "Payment to Energy Companies for Gas and/or Electricity" General Licence to:

• extend the duration of the General Licence - there is no longer an expiry date; and
• permit a "Person" to make permitted payments to energy companies for or on behalf of designated persons. (A "Person" is an individual or a body of persons corporate or unincorporate but does not include a UK designated person.)

This GL allows for payment to utility companies for gas and electricity by UK designated persons who own or rent properties in the UK. For further details, see the entries at 17 November 2022 and 24 February 2023 below.

The Oil Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) have issued the following documents in respect of the price caps on seaborne Russian oil:

• Statement on actions taken to enforce price caps for seaborne Russian-origin oil and petroleum products: This states that the Coalition is focusing on supporting compliance and enforcement of the policy, noting that Russian oil tax revenue was down 45% from January -August this year relative to 2022. The statement also underscores the risks of violating price cap rules and highlights that the US is taking steps to action to impose sanctions on two entities and identify vessels as property in which those entities have an interest.
• Maritime Safety Advisory for the Maritime Oil Industry and Related Sectors: This advisory outlines best practices industry stakeholders can adopt to reduce risks while promoting the safe flow of oil on the market, and builds on previous guidance by the Coalition (details of which are in the advisory). By adopting the recommendations in the advisory and previous guidance documents, industry stakeholders can reduce their exposure to possible risks associated with recent developments in the maritime oil trade.

General Licence: Prior Obligations - amendment

[INT/2023/3024200]

Publication notice

OFSI has made a number of amendments to the "Prior Obligations" General Licence, including:

• The limit of £200,000 now applies to the remaining amount due under the relevant contract, rather than its total value;
• The General Licence now applies persons designated under the Belarus Regulations, as well as the Russia Regulations;
• The list of excluded contracts has been amended (see Annex A and Annex B); and
• The General Licence will now expire on 21 May 2024.

OFSI has issued a General Licence permitting Designated Persons (DPs) / persons acting on their to make Permitted Payments to Companies House.

"Permitted Payment" means:

• The payment of fees owed by or due from DPs to Companies House for filing a confirmation statement (previously known as an annual return) in respect of UK companies registered with Companies House; and
• The payment of late filing penalty fees owed by or due from DPs to Companies House incurred as a result of late filing of the confirmation statement.

Persons acting on behalf of UK DPs for this purpose, and financial institutions, are permitted to receive and process the above payments.

The General Licence does not permit payment by any person designated by the United Nations.

Subject to reporting and record-keeping requirements. The licence does not have an expiry date.

Trade restrictions: licencing grounds – divestment from Russia 

The UK has updated its Russia Guidance to add additional licencing grounds for trade activities that would otherwise be prohibited.

A licence may be granted for the activities below if the activity is necessary for the purposes of divestment from Russia, subject to certain conditions:

• making available or transfer of any of the following for use in Russia, or to a person connected with Russia: oil refining goods and technology (Regs 25 and 26), energy-related goods (Regs 40-42), luxury goods (Reg 46B), jet fuel (Reg 46N), G7 dependency goods (Reg 46Y), and Russia's vulnerable goods (Reg 46Z30); and
• the provision of technical assistance, brokering services, financial services or funds related to the above.

The Export Control Joint Unit (ECJU) is responsible for administering the trade licensing provisions on behalf of the Department for Business and Trade.

Trade restrictions: third country processed iron and steel measures – measure in force

(Chapter 4CA, Regulations 46IA - 46IE)

Guidance

The restrictions relating to Russian iron and steel processed in third countries are in force as of 30 September 2023. The measures were introduced on 20 April 2023 – for further detail see the original entry for 20 April below.

Asset Freeze - additions

Press Release

10 individuals and 1 entity have been added to the consolidated list and are now subject to asset freeze and trust services sanctions.

The individuals sanctioned are:

• Andrei Anatolievich Aleksyenko, Head of the Kherson regional administration.
• Igor Olegovich Babkin, Deputy Head of the LPRA.
• Natalya Alekseevna Budarina, Secretary of the Russian Central Election Commission.
• Viktor Andriyovych Emelyanenko, Deputy Head of the administration in Zaporizhzhia.
• Galina Anatolyevna Katyushenko, Chair of the Election Commission of the Zaporizhzhia region.
• Alexander Vyacheslavovich Kurenkov, Minister of the Russian Federation for Civil Defence, Emergencies and Elimination of Consequences of Natural Disasters.
• Oleg Georgevich Shapovalov, Minister of Justice of the Republic of Crimea.
• Alexander Gennadievich Sidyakin, Head of the Central Executive Committee of United Russia.
• Vladimir Vladimirovich Yezhikov, Acting Deputy Chairman of the Government of the Donetsk People's Republic.
• Marina Yuryevna Zakharova, Head of the Election Commission of the Kherson Region.

The entity sanctioned is the Russian Central Election Commission.

General Licence: Correspondent Banking Payments (Russia and Belarus)

[INT/2023/3566356]

Publication notice

OFSI has issued a General Licence permitting a Credit or Financial Institution to return a Relevant Payment to the Credit or Financial Institution which sent the Relevant Payment directly to it, so long as neither the sending or receiving Credit or Financial Institution are a designated person (DP).

"Relevant Payment" means a payment;

• which has been received by a Credit or Financial Institution which is not a DP; and
• which was received directly from a Credit or Financial Institution which is not a DP; and
• which has, at some point in the chain of payments, been processed by a Credit or Financial Institution which is a DP acting as an originating, correspondent or intermediary institution; and
• where both the original account holder (the entity/individual which holds the account at the first institution in the chain of payments) and the original intended recipient (the entity/individual which holds the account at the final institution in the chain of payments) of the payment are not DPs.

This licence is issued for the purpose of providing certainty and does not reflect a view that UK financial sanctions are engaged by the actions referred to in this licence. Any act which would otherwise breach the prohibitions in Regulations 11 to 15 of the Russia Regulations or the Belarus Regulations is exempt from those prohibitions to the extent required to give effect to the permissions in this licence.

This licence took effect from 29 September 2023 and expires at 23:59 on 1 December 2023.

Guidance: Exporting Commercial Goods - Russia Sanctions – Common High Priority Items List

See also: US press release

Australia, Canada, New Zealand, the UK, and the US (collectively referred to as "the Export Enforcement Five" or "E5") have issued joint guidance to industry and academia identifying high priority items critical to Russian weapons systems and urging specific actions to prevent diversion of these items to Russia through third countries.

The Guidance contains a list of 45 prioritized Harmonized System (HS) codes containing items Russia needs for its weapons systems, of which nine codes are the highest priority. The list will be updated when required.

The Guidance also contains information on diversion concerns as well as due diligence tips for screening such parties, and red flag indicators.

General Licence: Payment to water companies for water and sewage

[INT/2023/3179120]

OFSI has issued a General Licence which permits payment to water companies for water and sewage services by UK designated persons (DPs) who own or rent properties in the UK. The General Licence permits:

• UK DPs to make the permitted payments to water companies from a frozen UK bank account;
• any person to make a permitted payment to a water company (directly or indirectly), for or on behalf of a DP or for the benefit of a DP;
• water companies to receive the permitted payments;
• water companies to make return payments to frozen UK bank accounts; and
• UK DPs to receive return payments from water companies into a frozen UK bank account.

This licence takes effect from 21 September 2023 and expires at 23:59 on 20 September 2025.

General Licence: Oil Price Cap – exempt projects and countries – amendment (Sakhalin-2 Project)

[INT/2022/2470156]

The General Licence has been amended to extend the expiration date of the exemption for the Sakhalin-2 Project to 28 June 2024 (see: Schedule 1 - Exempt Projects).

See also: publication notice

The Department for Business & Trade and the Department for International Trade have published a notice explaining the scope of the measures relating to Russian iron and steel processed in third countries, including:

• Guidance on demonstrating compliance;
• Licensing provisions;
• An explanation of how the rules may apply in HMRC inspections; and
• What constitutes "iron and steel" product.

The measures were introduced on 20 April 2023 (see below) are due to come into effect on 30 September 2023.

Asset freeze – additions

Cyber Sanctions – Russian cybercrime group designated (Notice)

The Cyber (Sanctions) (EU Exit) Regulations 2020 (S.I. 2020/597)

Press Release

11 members of a Russian cybercrime group have been designated and are now subject to an asset freeze. This was the cyber criminal gang behind the Trickbot/Conti ransomware attacks, which included the hacking of crucial infrastructure and hospitals during the COVID-19 pandemic.

The individuals designated are:

• Mikhail Vadimovich Chernov;
• Maksim Sergeyevich Galochkin;
• Maksim Marselevich Khaliullin;
• Artem Igorevich Kurov;
• Sergey Loguntsov;
• Alexander Vyacheslavovich Mozhaev;
• Dmitry Sergeevich Putilin;
• Maskim Rudenskiy;
• Mikhail Tsarev; and
• Vadym Firdavysovych Valiakhmetov.

This was a joint action by the UK FCDO and the US OFAC.

OFSI has used its disclosure powers for the first time, by disclosing that a UK fintech firm had breached financial sanctions after a cash withdrawal of £250 was made from a business account held by a company owned or controlled by a Designated Person. In particular, OFSI found that the firm's systems and controls in response to the sanctions designation were inappropriate.

Where OFSI decides it is necessary and proportionate, OFSI will publish details of a breach on its website in the form of a notice. The intention is to use the power in response to moderately severe breaches, when a warning letter would be too lenient but a monetary penalty would be disproportionately punitive.
OFSI has published a blog update with further information

OFSI has also updated Section 10 of its Enforcement and Monetary Penalty Guidance to provide further detail on how it assesses the severity of breaches.

General Licence – Amendment

Telecommunications Services and News Media Services
(Continuation of Business and Basic Needs) - INT/2022/1875276

OFSI has made an amendment to this General Licence to clarify that:

• PJSC MegaFon is a "Civilian Telecommunication Designated Person"; and
• PJSC MegaFon is a "News Media Services Designated Person".

See entries at 30 May 2022 and 26 June 2023 for more information on this General Licence.

General Licence – Amendment

GTLK Companies and their Subsidiaries – Insolvency related payments and activities - INT/2023/3263556

OFSI has made an amendment to this General Licence to make clear that STLC Europe Nine Leasing Limited is covered by the General Licence.

Annex 1, which provides a list of non-exhaustive subsidiaries, has been amended to reflect this.

See entry at 1 August 2023 for more information on this General Licence.

General Trade Licence: Russia sanctions: Legal Advisory Services

See Notice to Exporters NTE 2023/16

A General Trade Licence has been granted by the Secretary of State which authorises the direct or indirect provision of legal advisory services below, so far as otherwise prohibited by the Legal Advisory Services regulation (Regulation 54D).

The licence authorises legal advisory services:

• as to whether an act or a proposed act complies with, or could trigger punitive measures (which includes administrative penalties) in relation to, restrictive measures, including sanctions, export and import controls on or controlling Russia or the non-government controlled Ukrainian territory, imposed by any jurisdiction.
• in relation to, or in connection with compliance with, or addressing the risk of punitive measures (which includes administrative penalties) in relation to:
  
  • restrictive measures, including sanctions, export and import controls on or concerning Russia or the non-government controlled Ukrainian territory, imposed by any jurisdiction;
  • any laws of Russia that have as their object or effect the frustration of any laws specified at (i); and/or
  • any criminal law imposed by any jurisdiction.
• where the legal advisory services are provided in relation to the discharge of or compliance with UK statutory or regulatory obligations.

There are various conditions and requirements, including registration of certain details on SPIRE and records requirements. Failure to comply with any conditions may result in use of the licence being revoked or suspended.

The licence comes into force on 11 August 2023.

Asset Freeze additions

Press Release

10 individuals and 9 entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions.

The individuals sanctioned include:

• Iranian individuals, member of the Board of Paravar Pars, which make available Unmanned Aerial Vehicles (UAV) technology, contributing to destabilising Ukraine (Mohsen Asadi, Mohammad Reza Mohammadi, Mohammad Sadegh Heidari Musa, Abulfazel Nazeri, Hossein Shamsabadi, Ali Reza Tangsiri, Abolghasem Valagohar);
• Ali Reza Balali, Iran national, Senior Adviser to the Chief of the Islamic Revolutionary Guards Corps Aerospace Force.
• Ashot Mkrtchev, Slovakian national, for his involvement in an attempted arms deal between the Democratic People's Republic of Korea (DPRK) and Russia; and
• Anselm Oskar Schmucki, Swiss national, for his role in Russia's financial services sector, including through working as Chief of the Moscow office of DuLac Capital Ltd.

The entities sanctioned include:

• Aeromotus Unmanned Aerial Vehicles Trading LLC;
• Azu International Ltd Sti;
• Islamic Revolutionary Guard Corps – Research And Self-Sufficiency Jihad Organization (IRGC-SSJO);
• Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization (IRGC-ASF SSJO);
• LLC Staut;
• LLC Testkomplekt;
• Paravar Pars Co;
• Smt-Ilogic; and
• Turkik Union Dijital Teknoloji Donusum Ofisi.

Belarus: Asset Freeze – additions

Press Release

6 entities have been added to the consolidated list and are now subject to an asset freeze:

• Belomo Holding;
• Joint Stock Company 2566 Radioelectronic Armament Repair Plant;
• Jsc Peleng;
• Open Joint Stock Company Gomel Radio Plant;
• Open Joint Stock Company Kidma Tech; And
• Open Joint Stock Company Orsha Aircraft Repair Plant.

 OFSI has updated its reporting forms for the Oil Price Cap (OPC) and Maritime Services Ban General Licences.

The updates provide additional information on the following:

• How to complete and return the reporting forms;
• Navigating around the OPC website; and
• Using the published guidance to assist in fulfilling reporting requirements.

OFSI strongly encourages use of the new forms immediately, however previous versions will still be accepted after 4 August 2023.

General Licence: GTLK Companies and their Subsidiaries – Insolvency related payments and activities

INT/2023/3263556

This General Licence permits:

• Any Person (which includes GTLK Companies – GTLK Europe and GTLK Capital, a Subsidiary and an Insolvency Practitioner) to make, receive or process any payments, or take any other action in connection with any Insolvency Proceedings, whether prior to or after the commencement of such proceedings.

• A Relevant Institution may process payments made in accordance with the above.

This licence is subject to a condition that no funds or economic resources shall be made available to or for the benefit of a person designated under the Russia Regulations including any entity owned or controlled by such a person, except for the GTLK Companies and any of their Subsidiaries.

The licence has notification and record-keeping requirements and takes effect from 1 August 2023 and expires at 23:59 on 31 July 2025.

This General Licence has been amended – please see entry at 23 August 2023.

6 individuals have been added to the consolidated list and are now subject to asset freeze and trust services sanctions:

• Vitaly Alexsandrovich Belitsky, Ekaterina Mikhailovna Dorokhina and Natalia Nikolaevna Dudar, all Moscow City Court Judges;
• Boris Georgievich Loktionov and Anna Evgenievna Potychko, General Prosecutor’s Office; and
• Danila Yurievich Mikheev, state prosecution’s “expert” witness in the trial against Vladimir Kara-Murza.

The individuals have been designated for their involvement in the politically motivated conviction of Vladimir Kara-Murza, after Mr Kara-Murza lost his appeal in Moscow on 31 July 2023 and faces 25 years in prison. For more information, see this Press Release.

General Licence: Mongolia Energy Payments amendment

INT/2022/2085212

The General Licence permitting payments to a Sanctioned Bank or a Subsidiary for the purpose of making energy available for use in Mongolia has been extended and will now expire at 23:59 on 14 August 2025.

See entry at 16 August 2022 for more information.

OFSI has updated its general guidance relating to options available following a rejected licence application. The amendment removes the option to request from OFSI a review of its decision.

Paragraph 6.12 of the General Guidance now provides that if you have had an application for a licence refused, you have the following options:

• re-apply with new or supplementary evidence or new supporting arguments
• re-apply under a different derogation (where applicable); and
• seek to challenge the decision in court.

A challenge to a decision in the courts will require application to the High Court or Court of Session in Scotland.

Overseas territories: Order in Council extending UK sanctions

The Russia (Sanctions) (Overseas Territories) (Amendment) (No.2) Order 2023

This order makes the necessary amendments to give effect in the relevant British overseas territories to the following changes made to the Russia sanctions regime pursuant to the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (S.I. 2023/440); the Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2023 (S.I. 2023/665) and the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (S.I. 2023/713):

• to modify offences in relation to export of goods to non-government controlled Ukrainian territory;
• to modify relevant offences in relation to import of relevant processed iron or steel products and revenue generating goods from Russia; and
• to modify certain provision in relation to prohibitions on the provision of professional and business services.

The following individual has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions:

• Oleg Yurievich Tinkov, former stakeholder in TCS Group Holdings PLC and founder of Tinkoff Bank.

17 July 2023

Asset Freeze

14 entries have been added to the consolidated list and are now subject to asset freeze and trust services sanctions:

• Vladimir Solodov
• Sergey Kravtsov 
• Murat Kumpilov
• Eleanor Fedorenko
• Vitaliy Ganchev
• Vladimir Kovalenko
• Ksenia Mishonova
• Daria Morozova
• Vyacheslav Dukhin
• Lenara Ivanova
• Anton Krasovsky
• Olga Lyubimova
• Timofei Sergeitsev
• The Federal State Budget Educational Institution Artek International Children's Center.

The designations are said to be in response to Russia's attempts to destroy Ukrainian national identity, including 11 against those involved in the forced deportation of Ukrainian children.

12 July 2023

OFSI Guidance: update to licensing process - Returning incomplete applications – OFSI Blog

Updated General Guidance

OFSI has issued an update to its General Guidance and published a blog post on updates to the licensing process in relation to incomplete applications for a specific licence, or an amendment to an existing specific licence.

To help mitigate the impact on applicants, OFSI has until now been returning incomplete applications to the applicant, and engaging until sufficient details and evidence have been received. The blog post explains that OFSI will be ending this temporary measure and will return applications which are not complete at the time of receipt. Applicants will be able to reapply, but this will be treated as a new application.

The blog suggests that to ensure an application is complete, an applicant may wish to:

• fully complete an application form;
• read OFSI’s Introduction to Licensing Blog;
• read OFSI’s Reasonableness in Licensing Blog;
• check if there are any applicable General Licences;
• consult the relevant regime specific guidance and the prohibitions and licensing purposes of the Regulations; and
• seek independent legal advice.

6 July 2023

Asset Freeze - removal

The following individual has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions:

• Lev Aronovich Khasis, former First Deputy Chairman of the Management Board at Sberbank.

29 June 2023

(in force 30 June 2023)

Trade restrictions– access to UK legal expertise: A new prohibition on the provision of legal advisory services

(amendment to Chapter 6B of Part 5)

The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2023

The UK Government has imposed prohibitions on the provision of legal advisory services – Regulation 54D.

A person must not directly or indirectly provide legal advisory services to any person who is not a UK person in relation to, or in connection with, specified activity which would be prohibited under the UK sanctions regime if the activity was done by a UK person or was taking place in the UK.

The specified activities which would contravene the UK sanctions regime are certain financial or trade activity (under Regulations 11 to 18C of Part 3 (asset-freeze and other financial and investment restrictions), and Chapters 2 to 6 or Chapter 6B of Part 5 (trade restrictions)).

"Legal advisory services" is defined to mean the provision of legal advice to a client in certain non-contentious matters.

It does not include any representation, advice, preparation of documents or verification of documents undertaken as part of legal representation services provided in, or in anticipation of (i) any proceedings before administrative agencies, courts or other duly constituted official tribunals; or (ii) arbitral or mediation proceedings.

This is subject to exceptions and licences.

A government Press Release has stated that the new law will "prevent UK lawyers from advising Russian companies in certain business deals – thwarting the nation from benefitting economically from the UK's world-leading legal expertise".

Trade restrictions– access to UK legal expertise: Exceptions

(amendment to Part 7)

Exceptions are introduced to the new prohibition on legal advisory services – Regulation 60DB. These include providing legal advisory services:

• that are necessary for the official purposes of a diplomatic mission or consular post in Russia, or of an international organisation enjoying immunities in accordance with international law;
• in relation to the discharge of or compliance with UK statutory or regulatory obligations;
• in relation to whether an act or proposed act complies with the Russia sanctions regulations;
• in satisfaction of an obligation arising under a contract concluded before 30 June 2023, or an ancillary contract necessary for the satisfaction of such a contract, provided that the act is carried out before the end of 29 September 2023 and the Secretary of State is notified by that same date.

An amendment is also made to Regulation 61 to ensure an exception for emergencies in certain cases.

Trade restrictions–:
Exceptions to the prohibition on provision of professional and business services

(amendment to Regulation 60DA)

New exceptions are introduced to the prohibition on the provision of professional and business services to a person connected with Russia for:

• the provision of auditing services where there are statutory or regulatory obligations; and
• in relation to the provision of expert evidence in connection with legal proceedings.

28 June 2023

OFSI/OFAC Fact Sheet – Humanitarian Assistance and Food Security

OFSI have published a joint fact sheet with OFAC to provide clarity on US and UK Russia sanctions. The statement provides guidance for use by humanitarian actors, NGOs, financial institutions, and companies engaged in agricultural trade or the provision of medical supplies and assistance, when engaging in transactions impacted by sanctions.

The statement answers FAQs from both a US and UK perspective. This include questions on:

• exceptions for NGOs or international organisations providing humanitarian assistance;
• whether financial institutions can process transactions related to the export of agricultural commodities, medicine or medical devices to, from, transiting or related to Russia; and
• whether financial institutions can process transactions involving Joint Stock Company Russian Agricultural Bank related to the export of agricultural commodities to, from, transiting, or related to Russia.

The joint statement also sets out a summary of key authorisations for certain activities both within the UK and US jurisdictions, and key humanitarian guidance.

26 June 2023

General Licence - Telecommunications Services and News Media Services

(Continuation of Business and Basic Needs) - amendment

(INT/2022/1875276)

OFSI have published amendments to the 'Telecommunications Services and News Media Services (Continuation of Business and Basic Needs)' General Licence as follows:

• Certain entities have been removed, which OFSI does not believe are owned or controlled by designated persons. These include:
  • Mobile TeleSystems PJSC (MTS);
  • PJSC Moscow City Telephone Network (MGTS);
  • and PJSC MegaFon.
• Rossiya Segodnya, a media group owned and operated by the Russian government, has been added as a News Media Services DP; and
• Certain subsidiaries of ZAO TransTeleCom have been added as Civilian Telecommunications DPs.

See entry at 30 May 2022 for more information on this General Licence.

See entry at 23 August 2023 for information on an amendment to this General Licence, with PJSC MegaFon included as Civilian Telecommunications and News Media Services DPs.

General Licence – Evraz – amendment

(INT/2022/1710676)

The General Licence permitting the continuation of business operations involving the North American subsidiaries of Evraz plc has been extended and will now expire at 23:59 on 31 March 2024.

In addition, the definition of North American Subsidiaries under the General Licence was amended on 4 May 2023 to make clear that the subsidiaries of Evraz Inc. NA and Evraz Inc. NA – Canada are covered by the General Licence.

See entry at 5 May 2022 for more information on this General Licence.

20 June 2023

General Licence: Humanitarian activity – amendment

(INT/2022/1947936)

OFSI have published amendments to the "Humanitarian Activity" General Licence, as follows:

• The definition of "Non-government controlled Ukrainian territory" now includes the Kherson and Zaporizhzhia oblasts; and
• The Designated Financial Institutions listed in Annex 1 now captures financial institutions designated since 7 July 2022. These include:

• Bank St Petersburg PJSC;
• Bank Uralsib PJSC;
• MTS Bank PJSC;
• Bank Zenit PJSC;
• Bank DOM.RF (designated by virtue of ownership);
• Rosbank PJSC;
• Tinkoff Bank;
• Russian Regional Development Bank; and
• PJSC JSCB Metallinvestbank.

19 June 2023

(in force 20 June 2023)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2023

Explanatory Memorandum

Russia (Sanctions) (EU Exit) Regulations 2019: updated purpose

(amendment to Regulation 4)

Amendment to introduce a new purpose to the 2019 Regulations to state that, in addition to the current purposes in regulation 4, the regulations are for the purposes of:

• "promoting the payment of compensation by Russia for damage, loss or injury suffered by Ukraine on or after 24th February 2022 as a result of Russia’s invasion of Ukraine".

The Explanatory Memorandum states that this change "reflects the UK position that Russia bears full responsibility or the war and the damage it has caused, including to Ukraine’s critical infrastructure, The UK considers that sanctions measures can contribute to the objective to make sure Russia pays compensation for the damage it has caused".

Trade sanctions: amendment to extend existing restrictions to include the Kherson and Zaporizhzhia Oblasts

(various)

Amendment to the existing definition of "non-government controlled Ukrainian territory" to include the non-government controlled areas of the Kherson and Zaporizhzhia oblasts.

A number of consequential amendments to extend existing sanctions and relevant exceptions to these non-government controlled areas:

• Export of relevant restricted goods to non-government controlled Ukrainian territory – Regulation 30B
• Export of infrastructure-related goods to non-government controlled Ukrainian territory – Regulation 48
• Export of restricted goods – Regulation 53A
• Port directions – Regulation 57
• Exceptions relating to investments in relation to non-government controlled Ukrainian territory – Regulation 60
• Trade: exception for humanitarian assistance activity – Regulation 61ZA

19 June 2023

UK Government announcement

Designated individuals - voluntary donation of assets

(announced but not yet implemented)

The UK Government has stated that it intends to introduce a route for sanctioned individuals who support Ukraine to voluntarily donate their frozen funds for Ukrainian reconstruction. The precise mechanics of the fund which will disburse these donations will be announced in due course.

The Government has stated that there will be no coercion of individuals to encourage them to transfer funds, nor any offer of sanctions relief in return for making a donation.

More information will be included on this tracker once available.

Increased reporting obligations

(announced but not yet implemented)

The UK Government has stated that it intends to pass new legislation imposing additional reporting obligations, as follows:

• persons and entities in the UK, or UK persons and entities overseas, who are designated under the Russia financial sanctions regime, must disclose assets they hold in the UK. The failure to disclose assets may lead to the imposition of further financial penalties or confiscation of assets.
• those holding assets in the UK on behalf of the Central Bank of Russia (CBR), Russian Ministry of Finance (MOF) or Russian National Wealth Fund (NWF) to disclose them to the Treasury. The Government has stated that this will help ensure it has a comprehensive picture of their value and nature and will assist the Treasury in monitoring compliance with, and detecting evasion of, financial sanctions.

More information will be included on this tracker once available.

14 June 2023

Oil Price Cap: updated OFSI guidance

OSFI has published updated guidance for the Maritime Services Ban and Oil Price Cap, to provide additional clarity and detail on the following:

• Wind-down periods: We are confirming that OFSI will introduce a 45-day wind-down period for any future changes to the Oil Price Cap
• Trading in Derivatives and Futures: Trading in derivatives and futures is now exempt from the Oil Price Cap (see entry below for the relevant General Licence)
• "As soon as reasonably practicable": Clarification has been added on OFSI’s view of what is considered to be taking the required steps to withdraw contracted services “as soon as reasonably practicable” in the event of a suspected breach

Bespoke reporting forms for required reporting, reporting suspected breaches, and specific licence applications are on OFSI's website.

Any reporting or queries should be directed to oilpricecap.OFSI@hmtreasury.gov.uk

General licence: Oil Price Cap - Trading in Derivatives and Futures

(INT/2023/3074680)

 This General Licence permits:

• trading in "Derivatives" and "Futures" related to the supply or delivery by ship of Russian oil and oil products which would otherwise breach the prohibition in regulation 46Z9C of the Russia Regulations;
• a "Derivative Broker" to provide services to any Person trading in Derivatives and Futures in accordance with the above; and
• a Relevant Institution to process payments in relation to the activities permitted under the General Licence.

"Derivative" means a financial instrument whose value is based on the change in value of an underlying asset.

"Derivatives Broker" means a person who buys and sells assets for others.

"Futures" means a type of derivative contract to buy or sell a specific commodity asset or security at a set future date for a set future price.

This licence takes effect from 14 June 2023 and is of indefinite duration.

General licence: Securing Energy for Europe General Licence – revoked

(INT/2022/2305324)

OFSI has revoked the "Securing Energy for Europe" General Licence.

The nationalisation of Gazprom Germania (renamed Securing Energy for Europe) means that Gazprom's UK subsidiaries are no longer in scope of the credit restrictions introduced by The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022, which this General Licence was designed to lift. OFSI therefore no longer considers there to be a need for this General Licence.

8 June 2023

Belarus: new sanctions package

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023

UK Government press release

Belarus: amendments to designation criteria

(amendment to Regulation 6)

Additions to / further explanation of the criteria for designation by expanding the definition of "involved person" to include:

• holding the right to nominate at least one director, trustee or equivalent of a Government of Belarus-affiliated entity, or an entity carrying on business of economic or strategic significance to the Government of Belarus;
• working for, or being affiliated to, the Government of Belarus by way of holding certain specified roles, including certain political positions, or holding senior positions at certain state-owned entities or in the military; and
• clarifying that being "associated with" any person who meets the designation criteria includes obtaining a financial benefit or other material benefit from that person; or being an immediate family member of that person.

Belarus: amendments to restrictions on dealing with securities/money-market instruments

(amendments to Regulation 15A)

Expanding the existing restrictions to include securities/money-market instruments issued by persons acting on behalf or upon the direction of Belarus, a Belarusian authority, or an entity wholly owned by Belarus or a Belarusian authority.

Belarus: trade restrictions – export of goods /technology to Belarus

(amendments to Regulations 21-26)

Expanding the existing restrictions on exports (including the supply from a third country) to or for use in Belarus to include:

• banknotes (denominated in sterling or any official currency of the EU);
• chemical and biological weapons-related goods and technology (as specified in Schedule 2H); and
• machinery-related goods and technology (as specified in new Schedule 2I).

Belarus: trade restrictions – import of goods/ technology from Belarus

(amendments to Regulations 27I-27M)

Expanding the existing restrictions on imports from Belarus (including the supply to countries outside the UK) to include:

• gold, gold jewellery and relevant processed gold (as specified in new Schedule 2J); and
• cement, rubber and wood products (as specified in new Schedule 2J).

Belarus: prohibition on providing certain internet services

(new Regulations 27P, 45A, 56A and B)

New restrictions requiring providers of:

• social media services to take reasonable steps to prevent content that is generated directly on the service, or uploaded to or shared on the service, by a designated person being encountered by a user of the service in the UK;
• internet access services to take reasonable steps to prevent a user of the service in the UK from accessing, by means of that service, an internet service provided by a designated person; and
  application stores through which an application for an internet service may be downloaded or otherwise accessed to take reasonable steps to prevent a user of the application store in the UK from downloading or otherwise accessing, by means of that application store, an internet service provided by a designated person..

"designated person" means a person who is designated under regulation 5 for the purposes of this new regulation 27P (i.e. not a person designated for the purposes of an asset freeze).

OFCOM has the power to request a person to provide certain information for the purpose of monitoring compliance with or detecting evasion of regulation 27P.

OFCOM has the power to impose a monetary penalty up to £1 million for breach of regulation 27P or 45A.

Belarus: new exceptions to prohibitions

(various)

Introduction of certain exceptions for the new prohibitions, including:

• Luxury goods: jewellery/gold jewellery of a non-commercial nature, which is owned by individuals travelling to Belarus or the UK and not intended to sale (Regulation 31D);
• Banknotes: banknotes for the personal use of individuals travelling to Belarus up to the value of £10,000 (Regulation 31J);
• Machinery-related goods/technology: humanitarian assistance activity; addressing a health emergency; providing a response to a natural disaster; medical or pharmaceutical purposes for the benefit of the civilian population of a country; temporary use by news media; ensuring cyber-security and information security for persons in Belarus (Regulation 31K).

The General Licence was amended to allow the Grain and Feed Trade Association (GAFTA) to receive Funds and Economic Resources from any person in connection with the direct and indirect provision of services related to contracts for the trade in agricultural commodities, by or on behalf of GAFTA.

See the original entry for this general licence dated 4 November 2022 for further detail.

The General Licence INT/2022/1552576 was amended to allow:

• Designated Person (DP) Representatives to pay funds to the London Court of International Arbitration (LCIA) to cover arbitration costs
• DPs or DP Representatives to transfer funds to their legal representatives for onward payment to the LCIA to cover arbitration costs
• Non-DP arbitral parties to pay substitute deposit(s) to the LCIA

See the original entry for this general licence dated 17 October 2022 for further detail.

The FCDO has issued a communication identifying a "Common High Priority Items List" composed of Western items critical to Russian weapons systems and its military development. The communication states that businesses should undertake due diligence to ensure that the end destination of these items is not Russia.

Together with its international partners, the UK has identified items that Russia is using in its weapons system. Many of these have been found on the battlefield in Ukraine. They include electronic components such as integrated circuits and radio frequency (RF) transceiver modules. The list, which will be updated when required, also includes items that are essential for the manufacturing and testing of the electronic components and circuits retrieved from the battlefield.

The list is divided into four Tiers:

• Tier 1: Integrated circuits (also referred to as microelectronics);
• Tier 2: Electronics items related to wireless communication, satellite-based radio navigation, and passive electronic components;
• Tier 3: Discrete electronic components, electronics cabling and connectors, digital cameras and related optical components; and
• Tier 4: Manufacturing, production, and quality testing equipment of electric components and circuits.

The UK is working with international partners to tackle sanctions avoidance and evasion including closing routes that Russia is potentially using to circumvent sanctions.

The Common High Priority Items List does not represent the extent of the UK's trade sanctions against Russia.

OFSI has published a blog post 5 months on from Trust Services sanctions coming into effect on 16 December 2022.

The blog aims to provide further clarity on themes arising from questions OFSI has received.

The blog covers when Trust Services sanctions apply, where the sanctions apply, key exceptions, OFSI's enforcement powers and licensing.

See also: OFSI's homepage on trust services sanctions.

OFSI has issued a General Licence which permits a Designated Person to transfer funds or economic resources to UK persons in satisfaction of a contractual obligation, provided that:

• The contractual obligation arose before the Designated Person became designated;
• Payment is for the benefit of a UK person;
• The total value of the payment due does not exceed £200,000 inc. VAT;
• The contract is not one of the excluded contracts listed in Annex A of the General Licence; and
• No payments are made to another Designated Person.

A bank or financial institution, which is itself a Designated Person and required to process payments made in accordance with this licence, may process such payments.

This General Licence is subject to reporting and record-keeping requirements.

This licence takes effect from 22 May 2023 and expires at 23:59 on 21 November 2023.

The UK Department for Business & Trade has published a guidance note for companies to help them understand what they need to do to ensure they are complying with the Russia sanctions. The aim of the notice is to prevent the undermining of trade sanctions, export controls and other restrictive measures designed in response to Russia's invasion of Ukraine.

The guidance covers:

• Due diligence;
• The procurement cycle and types of entities likely to acquire goods covertly; and
• Key risk indicators.

The G7 leaders published a statement of continued commitment against Russia's war against Ukraine, following the G7 meeting in Hiroshima on 19 May.

The statement noted the following measures to be taken in relation to sanctions and other measures:

• Further restriction on exports of all items critical to Russia's aggression including exports of industrial machinery, tools and other technology that Russia uses;
• Key sectors to be targeted including manufacturing, construction, transportation and business services;
• Continued shielding of agricultural, medical and humanitarian products from restrictive measures and making every effort to avoid potential spill over impact on third countries;
• Prevention of evasion and circumvention of measures against Russia, including targeting entities transporting materials to the front;
• Engaging with third countries to strengthen third countries' understanding of G7 measures;
• Coordination to prevent and respond to third parties supplying weapons to Russia;
• Curtailing Russia's use of the international finance system to further its war in Ukraine and taking further measures against those who wilfully support the financing of Russia's war;
• Reducing avenues for Russia to circumvent financial measures including by preventing third-country branches of Russian banks from being used to avoid sanctions and actions against Russia's financial sector;
• Reducing Russia's revenue by limiting energy revenue and future extractive capabilities, building on measures taken so far including export bans and price caps for crude oil and refined oil products;
• Reducing reliance on civil nuclear and related goods, working to assist countries seeking to diversify their supplies;
• Reducing Russia's revenue from metals; and
• Restriction of trade in and use of diamonds mined, processed or produced in Russia and engage with key partners with the aim of ensuring effective implementation of future coordinated restrictive measures, including through tracing technologies.

Asset freeze – additions and removals

86 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• 42 individuals; and
• 44 entities.

The entities include the following banks: DOM.RF, Rosbank PJSC, Tinkoff Bank, Russian Regional Development Bank, and PJSC JSCB Metallinvestbank.

These designations target individuals on the Boards of Directors of Sovcomflot, Russian Railways, Gazprom Neft, and Transneft, alongside individuals and entities in the shipping, energy, military and defence sectors. This includes companies connected to the theft of Ukranian grain, the shipment of Russian energy and companies connected to Rosatom, which are producing advances materials and technology in support of Putin's military efforts.

Additionally, the following individuals have been removed from the consolidated list and are no longer subject to an asset freeze or trust services sanctions:

• Nikolay Yurievi Petrunin;
• Kyrylo Sergiyovich Stremousov; and
• Vladimir Nikolayevich Sungorkin.

Prime Minister Rishi Sunak has announced incoming import bans on Russian diamonds and metals at the G7 in Japan.

In further comments made on 22 May 2023, UK Prime Minister Rishi Sunak has also committed to a new package of sanctions.

OFSI has issued a General Licence which permits a UK legal firm or UK counsel who has provided legal advice to a person designated under either the Russia or Belarus regime to receive payment from that designated person without an OFSI specific licence, provided that the terms of the General Licence are met. The existing Legal Fees General Licence issued on 28 October 2022 expires on 28 April 2023 (see below).

The licence is split into two parts:

• Part A: legal services based on a prior obligation; and
• Part B: legal services not based on a prior obligation.

Each has its own set of conditions and there is a separate legal fees and expenses cap for each part.

The previous legal fees caps and expenses caps have been reset. Users will be able to make use of the legal fees caps (£500,000 inc. VAT) and the expenses caps (5% of legal fees, up to £25,000) under Parts A and B of the General Licence. The General Licence also contains maximum hourly rates for fee earners.

Legal fees and expenses for cases involving defamation or malicious falsehoods are not permitted to be paid under this General Licence.

The General Licence is subject to reporting and record-keeping requirements.

This General Licence takes effect at 00:01 on 29 April 2023 and expires at 23:59 on 28 October 2023.

3 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions for their involvement in a politically motivated case against and arrest of opposition politician Vladimir Kara-Murza:

• Andrey Andreevich Zadachin, investigator at the Investigative Committee of the Russian Federation;
• Denis Vladmirovich Kolesnikov, Head of the Investigative Department; and
• Elena Anatolievna Lenskaya, Judge at the Basmanny Court in Moscow.

20 April 2023

The Russia Sanctions (EU Exit) (Amendment) Regulations 2023

Explanatory memorandum

Trade restrictions: new category of revenue generating goods – supply to third countries

(new Chapter 4GA - Regulations 46XA – 46XG, and Schedule 3DA)

Prohibition on the following activities in respect of a new category of revenue generating goods (as listed in new Schedule 3DA):

• imports which are consigned from Russia
• direct or indirect acquisition of such goods which originate or are located in Russia
• direct or indirect supply from a place in Russia to a third country
• associated technical assistance, financial services and funds, and brokering services in respect of the above.

The restrictions in respect of the goods listed in Part 3 of Schedule 3DA will not apply to any goods which are either consigned from Russia or imported into the UK before 21 April 2023.

Revenue generating goods that have an important humanitarian or civilian use, such as certain agricultural and energy-related goods (as listed in the amended schedule 3D) are not covered by this new prohibition on supply and delivery from Russia to third countries.

The prohibition on the acquisition of these goods, and associated services, do not apply to:

• goods which have been lawfully imported into the UK; and
• a UK national in Russia where the goods are located in Russia and the goods are for personal use/use by immediate family members in Russia

The restrictions are also subject to the existing exceptions, such as humanitarian assistance.

The existing Schedule 3D (revenue-generating goods) has been recast in light of these changes.

Further amendments to existing trade restrictions:

• a new Part 3 has been added to the "iron and steel products" in Schedule 3B
• various amendments – additions and deletions – have been made to the list of "revenue generating goods" in Schedule 3D (a number of the deletions now appear in the new Schedule 3DA)

The restrictions in respect of the goods listed in Part 3 of Schedule 3B and Part 3 of Schedule 3D will not apply to any goods which are either consigned from Russia or imported into the UK before 21 April 2023 (Regulation 60G).

• amendments to Schedule 2A (Critical-industry goods and critical-industry technology)
• additions to Schedule 3C (Defence and security goods and defence and security technology)
• amendments to Schedule 3E (G7 dependency and further goods)
• amendments to Schedule 3I (Russia’s vulnerable goods)

A number of these amendments are intended to bring a range of goods found on the battlefield within the scope of existing restrictions.

Trade restrictions:–iron and steel products processed in a third country

(new Chapter 4CA, Regulations 46IA - 46IE) 

Introduction of a new prohibition on the import of specified iron and steel products which have been processed in a third country and which incorporate one or more iron or steel products originating in Russia on/after 30 September 2023.

The "iron and steel products" are listed in Schedule 3B.

For the purposes of this restriction, "processed" means altered; transformed in any way; or subjected to any other type of operation or process.

Includes a prohibition of the provision of associated technical assistance, financial services and funds, and brokering services. 

General Licence - Lithuania Rail

This General Licence permits:

• Russian Railways to pay Lithuanian Railways for Relevant Passenger Rail Travel, which is the transit of persons between the Kaliningrad Region and other parts of Russia via LTG's passenger rail service;
• Lithuanian Railways to receive payment from Russian Railways for the same; and
• A person (not including Russian Railways or any other designated persons including persons owned or controlled, directly or indirectly by such designated persons) to carry out activity reasonably necessary to effect payment of the same.

This licence takes effect from 14 April 2023 and expires at 23:59 on 13 April 2025.

The updated guidance clarifies the position on co-mingling and provides information on what suppliers should do to ensure they comply with sanctions.

The update reinforces that the prohibitions apply regardless of the importer's knowledge or suspicions about the origin of the goods, their location or the place from which they were consigned. Breaching the prohibitions can be a criminal offence.

14 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• 10 individuals; and
• 4 entities, namely Curzon Square Limited, Hanley Limited, Meritservus HC Limited and USM Holdings Limited.

These designations are said to target those who have knowingly assisted sanctioned Russia oligarchs to hide their assets in complex financial networks. 

OFSI has updated its "UK Maritime Services Ban and Oil Price Cap" industry guidance. This document provides guidance regarding the UK ban on the provision of maritime transportation of certain Russian oil and oil product, and associated services.

See entry dated 3 November 2022 for more information on the introduction of this prohibition.

Permits:

• an issuer (who is not a Designated Person) which has/may have bondholders who are Designated Persons to effect the terms of any restructuring or amendments agreed between the issuer and its bondholders; and
• a UK Person (including financial institutions) to take any steps necessary to effect a bond restructuring or amendment.

These permissions are subject to the condition that no funds or economic resources are to be made available, directly or indirectly, to a Designated Person. Any funds or economic resources that a Designated Person would be entitled to as part of a bond restructuring or amendment must be frozen.

The licence expires at 23:59 on 28 March 2025 and is subject to reporting and record-keeping requirements.

Permits any activity necessary to terminate an arrangement for the provision of trust services to a Designated Persons which would otherwise be prohibited under Regulation 18C, including:

• The provision of trust services to a Designated Person on or after the date of their designation; and
• The processing of any associated payments by UK financial institutions

The General Licence allows for a 90-day period from the date on which a Designated Person becomes designated for the purposes of Regulation 18C to undertake any of the permitted activity.

Use of the General Licence requires a reporting form and associated evidence to be submitted to OFSI within 30 days of undertaking an activity under the General Licence. Use of the General Licence is also subject to a 6-year record-keeping requirement.

The following individual has been removed from the consolidated list and is no longer subject to an asset freeze:

• Brian MCDONALD, head of Russia Desk for the English language edition of RT (formerly Russia Today).

OFSI has updated its guidance covering enforcement and monetary penalties for breaches of financial sanctions. New sections relating to ownership and control have been included under sections 3.22-3.31.

In summary, the updated guidance provides that:

• Appropriate due diligence may be considered a mitigating factor where the determination reached by the firm with respect to ownership and control was reasonable and made in good faith. The onus of demonstrating the above will rest with the person against whom OFSI is considering taking enforcement action;
• OFSI will consider the nature of a person’s contractual or commercial relationship with the entity when assessing the appropriateness of measures undertaken;
• OFSI expects evidence of a decision making process taking into account the sanctions risk (e.g. by reference to an internal framework or policy);
• Aggravating factors may include a failure to carry out appropriate due diligence or the carrying out of any such due diligence in bad faith. The weight to be attributed to a mitigating or aggravating factor will be assessed on a case-by-case basis;
• A list of efforts that may be considered mitigating factors by OFSI are listed under section 3.26;
• A list of areas of enquiry OFSI may expect to be undertaken by a person seeking to investigate ownership and control are listed under section 3.29.

The UK Prime Minister announced the launch of a new fund (UKISF) to support the new Economic Deterrence Initiative (see entry below for more info). The UKSIF will have a budget of approximately £1 billion and will combine several other funds across the government.

An additional £50 million in funding has been provided, notably to improve enforcement of the UK’s sanctions regime. The government will also work with the private sector to maximise the reach of sanctions against those who pose a threat to the UK.

Government priority actions: sanctions evasion

(see also: Press Release)

The UK government published its ‘Integrated Review Refresh 2023: Responding to a More Contested and Volatile World’ (IR23).

The IR23 sets out a number of priority actions for the UK government. This includes establishing an "Economic Deterrence Initiative" to improve the UK's sanctions implementation and enforcement by strengthening the UK's diplomatic and economic tools.

The IR23 also indicated that the UK government will:

• publish more details on how the National Cyber Force conducts its operation (notably to counter sanctions evasion); and
• build expertise across the government to design, implement and enforce sanctions for maximum impact, develop an autonomous sanctions regimes, and deepen international coordination to assess, prepare for, deter and respond rapidly to future economic threats.

9 March 2023
(made on 8 March 2023)

Overseas territories:
Order in Council extending UK sanctions - trust services

The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2023

This Order makes the necessary amendments to give effect in the relevant British overseas territories to the following changes made to the Russia sanctions regime pursuant to the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022:

• to impose a new restriction in relation to the provision of trust services to designated persons or persons connected with Russia (and associated reporting requirements);
• to extend financial and investment restrictions;
• to add additional services to the existing provisions imposing restrictions relating to professional and business services;
• to provide for exceptions and licences relating to the new restrictions introduced by the amendments; and
• to add further items to the lists of goods subject to trade prohibitions.

The House of Commons has objected to the "Seizure of Russian State Assets and Support for Ukraine Bill" (see entry dated 7 February 2023 for more info). The Bill was introduced under the "Ten Minute Rule" and had its second reading (i.e. this was the first opportunity for MPs to debate the main principles of the Bill).

The Bill requires the Secretary of State to lay before Parliament proposals for the seizure of Russian state assets to provide support for Ukraine. Under the Bill, the Secretary of State must consider the following in preparing the proposals:

• the types of Russian state assets that should be seized;
• who determines which assets should be subject to seizure;
• for what purposes the seized assets could be applied; and
• who should hold and manage the application of seized assets.

The next sitting of the House of Commons to consider the Bill will be on 3 March 2023.

Asset Freeze

(See also Government press release)

92 entries have been added to the consolidated list and are now subject to an asset freeze. These include:

• 19 designations of individuals connected to Rosatom (a Russian state-owned nuclear power company);
• 19 designations of individuals connected to Rostec (a Russian state-owned defence conglomerate);
• 6 designations of entities involved in the manufacture or repair of military equipment for Russia’s armed forces, including aviation and navy, namely, JSC Izumrud, LLC Zavod Sokol, JSC Zavod EleKon, JSC Zvezda, JSC Rembaza, JSC Lomo;
• 15 designations of individuals connected to Almaz-Antey (a state owned Russian company specialising in producing surface to air missiles and firearms for aircrafts);
• 5 designations of senior Iranian executives in Qods Aviation Industry, the company manufacturing the drones used in Ukraine;
• 4 designations of individuals connected to the Kremlin wealth;
• 4 designations of Russian banks, namely Bank Saint Petersburg, Uralsib, MTS Bank and Bank Zenit; and
• 20 designations of executives connected to Gazprom and Aeroflot.

New package of sanctions- Press release

(announced but not yet implemented) 

In addition to the new designations (above), the UK has announced a new package of additional sanctions. This includes:

• Export ban of every item Ukraine has found Russia using on the battlefield to date, including aircraft parts, radio equipment, and electronic components that can be used by the Russian military industrial complex, including in the production of UAV;
• Import ban on 140 goods, including iron and steel products processed in third countries; and
• An extension of current measures against Crimea and non-government controlled territory in Donetsk and Luhansk oblasts to target Russian controlled areas of Kherson and Zaporizhzhia oblasts, restricting their access to UK trade and finance.

[Note: A more detailed breakdown of new restrictive measures will be included on this page once the relevant legislation has been published.]

OFSI has extended the expiry dates of the following general licences:

• The VTB (regulators) general licence titled "Russia: Regulatory Authorities – Prudential Supervision or Financial Stability" will now expire at 23:59 on 3 April 2025 (please see entry dated 1 March 2022 below for more information);
• The VTB (basic needs) general licence titled "Russian Banks – UK subsidiaries – Guernsey subsidiary – EU subsidiaries -Basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments" will now expire at 23:59 on 3 April 2025 (please see entry dated 1 March 2022 below for more information);
• The general licence titled "Payment to Energy Companies for Gas and/or Electricity" will now expire at 23:59 on 16 October 2023 (please see entry dated 17 November 2022 below for more information).  [This general licence now has no expiry date – see entry dated 13 October 2023 above for more information.]

The House of Commons Library published two research briefings: "Sanctions against Russia" and "Post-conflict reconstruction assistance to Ukraine".

The "Sanctions against Russia" paper provides an overview of the evolution of the UK sanctions regime since Russia's invasion of Ukraine;

The "Post-conflict reconstruction assistance to Ukraine" paper addresses the question of whether Russian sanctioned assets could be used for Ukraine's reconstruction and outlines the main legal issues with the proposal. In summary:

• The UK's current asset freezing regime prohibits those in possession of frozen economic resources to "deal" with them;
• Seizing private assets risks falling foul of bilateral agreements protecting foreign investors from unlawful expropriation;
• Seizing state-owned assets may also have international implications (e.g. conflict with the principle of non-intervention, or sovereign immunity in judicial proceedings);
• The proposal to seize Russian assets is likely to require a specific legal basis in international law (e.g. through the doctrine of countermeasures);
• From an international standpoint, there have also been developments in the US, the EU and Canada as to whether frozen Russian assets should be upgraded to seizure of assets and potentially redirected to the reconstruction of Ukraine.

Please refer to entries dated 20 January 2023 and 7 February 2023 below for more background information.

OFSI has amended the General Licence permitting a UK national/entity to purchase tickets from certain designated Russian travel companies, or any subsidiary, for flights or rail journeys within Russia or originating in Russia (see entry dated 23 May 2022 for more information).

The updated General Licence now permits:

• A UK individual or entity to purchase tickets from South Caucasus Railway CJSC (a subsidiary of Russian Railway) for passenger rail journeys between Armenia and Georgia and within either of those two countries; and

• A UK individual or entity, a financial institution, PJSC Aeroflot, JSC Rossiya Airlines, JSC Ural Airlines and Russian Railways, may carry out any activity reasonably necessary to effect the purchase of tickets for flights or rail journeys in accordance with the paragraph above.

This licence took effect from 23 May 2022 and expires on 23 May 2024.

7 Russian individuals have been added to the consolidated list under The Cyber (Sanctions) (EU Exit) Regulations 2020.

The sanctioned individuals form part of a Russian cybercrime group, Trickbot, and was one of the first cybercrime groups to back Russia's war in Ukraine according to the NCA. They have been sanctioned for their involvement in cyberactivity intended to undermine the integrity of the UK and other countries, or cause economic loss/prejudice commercial interests.

OFSI simultaneously published its Ransomware and Sanctions Guidance.

Note: These individuals do not explicitly bear a connection to Russia's invasion of Ukraine under OFSI's notice.

15 new entries have been added to the consolidated list and are now subject to an asset freeze. This includes the following individuals:

• Nikolai Dmitrievich EGOROV , Director of Antipinsky Oil Refinery JSC, and owner of Energetika Sodruzhestvo Uspekh LLC (two Russian energy companies);
• Svetlana Alexandrovna KRIVONOGIKH, Shareholder of Bank Rossiya (who is in turn a significant stakeholder in National Media Group);
• Viktor Evgenyevich MYACHIN, owner of Aerostart (an entity operating in the Russian transport sector);
• Alexander Evgenyevich REPIK, Chairman of the Boards of R-Pharmand and Delovaya Rossiya (one of Russia’s largest pharmaceutical companies);
• Sergei Olegovich RUDNOV, owner of Regnum News Agency (a Russian news agency);
• Evgeny Mikhailovich SHKOLOV, Deputy Chairman of the Board of Directors for JSC System Operator of the Unified Energy System (SO UES) (an entity carrying on business in the energy sector);
• Pavel Borisovich TITOV, Chairman of the Board of Directors of Abrau-Durso and President of Delovaya Rossiya (Business Russia); and
• Boris Yuryevich TITOV, Russia’s Presidential Commissioner for Entrepreneurs’ Rights and a prominent business person.

The new entries also include the following entities:

• AO NPP TOPAZ, a Russian based avionics company that develops and produces hardware and software used in military aircraft of the Armed Forces of the Russian Federation;
• JSC PLANT UNIVERSALMASH, a Russian based manufacturing plant, manufacturing the tracked chassis of the S-300V4 anti-aircraft missile system used by the Armed Forces of the Russian Federation in Ukraine;
• LIPETSK MECHANICAL PLANT LLC, providing goods or technology that could contribute to destabilising Ukraine;
• LLC CST, a manufacturer and supplier of drones;
• LLC RT-KOMPLEKT, a Russian based manufacturing business, its activities include the maintenance and repair of aviation equipment;
• MOSCOMS LLC, a Russian IT Services company; and
• OBORONLOGISTICS LLC, a Russian Ministry of Defence owned and controlled shipping and logistics company.

The "Seizure of Russian State Assets and Support for Ukraine Bill" had its first reading in Parliament on 7 February.

The Bill would require the British Government to present plans to seize Russian assets frozen in the UK due to sanctions, and allocate them to Ukraine and the Ukrainian people. These powers of seizure would not apply to individuals' assets, but only to Russian state assets, bypassing the concept of sovereign immunity.

The EU also introduced the idea of using frozen Russian assets for the reconstruction of Ukraine in November 2022 (Accountability for international crimes- EU Press Release).

The next stage for the Bill (second reading) is scheduled to take place on Friday 24 February. This will be the first opportunity for MPs to debate the general principles and themes of the Bill.

The prohibition in respect of oil and oil products with CN code 2710 comes into force on 5 February 2023.

This measure was introduced on 3 November 2022 in the "The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022" (see 3 November entry below for more details).

OFSI updated its "UK Maritime Service Prohibition and Oil Price Cap" industry guidance.

The guidance outlines obligations under the UK Maritime Services Prohibition and Oil Price Cap exception, as well as OFSI’s approach to implementation and enforcement.

Refined Oil Products Winddown General Licence - INT/2023/2660772

[NOW REVOKED] 

[THIS GENERAL LICENCE WAS REVOKED ON 20 DECEMBER 2023 – SEE ENTRY ABOVE]

OFSI issued the "Refined Oil Products Wind-Down" General Licence. The licence concerns commodity codes 2710 Russian oil and oil products purchased above the price caps and loaded onto a ship at the port of loading prior to 5:01 a.m., GMT, 5 February 2023, and offloaded at the port of destination prior to 5:01 a.m., GMT, 1 April 2023. It allows:

1. A legal or natural person to supply or deliver Russian oil by ship from a place in Russia to a third country or from one third country to another third country;
2. A Service Provider to provide Relevant Services to any legal or natural person supplying or delivering Russian oil by ship from a place in Russia to a third country or from one third country to another third country; and
3. A financial institution to process payments in relation to the activities authorised above.

The general licence differentiates between Tier 1, Tier 2 and Tier 3 providers, each of which is subject to different requirements (Tier provider status is determined by the extent to which a service provider can access the unit price agreed per barrel of Russian oil).

The general licence also sets out separate requirements for "Involved Persons" (i.e. a person who is not a Tier 1, 2 or 3 Provider, and is involved in (a) the supply or delivery of oil and oil products; or (b) the provision of financial services or funds or brokering services relating to the supply or delivery of oil and oil products).

The licence utilises date attestations, which evidence the date that the Russian oil products was loaded and was or will be offloaded in a third country.

The licence is also subject to strict record-keeping requirements lasting 4 years from the end of the calendar year in which the record was created. Additional record-keeping requirements apply to Tier 1, Tier 2 and Tier 3 providers.

This licence takes effect from 05 February 2023 and is of indefinite duration.

THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/4423849

On 5 December 2022, OFSI introduced the "oil price cap" general licence allowing the maritime transport of Russian crude oil and the provision of related services where the oil is purchased at or below $60 per barrel (see entry dated 5 December below for more information).

OFSI amended the general licence to include 2710 oil and oil products under the definition of "Russian Oil" and "Price Cap".

The definition of "Price Cap" has been updated as follows:

• USD 100 per barrel for commodity codes 2710 12 31, 2710 12 41 , 2710 12 45 , 2710 12 49 , 2710 12 50 , 2710 12 70 , 2710 12 90 , 2710 19 11 , 2710 19 15 , 2710 19 21 , 2710 19 25 , 2710 19 29 , 2710 19 31 , 2710 19 35, 2710 19 43, 2710 19 46, 2710 19 47, 2710 19 48, 2710 19 71, 2710 20 11, 2710 20 16 and 2710 20 19 ("Premium to Crude"); and
• USD 45 per barrel for all other 2710 commodity codes ("Discount to Crude").

This licence takes effect from 05 December 2022 with regard to 2709 oil and oil products and from 05 February 2023 with regard to 2710 oil and oil products and is of indefinite duration.

Following, the implementation of a $60 price cap on Russian crude oil in December 2022, the Price Cap Coalition of the G7, the European Union and Australia have set caps on the price of seaborne Russian oil products, effective from 05 February 2023.

High-value Russian exports such as diesel and gasoline, will be capped at USD 100 per barrel while lower-value products such as fuel oil will be capped at USD 45 per barrel.

These prices will be kept under review.

This measure was legislated for in the “The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022” laid on 3 November 2022 (see entry below).

Telecoms company, Truphone Limited, has been sold to TP Global Operations pursuant to a licence granted by OFSI. The transaction follows the UK's imposition of sanctions on three of Truphone's owners in 2022, namely, Roman Abramovich, Alexander Frolov and Alexander Abramov (see entries dated 10 March 2022 and 2 November 2022 for more information).
To mitigate the risk to national security, TP Global Operations, amongst others, is subject to an order made by the Secretary of State under s,26 of the National Security and Investment Act 2021. The Secretary of State's conditions imposed on the transaction are summarised below:

• A requirement to appoint a Chief Information Security Officer approved by the Secretary of State; and
• A requirement to put in place telecoms information security measures; and
• A requirement to carry out a security audit by a government approved auditor to produce a report setting out any new security measures.

The International Trade Committee will launch a new enquiry into the UK's trade sanctions on Russia focusing on the following points:

• the role of the Department for International Trade (DIT) in developing, implementing and enforcing trade-related sanctions on Russia;
• the interaction between DIT and other Government departments, including the Foreign, Commonwealth and Development Office, the Home Office, HMRC and the Treasury, in enforcing sanctions on Russia;
• the impact of trade-related sanctions on UK businesses, supply chains and consumers, and the effectiveness of the Government’s support and guidance; and
• whether the UK’s trade policy and approach to international co-operation has mitigated the domestic impact of the sanctions.
  The Committee is asking for written evidence to be submitted by 12pm on Friday 17 March 2023 (here).

The Export Control Joint Unit (ECJU) published the following:

• A notice briefly setting out the sanctions against Russia introduced under The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (please see the entry dated 15 December below for more information);
• A form to apply for a licence from the ECJU to provide technical assistance or support;
• New guidance regarding Open Individual Export Licences (OIEL). OEIL may be used to regularly export similar controlled items to the same customer; and 
• Updated guidance regarding Global Project Licences. These licences are used to simplify the export of military goods and technology classed as collaborative defence projects.

Allows for a 7 day wind down period with respect to certain financial prohibitions introduced by The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022, meaning that:

• A person may deal with a transferable security or money-market instrument (Regulation 16);
• A person may make funds or economic resources available to a person, other than an individual, which is not a person connected with Russia where the purposes of making those funds or economic resources available is to enable such person to grant a relevant loan as described in Regulation 17(2A);
• A person directly or indirectly grantor enter into an arrangement to grant a Category 6 loan as described in Regulation 17(5); and
  A person may directly or indirectly acquire an ownership interest in or control over a person, other than an individual, which is not a person connected with Russia, for the purposes set out in paragraph 18B(3) of the Russia Regulation.

Please see the entries below for more information regarding each prohibition above. The licence takes effect from 00:01 on 16 December 2022 and expires at 23:59 on 22 December 2022.

15 December 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022

(comes into force on 16 December 2022)

The Explanatory Memorandum is available here and the Impact Assessment is available here.

Disapplication of Banking Act 2009 requirement

(new regulation 97A)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 

Suspends the Bank of England’s duty under the Banking Act 2009 to make a decision in respect of a notification of third-country resolution action in respect of designated persons or persons owned or controlled by designated persons.

Resolution is the process by which regulatory authorities manage the orderly failure of financial institutions. 

Trust services prohibition

(new regulation 18C)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 

Introduces a new prohibition on providing trust services:

• to, or for the benefit of, designated persons; and
• to, or for the benefit of, persons connected with Russia unless they were doing so immediately prior to 16 December 2022.

"trust services" means—

• the creation of a trust or similar arrangement,
• the provision of a registered office, business address, correspondence address or administrative address for a trust or similar arrangement,
• the operation or management of a trust or similar arrangement, or
• acting or arranging for another person to act as trustee of a trust or similar arrangement, where “trustee”, in relation to an arrangement similar to a trust, means a person who holds an equivalent or similar position to a trustee of a trust

Trust services are provided for the benefit of a person (“B”) where—

• B is a beneficiary of a trust or similar arrangement,
• B is referred to as a potential beneficiary in a document from the settlor relating to a trust or similar arrangement (such as a letter of wishes), or
• having regard to all the circumstances, B might reasonably be expected to obtain, or to be able to obtain, a significant financial benefit from the trust or similar arrangement.

The prohibition is also subject to a number of specific exceptions - all listed under the new regulation 60ZZB.

Financial restrictions - dealing with transferable securities or money-market instruments – new category

(amendment to regulation 16)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 

Addition of a new category of transferable security or money-market instrument to the existing prohibitions:

It is prohibited to deal, directly or indirectly, with a transferable security or money-market instrument issued:

• on or after 16 December 2022,
• by a person, other than an individual, which is not a person connected with Russia, and
• for the purposes of certain activities in respect of investments in Russia (Note: these are the same activities which are prohibited by the investment restrictions set out under regulation 18B(2) – see 19 July entry below).

Financial and investment restrictions – investments in relation to Russia – amendment to definition of "relevant entity"

(amendment to regulation 18B)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 

Amendment of the definition of a "relevant entity" for the purposes of the investment restrictions to clarify that a "relevant entity" is "means a person, other than an individual, which has a place of business located in Russia but is not a person connected with Russia".

(see further detail regarding the investment restrictions below – 19 July 2022)

The exceptions to the investment restrictions have also been amended – Regulation 60ZZA.

Financial restrictions - Loans and credit arrangements

(amendment to regulation 17)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 

Introduces a new prohibition to existing restrictions:

• a person is prohibited from making funds or economic resources available to a "relevant entity" where the purposes of making those funds or economic resources available is to enable such entity to grant a relevant loan (i.e. a loan prohibited by the restrictions in Regulation 17) on or after 16 December 2022.

"relevant entity" – see entry immediately above.

Also adds a new category of loan to those which are subject to existing restrictions on the granting of loans/credit (see 1 March 2022 and 28 October 2022 entries below). A "Category 6 loan" is a loan or credit:

• made or granted to a relevant entity,
• which is for the purposes of a certain activities in respect of investments in Russia (Note: these are the same activities which are prohibited by the investment restrictions set out under regulation 18B(2) – see 19 July entry below);
• which is first made or granted at any time on or after 16 December 2022, and
• which is not a category 1 loan, a category 2 loan, a category 3 loan, a category 4 loan or a category 5 loan.

Trade restrictions - amendments to existing restrictions

(amendments to Schedule 2A and 3C)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 

Amendments to existing trade restrictions:

• additional items added to the list of critical-industry goods/technology, including camouflage, oil production and mining equipment (Schedule 2A); and
• additional items added to the list of defence and security goods/technology, including calcium carbide, carbon monoxide, monoethyleneglycol, sulphur, and sulphur dioxide (Schedule 3C).

Trade restrictions - Professional and business services – additional services added

[(amendment of regulation 54C)-]

The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022

Introduces a prohibition on the direct and indirect provision of the following additional professional and business services to a person connected with Russia:

• auditing services;
• advertising services;
• architectural services;
• engineering services; and
• information technology consultancy and design services.
  

Each of these services are defined in more detail under the new Schedule 3J to the Russia (Sanctions) (EU Exit) Regulations 2019.

Overseas territories:
Order in Council extending UK sanctions

The Russia (Sanctions) (Overseas Territories) (Amendment) (No. 4) Order 2022

(made on 14 December 2022)

This Order makes the necessary amendments to give effect in the relevant British overseas territories to the following changes made to the Russia sanctions regime pursuant to the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022:

• creating new trade prohibitions relating to gold jewellery and to certain processed gold, together with related definitions, exceptions and consequential amendments;
• making provision concerning the prohibition of imports of liquefied natural gas and the export of Russia’s vulnerable goods (as defined in the amending regulations);
• creating new prohibitions concerning the supply and delivery by ship of certain oil and oil products (“the new prohibitions”) and the provision of related ancillary services;
• creating exceptions from the new prohibitions and for Treasury licences allowing maritime transportation of oil and oil products to take place notwithstanding the new prohibitions;
• allowing for the issue of monetary penalties for breaches of the new prohibitions.

15 individuals and 1 entity have been added to the consolidated list and are now subject to an asset freeze. This includes Russian members of the armed forces and Iranian businessmen involved in providing Unmanned Aerial Vehicles (UAVs) for use by the Russian military.

The newly added entity is Oje Parvaz Mado Nafar Company which has provided to the Russian military components and engines for UAVs that could contribute to destabilising Ukraine.

1 individual has been added to the consolidated list and is now subject to an asset freeze:

• Ramil Rakhmatulovich IBATULLIN, colonel of the armed forces of the Russian Federation.
   

The UK Parliament debated the Immigration (Persons Designated under Sanctions Regulations) (EU Exit) (Amendment) Regulations 2022. The new regulations seek to clarify that:

• when a travel ban is imposed under the Sanctions Act, people lawfully in the UK are exempt from its effect while their human rights or protection claim is considered;
• however, when a sanctioned person leaves the UK, that exemption should end.

A travel ban has an effect on a person’s immigration status; they cannot enter or remain in the UK. The current legislation allows for a person who is lawfully in the UK to make a human rights claim before a travel ban made under the Sanctions Act impacts their immigration status. They are then exempt from the effect of the travel ban while the claim is considered. By contrast, non-designated persons making a human rights claim under the immigration rules also benefit from the same protections, but cannot leave the UK and return simply on the basis of a claim lodged before their departure.

The updated regulations aim to protect the UK sanctions regimes from abuse and provide consistency with the wider immigration system.

OFSI published guidance regarding the UK ban on the provision of maritime transportation of certain Russian oil and oil products and associated services. The guidance covers the following topics:

1. Purpose of the ban;
2. The UK’s ban on the maritime transportation of Russian oil and oil products and associated services;
3. How will the bans be implemented and enforced;
4. Exceptions and licensing;
5. How attestation works; and
6. Reporting.

Permits:

• the supply or delivery by ship of Russian oil originating in or consigned from the Sakhalin-2 Project from a place in Russia, to a place in Japan from 5 December 2022 until 29 September 2023;
• the execution of contracts concluded before 4 June 2022, or of ancillary contracts necessary for the execution of such contracts, for the purchase, import or transfer of Russian oil into Bulgaria from 5 December 2022 until 31 December 2024;
• where there are no alternative supplies of vacuum gas oil available, the purchase, import or transfer of vacuum gas oil falling under commodity code 2710, which is consigned from, or originates in, Russia into Croatia from 5 February 2022 [This appears to be an error and should refer to 5 February 2023] until 31 December 2023;
• the supply or delivery by ship of crude oil originating in or consigned from Russia falling under commodity code 2709 for a landlocked European member state as described in Council Regulation (EU) 2022/879 of 3 June 2022, if the supply of crude oil by pipeline from Russia is interrupted for reasons outside the control of that member state from 5 December 2022 until the Treasury's confirmation that the supply of crude oil by pipeline from Russia to the landlocked European member state is resumed; and
• the provision of relevant services (associated financial services, funds and brokering services) in respect of the same.

This licence takes effect from 5 December 2022 and is of indefinite duration (subject to the expiration dates above).

General Licence- Oil Price Cap winddown

[INT/2022/2470256]

[NOW REVOKED]

[THIS GENERAL LICENCE WAS REVOKED ON 20 DECEMBER 2023 – SEE ENTRY ABOVE]

This general licence provides for a time-limited exception to the oil and oil products maritime transportation ban for transactions involving oil that is loaded onto a vessel at the port of loading prior to 5 December 2022. It permits:

• the supply or delivery of Russian oil by ship from Russia to a third country or from a third country to another third country;
• the provision of relevant services by service providers to any person by ship from Russia to a third country or from a third country to another third country; and
• the processing of payments by financial institutions in relation to the above.

The Russian oil must be loaded onto a Ship at the port of loading prior to 5:01 a.m., GMT, 5 December 2022, and offloaded at the port of destination prior to 5:01 a.m., GMT, 19 January 2023.

The general licence differentiates between Tier 1, Tier 2 and Tier 3 providers, each of which is subject to different requirements (Tier provider status is determined by the extent to which a service provider can access the unit price agreed per barrel of Russian oil).

The licence is also subject to strict record-keeping requirements lasting 4 years from the end of the calendar year in which the record was created. Additional record-keeping requirements apply to Tier 1, Tier 2 and Tier 3 providers.

This licence takes effect from 5 December 2022 and is of indefinite duration.

On 03 February 2023, General Licence INT/2022/2469656 was amended to include 2710 oil and oil products under the definition of Russian oil and Price Cap (see entry dated 3 February 2023 above for more information).

This general licence permits:

• the supply or delivery of Russian oil by ship from Russia to a third country or from a third country to another third country provided that the unit price of the Russian oil is at or below the price cap of USD 60 per barrel of crude oil (the "Price Cap");
• the provision of relevant services by service providers to any person in respect of the supply or delivery of Russian oil by ship from Russia to a third country or from a third country to another third country provided that the price per barrel of Russian oil is at or below the Price Cap; and
• the processing of payments by financial institutions in relation to the above.

The general licence differentiates between Tier 1, Tier 2 and Tier 3 providers, each of which is subject to different requirements. (Tier provider status is determined by the extent to which a service provider can access the unit price agreed per barrel of Russian oil) .

The licence is also subject to strict record-keeping requirements lasting 4 years from the end of the calendar year in which the record was created. Additional record-keeping requirements apply to Tier 1, Tier 2 and Tier 3 providers.

This licence takes effect from 5 December 2022 and is of indefinite duration. 

The G7, EU and Australia have agreed to set the maximum price of USD 60 per barrel for seaborne Russian-origin crude oil.

The price cap on Russian-origin crude oil entered into force across the relevant jurisdictions on 5 December 2022 (please see the UK general licence above). The statement reiterated that the price cap on Russian-origin petroleum products will enter into force on 5 February 2023.

The Department for International Trade has published guidance on applying for licences with respect to the provision of accounting, business and management consulting, and public relations services to a ‘person connected with Russia’. The guidance notably includes information on the contents of the cover letter for a licence application.

Please see the entry dated 21 July 2022 for more information regarding the prohibition of accounting, business and management consulting, and public relations services.

22 individuals have been added to the consolidated list and are now subject to an asset freeze. These include a number of Russian officials such as:

• MANTUROV, Denis Valentinovich, Russian Deputy Prime Minister and Minister of Industry and Trade; and
• GOSTEV, Arkady Alexandrovic , Director of the Russian Federal Penitentiary Service.

The Solicitors Regulation Authority (SRA) published guidance setting out its expectations regarding the UK sanctions regime and providing practical advice on avoiding breaches. This guidance will be relevant to SRA-regulated firms, solicitors, registered European lawyers and registered foreign lawyers.

Separately, the SRA expressed concern in a warning notice around the misuse of litigation to discourage public criticism, a type of abusive litigation known as strategic lawsuits against public participation (SLAPPs). The SRA has specifically referred to that warning notice on its page dealing with 'Impacts of Russia sanctions' . The SRA warned that failure to have proper regard to this warning notice is likely to lead to disciplinary action.

British overseas territories:
Order in Council extending UK sanctions

Russia (Sanctions) (Overseas Territories) (Amendment) (No. 3) Order 2022 

A new Order has been introduced by the UK government to give effect in the relevant British overseas territories to the changes made to the Russia sanctions regime by the regulations below:

• The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 (see entry dated 15 July 2022 for more information);
• The Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 (see entry dated 19 July 2022 for more information);
• The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 (see entry dated 18 July 2022 for more information); and
• The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 (see entry dated 21 July 2022 for more information).

The list of British overseas territories is available under the Schedule to the regulation.

21 November 2022 Updated guidance- UK ban on Russian oil and oil products The UK government published guidance explaining the ban on Russian oil, oil products and associated services. The guidance covers:

• Details of the UK ban on Russian oil and oil products intended for entry into the UK;
• How to determine the origin of oil imports to the UK; and
• How the UK ban on intended entry of Russian oil and oil products will be enforced.

The general licence permits:

• payments from frozen accounts to utility companies for gas and electricity by UK designated who own or rent properties in the UK;
• receipt of such payments by energy companies;
• making return-payments as a result of over-payments made pursuant to this licence or in relation to the UK Government energy subsidy payments under the Energy Bills Support Scheme over winter 2022 to 2023; and
• processing of all payments above by financial institutions.

This licence is subject to record-keeping requirements (available here). It will take effect from 17 November 2022 and will expire at 23:59 on 16 April 2023 16 October 2023 has no expiry date.

[Note: This general licence was extended on 24 February 2023 - see entry above for more information].

OFSI announced that by 5 December 2022 (date by which the crude oil ban will come into effect):

• a general licence creating the price cap will be published; and
• additional general licences to ensure international alignment and the smooth operation of the price cap will also be published.

OFSI published its "UK Maritime Services Prohibition and Oil Price Cap Guidance". This document provides guidance regarding the UK ban on the provision of maritime transportation of certain Russian oil and oil product and associated services (as introduced by The Russia (Sanctions) (EU Exit) (Amendments) (No.16) Regulations 2022).

Please see the entry dated 3 November 2022 below for more information regarding the Russian oil and oil product ban. 

The general licence granted in relation to Truphone Limited on 2 November 2022 has been amended to incorporate the following changes:

• The licence will expire at 23:59 on 28 April 2023 instead of 31 January 2023;
• The licence has been extended to Truphone Limited's subsidiary companies, as existed at the point of designation with the exception of Cellnetrix Technology LLC; and

Additional clarifications regarding the scope of the licence have been included (notably regarding incremental orders and loan funding by directors).

The general licence allowing non-designated persons to make use of retail banking services of a sanctioned credit or financial institution has been renewed from 10 November 2022 until 10 November 2023. The licence was granted for personal use only and for a total value not exceeding £50,000.

The original licence was originally granted on 10 June 2022 and expired on 10 September 2022. Please see the entry dated 16 June 2022 below for more information regarding the scope of the licence.

The Export Control Joint Unit published a general licence authorising the direct or indirect provision of financial services or making funds available to a person connected with Russia in connection with:

• The direct or indirect supply or delivery of specified fertiliser goods from Russia to a third country; or
• Directly or indirectly making specified fertiliser goods available from Russia to a person in a third country;

provided the fertilisers are for agricultural use only. "Specified fertiliser goods" is defined under the licence.

This licence shall come into force on 9 November 2022. Any person seeking to rely on the licence must register online via SPIRE within 30 days of their first use of the licence.

For the purposes of this licence, "Agricultural Commodities" means "Food; Fertiliser; Seed; Feed; and Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food for animals".

Relevant Exporters (i.e. non-designated exporters, producers, sellers or transporters of Agricultural Commodities); or DIT Licence Holders may continue to:

1. receive funds and economic resources from any person, including from Designated Persons, in connection with the export, sale, production and transport of Agricultural Commodities; or
2. transfer funds or economic resources to:

• relevant Institutions, Insurance Providers or Relevant UK Nationals in connection with the export, sale, production and transport of Agricultural Commodities, including for the purchase of insurance and reinsurance; or
• UK Corporates, Designated Persons or any other Person in connection with the export, sale, production and transport of Agricultural Commodities.

Relevant Institutions, Insurance Providers, UK Corporates or Relevant UK Nationals may carry out the activities necessary to effect the above permissions.

This includes the provision of insurance, reinsurance and underwriting services and any other Financial Service (as defined as defined in section 61(1) of the Sanctions and Anti-Money Laundering Act 2018) to a Relevant Exporter, DIT Licence Holder or Designated Person in connection with a transaction relating to Agricultural Commodities.

Designated Persons may also carry out the following activities:

• transfer Funds to Relevant Institutions or Insurance Providers to:
  • pay Banking Fees in connection with a transaction relating to Agricultural Commodities; and
  • effect and/or process the transactions referred to in the paragraphs below.
  • pay for insurance and reinsurance services in connection with a transaction relating to Agricultural Commodities;

• transfer Funds or Economic Resources to Relevant Exporters, DIT Licence Holders or UK Corporates in connection with the export, sale or production of Agricultural Commodities; and

• receive Funds or Economic Resources from Relevant Exporters, DIT Licence Holders, UK Corporates, Relevant Institutions or Insurance Providers in connection with the export, sale or production of Agricultural Commodities.

This licence takes effect from 4 November 2022 and has no expiry date.

3 November 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022:

Explanatory memorandum

Impact assessment

Trade restrictions -maritime transportation of certain oil and oil products

The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022

(New Chapter 4IA)

Introduces a prohibition on direct or indirect supply or delivery by ship of certain oil and oil products which originate in or are consigned from Russia (i) from a place in Russia to a third country; or (ii) from one third country to another third country.

The prohibition comes into effect:

• from 5 December 2022 for products falling within commodity codes 2709
• from 5 February 2023 for products falling within commodity codes 2710

Includes a prohibition on associated financial services, funds and brokering services.

Provides for exceptions where such products:

1. originate in a country that is not Russia,
2. are not owned by a person connected with Russia, and
3. are only being loaded in, departing from or transiting through Russia (new Regulation 60HA).

According to the explanatory memorandum:

• a General Licence will be introduced to allow a price cap exception where the supply or delivery by ship of 2709 and 2710 oil and oil products and the provision of related ancillary services will be available to third country importers, so long as they purchase oil below an agreed price.
• further licences will be introduced in certain circumstances to permit supply or delivery by ship of 2709 and 2710 oil and oil products and related services in respect of specific activities critical to energy security.

Existing reporting obligations (under Regulation 70) are expanded to include a requirement to report breaches or suspected breaches of these prohibitions, and associated information, to Treasury.

Trade restrictions – maritime transport of oil products - civil penalties for breach

The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022

(New Regulations 88C and 88D) 

Confers on OFSI the power to impose civil monetary penalties on a person who fails to comply with the trade sanctions relating to maritime transportation of certain oil and oil products. Any defence that the person did not know and had no reasonable cause to suspect that such an offence had been committed is to be ignored

Existing criminal penalties for breaches of trade sanctions also apply.

The amount of the penalty may not exceed the permitted maximum which is:

• the greater of £1,000,000 or 50% of the estimated value of the breach where it is possible to estimate the value of the breach of the prohibitions; or
• £1,000,000 in any other case.

Trade restrictions – oil and oil products – amendment to implementation date

The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022

(Amendments to regulation 46Z3)

Four individuals have been added to the consolidated list and are now subject to an asset freeze.

• Alexander Grigoryevich Abramov
• Alexander Vladimirovich Frolov
• Airat Mintimerovich Shaimiev
• Albert Kashafovich Shigabutdinov

The general licence permits:

• Truphone to continue to provide telecommunications services under existing arrangements, and to make and receive any payments due under contractual obligations arising from the same;
• A person to undertake any activity necessary for the effect termination of any telecommunications services contracts or obligations;
• Truphone to pay UK staff salaries/pensions etc; fees/costs for the functioning of the business (e.g. utilities and tax); and third parties necessary for the provision of telecommunications services.

Relevant institutions may process payments in accordance with the above. Any payments received by Truphone must be paid into a UK bank account, whereupon they must be frozen.

The general licence does not permit the repayment of any loans or any other debt facilities extended to the Truphone, directly or indirectly, by Alexander Abramov, Alexander Frolov or any person, including any shareholders.

Payments/activity over £5,000 must be reported to OFSI within 14 days.

The general licence terminates on 23:59 on 31 January 2023

The UK government issued a general licence allowing payments to be made by a person designated under the Russia or Belarus regime for legal professional fees and expenses associated with the provision of legal services.

The licence differentiates between legal services provided ‘pre-designation’ (Part A) and ‘post-designation’ (Part B):

• For legal services carried out in satisfaction of a prior obligation (for example where a law firm or barrister is engaged before the designation of the individual or entity), there is a £500,000 (inc. VAT) cap on the amount that can be claimed over the duration of the licence; and
• For legal services carried out post-designation, users of the licence will need to demonstrate through their reporting obligations that all fees paid are reasonable. This will be done by providing details of hourly fees, workstreams, and evidence that overall fees are at or below a cap of £500,000 (inc. VAT).

Both caps may be combined (i.e. up to a £1 million limit), and a specific licence should be sought for any fees above this cap. Any activity conducted under this general licence must be reported to HM Treasury within 7 days, with details and supporting evidence. More information on reporting requirements are available on OFSI's website here.

This licence takes effect from 28 October 2022 and expires on 28 April 2023.

The UK government issued a general licence permitting the continued granting of category 5 loans or entering into arrangements to grant category 5 loans to Saving Energy For Europe GmBH, also known as Gazprom Germania and/or its subsidiaries, including SEFE Marketing and Trading and SEFE Energy, for the following purposes:

• over the counter trading in gas and power market trades;
• payment in respect of credit arrangements and invoices by Gazprom Germania and/or any of its Subsidiaries to any third party for purchase of gas or services;
• customer credit arrangements/any arrangements by customers to make prepayments to Gazprom Germania and/or any of its Subsidiaries;
• provision of clearing services to Gazprom Germania and/or any of its Subsidiaries;
• payments and loan arrangements between Gazprom Germania and/or any of its Subsidiaries;
• issuing and providing financing for letters of credit.

Relevant Institutions are permitted to process any of the above payments.

Please see the entry below for more information regarding "category 5 loans".

This Licence takes effect from 28 October 2022 and expires on 29 October 2023 (available here).

The UK government issued a general licence permitting the continued granting of category 5 loans for the 7 days following the issuing of the Licence (please see the entry below for more information regarding "category 5 loans")subject to record-keeping requirements. 

This Licence takes effect from 28 October 2022 and expires on 5 November 2022.

Financial restrictions – capital markets restrictions (granting new loans) – amendment

The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

(amended Reg 17(5))

Definition of "category 3 loan" amended to add an end-date of 28 October 2022 (effectively phasing out the restrictions on "category 3" loans that have been in place since 1 March 2022). 

Added a new category of loan to those which are subject to existing restrictions on the granting of loans/credit (see 1 March 2022 entry below). A "category 5 loan" is a loan or credit:

1. which is not a category 1-4 loan, 
2. has a maturity exceeding 30 days and
3. is granted on or after 29 October 2022 to:

• an entity connected with Russia (other than an entity incorporated outside of Russia on 29 October, or an entity owned by such entity); or
• an entity owned by an entity described in point 1 above; or
• an entity owned by an individual connected with Russia.

Trade restrictions – gold jewellery and processed gold

The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

(new Chapter 4JA)

Introduces prohibitions on:

• importing gold jewellery originating in Russia where it has been exported from Russia on or after 29 October 2022;
• importing relevant processed gold;
• acquiring, directly or indirectly, gold jewellery which originates in Russia and is located in Russia or has been exported from Russia after 29 October 2022, with the intention of the gold jewellery entering the UK; and
• associated technical assistance, financial services and funds, and brokering services.

"relevant processed gold" means gold which: (a)has been processed in a third country; and (b) incorporates gold that, on or after 21 July 2022 originated in Russia, and has been exported from Russia.

Trade restrictions – liquified natural gas (LNG)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

(new Chapter 4L)

From 1 January 2023, there will be prohibitions on:

• importing of liquefied natural gas which is consigned from, or originates in, Russia;
• acquiring, directly or indirectly, directly or indirectly, liquefied natural gas which originates in Russia and is located in Russia or has been exported from Russia, with the intention of the liquefied natural gas entering the UK; and
• associated technical assistance, financial services and funds, and brokering services.

"liquefied natural gas" means liquefied natural gas falling within commodity code 2711 11 00

Trade restrictions – Russia's vulnerable goods

The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

(new Chapter 4M and Schedule 3I)

Introduces prohibitions on a new category of goods – Russia's "vulnerable goods" (as listed in Schedule 3I), including:

• exporting Russia's vulnerable goods to, or for use in, Russia;
• directly or indirectly supplying or delivering Russia’s vulnerable goods from a third country to a place in Russia;
• directly or indirectly making Russia’s vulnerable goods available for use in Russia or to a person connected with Russia;
• associated technical assistance, financial services and funds, and brokering services.

Russia's "vulnerable goods" are products which are critical to Russia's economy.

Trade restrictions –amendments to existing restrictions

The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

Amendments to existing trade restrictions:

• minor clarificatory amendments to the lists of critical-industry goods and critical-industry technology (Schedule 2A); oil refining goods and technology (Schedule 2D) and quantum computing and advanced materials goods and technology (Schedule 2E)
• insert additional goods as Additional "G7 dependency and further goods" (new Part 3 of Schedule 3E). The aim of this measure is to further align with the EU’s existing prohibitions to include oil refining technology and manufacturing products.
• introduces new exceptions for the trade restrictions on "luxury goods" and gold 

26 October 2022

3 Iranian individuals and 1 Iranian entity have been added to the consolidated list and are now subject to an asset freeze:

• Saeed Aghajani
• Mohammad Bagheri
• Seyed Hojjatollah Qureishi
• Shahed Aviation Industries, a drone manufacturing company.

The UK government's press release confirms that these sanctions have been imposed against those Iranian individuals and businesses responsible for supplying Russia with kamikaze drones used in Ukraine.

The UK Parliament debated the draft Sanctions (Damages Cap) Regulations 2022 this week. The purpose of this instrument is to specify the amount of damages which cannot be exceeded where a court is satisfied that a designation was made in bad faith. The proposed cap is set at £10,000.

In some cases, designated persons may have an incentive to pursue government through the courts, even though their claims may eventually be found to be without merit. This cap on damages seeks to disincentivise such claims.

Please find the explanatory memorandum here, the draft legislation here and the procedure timeline here.  

OFSI and OFAC have issued a statement detailing their enhanced cooperation following a multi-day technical exchange in London. This includes:

• OFAC and OFSI officials working together on implementation and enforcement, including further exchanging best practices and strengthening working relationships at all levels;
• identifying opportunities to pool expertise, thinking creatively about current challenges, exploring opportunities to align the way both organisations implement sanctions, and assisting stakeholders either through joint products or by providing guidance resulting from collaboration behind the scenes; and
• developing approaches to address shared priorities like cyber threats and the misuse of virtual assets, improving information sharing, and ensuring that sanctions do not prevent humanitarian trade and assistance from reaching those in need.

OFSI has issued a new General Licence which permits the following:

• Any natural or legal persons designated under the Belarus or the Russia regulations ("DPs"), companies owned or controlled by DPs or their legal representatives may make payments to the London Court of International Arbitration ("LCIA") to cover their arbitration costs;
• The LCIA may direct and receive such payments to use them to pay for arbitration costs; and
• The LCIA’s banks may apply interest to any funds which are held by the LCIA on trust for DPs or companies owned or controlled by DPs (please see the entry dated 22 August 2022 below for a definition of "Bank"). In addition, financial institutions may process the payments set out above.

This General Licence takes effect from 17 October 2022 and is of indefinite duration.

The UK Prime Minister Liz Truss joined a virtual gathering of G7 leaders and President Zelenskyy on 11 October following Russia's most recent attacks in Kyiv. This meeting was the first gathering of all G7 leaders since Ukraine’s counter-offensive started to take hold in Ukraine.

The group discussed the following points:

• The UK Prime Minister asked countries to maintain sanctions and called for an urgent meeting of NATO leaders to ensure allies remain united in their opposition to Russia's invasion of Ukraine; and
• The group also worked to finalise and implement an international cap on the price of Russian oil.

The G7 leaders' joint statement following the meeting is available here.

OFSI amended the VTB basic needs General Licence granted on 1 March 2022 to include payments related to Insolvency Proceedings under the German Banking Act.

The General Licence expires on 3 April 2023. See entries on 1 March 2022 and 22 August 2022 below for more details.

1 individual has been added to the consolidated list and is now subject to an asset freeze:

• Sergei Vladimirovich Yeliseyev, Deputy Prime Minister of Kaliningrad and Head of Government of the Russian-occupied Kherson region.

1 individual has been removed from the consolidated list and is no longer subject to an asset freeze:

• Sergei Stanislavovich Yeliseyev, Vice-Admiral of the Russian Navy and Head of Government of the Russian-occupied Kherson region.

The UK Foreign Secretary has announced new services and goods export bans in response to Russia's illegal annexation of the Ukrainian regions of Donetsk, Luhansk, Kherson and Zaporizhzhia following sham referenda.

Under the new sanctions, the UK will prevent Russian access to:

• IT consultancy services;
• architectural services;
• engineering services;
• advertising services;
• transactional legal advisory services; and
• auditing services.

The UK will also ban the export of nearly 700 goods that are critical for production in Russia’s manufacturing sector.

In addition, the UK will suspend the process by which actions taken to manage the orderly failure of Russian banks subject to sanctions are recognised under UK law. This will prevent any Russian actions from taking legal effect in the UK and potentially providing economic benefit to the Russian state.

Finally, the UK continues to work with the G7 to finalise and implement the proposed price cap on Russian oil (please see the entry dated 5 September 2022 below for more information).

1 individual has been added to the consolidated list and is now subject to an asset freeze:

• Elvira Sakhipzadovna Nabiullina, Governor of the Central Bank of the Russian Federation.

OFSI has imposed a monetary penalty of £30,000 against UK registered company, Hong Kong International Wine and Spirits Competition Ltd (HKIWSC) for breaches of sanctions which were imposed by the EU (including the UK) in 2014 in response to actions which undermined or threatened the territorial integrity, sovereignty, and independence of Ukraine. 

The penalty relates to three payments and 78 wine bottles HKIWSC received from a designated entity for entry into competitions between September 2017 and August 2020. OFSI identified five potential breaches:

• four of the breaches related to the receipt of funds and/or wine bottles with a cumulative value of just under £4,000, a tangible economic resource, from the designated entity; and 
• one breach related to the publicity HKIWSC made available to the designated entity, which OFSI determined to be an intangible economic resource, an asset which may be exchanged or used in exchange for funds.

92 entries have been added to the consolidated list in response to the Russian regime imposing "sham referendums" in 4 regions of Ukraine: comprising: 

89 individuals: Amongst those individuals designated are:

• Igor Makarov, president and owner of ARETI International Group, a major investor in the oil and gas sector;
• 23 individuals from the Gazprombank Board of Directors and Management Board;
• 16 members of the Sberbank Supervisory Board, Executive Board, and other Directors; and
• 10 individuals from Sovcombank, including the Deputy Chairman and members of the Supervisory Board and Management Board. 

3 entities:

• Goznak
• IMA Consulting
• LLC Commercial Bank – International Settlements Bank

The Economic Crime and Corporate Transparency Bill (the "Bill") passed its first reading in the House of Commons.  The Bill is intended to build on the measures contained in the Economic Crime (Transparency and Enforcement) 2022 Act (the "ECTE Act").  It contains an additional suite of reforms to tackle economic crime and improve transparency over corporate entities.  In summary, as regards sanctions, the Bill: 

• makes it an offence for persons designated under UK or UN sanctions to act as directors of companies or to take part in the promotion, formation or management of a company;
• removes to the requirements in SAMLA 2018 for statutory instruments each time the UK’s High-Risk Third Countries list needs updating; 
• imposes requirements for enhanced customer due diligence measures by reference to a list of high-risk countries;

• removes the statutory fining limit to allow the Solicitors Regulation Authority to set its own limits on financial penalties imposed for economic crime disciplinary matters, including those relating to sanctions.

The House of Commons has started its second reading of the Bill. Further information regarding the status of the Bill is available here . Further information regarding the contents of the Bill is available here. 

The following entity has been removed from the consolidated list and is no longer subject to an asset freeze:

• ZAO Interavtomatika (IA) 

The G7 Finance Ministers' statement following their meeting on 2 September 2022 contained the following statements about the crude oil and petroleum price cap:

• Today we confirm our joint political intention to finalise and implement a comprehensive prohibition of services which enable maritime transportation of Russian-origin crude oil and petroleum products globally – the provision of such services would only be allowed if the oil and petroleum products are purchased at or below a price ("the price cap") determined by the broad coalition of countries adhering to and implementing the price cap.
• In line with our extensive and ongoing engagement with a diverse group of countries and key stakeholders, we invite all countries to provide input on the price cap´s design and to implement this important measure
• The initial price cap will be set at a level based on a range of technical inputs and will be decided by the full coalition in advance of implementation in each jurisdiction. The price cap will be publicly communicated in a clear and transparent manner. The price cap's effectiveness and impact will be closely monitored and the price level revisited as necessary.
• We envisage that practical implementation of the price cap will be based on a recordkeeping and attestation model covering all relevant types of contracts. We aim to ensure consistent implementation across jurisdictions.

Extended the VTB basic needs General Licence granted on 1 March 2022 to include the following VTB subsidiaries:

• VTBC Asset Management International Limited (Guernsey subsidiary);
• VTB Bank (Europe) SE ("VTBE") (EU subsidiary); and 
• any entity owned or controlled by VTBE incorporated in Germany.

The General Licence expires on 3 April 2023.  See entry on 1 March 2022 below for more details.

Permits, subject to record-keeping requirements:

• A Bank to take the payment of Service Fees from frozen accounts, arising from the routine holding or maintenance of those accounts, including the payment of Service Fee arrears;
• Persons to make payment to settle any tax liabilities arising from the above and HMRC to receive such payments; and
• Relevant institutions to process payments made in accordance with this General Licence. 

"Bank" means a person or a firm with a Part 4A permission which includes accepting deposits, and which is a credit institution. It does not include a building society, friendly society or a credit union. 
"Person" means an individual, a body of persons corporate or unincorporate, any organisation or any association or combination of persons.

"Service Fees" means service fees that a Bank would otherwise charge for the routine holding or maintenance of a bank account, including but not limited to premium bank account fees, fees associated with the provision of bank statements, account maintenance fees, late payment charges and overdraft fees. Service fees may also include transaction fees, payment fees or transfer fees, where those fees pertain to a transaction otherwise licensed by OFSI.

This General Licence does not permit the payment to banks designated under the Russia Regime. 

This General Licence is of indefinite duration. 

The General Licence permitting certain insurance-related payments (see entry from 22 July 2022) has been extended to include within "Permitted Payments":

• Terrorism Insurance
• Property Owners' Liability Insurance
• Claims Preparation Insurance

This General Licence is of indefinite duration.

Permits, where Crown immunity does not apply:

• A Crown Servant, Contractor, Family Member or Visiting Family Member to carry out activities in their personal capacity in Russia which would otherwise be prohibited by regulations 11-15 and 17A of the Russia Regulations;
• Visiting Family Members to carry out only those activities which arise as a result of their being in Russia to visit the household of a Crown Servant or Contractor; and
• Any relevant institution to carry out any activity necessary to effect the above permissions. 

"Crown Servant" means an individual holding office or employment under the Crown

"Contractor" means an individual who is not a Crown Servant, but who has been contracted by the Crown to provide goods or services within or in relation to the Crown’s operations in Russia

"Family Member" means a member of the family forming part of the household of a Crown Servant or Contractor, namely: 

• A spouse;
• A civil partner;
• An established partner; and
• Dependent children up to the age of 18, or up to the age of 21 and in full-time education. 

"Visiting Family Member" means:

• The spouse of a Crown servant, or Contractor; 
• The civil partner of a Crown servant, or Contractor; 
• The established partner of a Crown servant or contractor; 
• Any parent or other ascendant of (i) a Crown servant or Contractor; or (ii) the spouse, civil partner or established partner of a Crown servant or Contractor; (e) Any child or other descendant of (i) a Crown Servant, Contractor; or (ii) the spouse, civil partner or established partner of a Crown servant or contractor; 
• Any individual who is a brother or sister of (i) a Crown Servant, or Contractor; (ii) the spouse, civil partner or established partner of a Crown servant or contractor; or (iii) a child or other descendant of that individual (i.e. nephews and nieces etc).

This General Licence takes effect from 11:59pm (midnight) on 19 August 2022 and has no expiry date.

Permits:

• A Person to continue to make payments to a Sanctioned Bank or any subsidiary for the purpose of making energy available for use in Mongolia; and
• A Person, relevant institution, Sanctioned Bank or subsidiary to carry out any activity reasonably necessary to effect this.

"Person" means an individual, a body of persons corporate or incorporate, any organisation or any association or combination of persons.

The "Sanctioned Banks" are:

• Credit Bank of Moscow;
• Gazprombank;
• Sberbank; and
• Rosbank PJSC.

This General Licence expires on 14 August 2023 14 August 2025 [GL was extended on 27 July 2023 - see entry above].

Permits, subject to reporting requirements:

• A Person (excluding a designated person) to make use of the retail banking services of a designated Credit or Financial Institution to make or receive payments that are exclusively for the purpose of winding down business operations in Russia provided that no payments are otherwise made to a designated person; and
• A relevant institution may process payments made in accordance with the above.

"Person" means a body of persons corporate or unincorporate, any organisation or any association or combination of persons, excluding a designated person

Payments permitted under this General Licence include payment of staff salaries, taxes, regulatory fees and other fees to official government bodies, and payment of bills or invoices.

Making use of the retail banking services of a designated Credit or Financial Institution does not include selling or transferring a Person's assets to a designated Credit or Financial Institution.
This General Licence expires on 5 November 2022.

[THIS GENERAL TRADE LICENCE WAS REVOKED ON 18 JANUARY 2024]
Permits the provision of technical assistance, financial services and funds, and brokering services relating to vessels, aircrafts and aero gas turbine engines / their component parts / associated technology, where;

• the restricted goods are;

• vessels and their component parts controlled under 8A992f of Schedule 2A to the Regulations and the restricted technology is technology related to such vessels controlled under 8E992 of Schedule 2A to the Regulations,
• aircraft and their component parts controlled under Schedule 2C to the Regulations and the restricted technology is technology related to such aircraft controlled under Schedule 2C to the Regulations, but in each case not including anything defined under Part 5 of the Regulations as military goods or military technology, or
• aero gas turbine engines and specially designed components therefor controlled under 9A991c of Schedule 2A of the Regulations and the restricted technology is technology related to such engines and components controlled under 9E991 of Schedule 2A to the Regulations,
• the aircraft or vessel is moving from a third country to Russia, or to the UK or a third country from Russia, or transiting Russian territorial waters or airspace or moving between two third countries,
• in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers,
• the aircraft or vessel is moving under its own power, and
• the movement of the aircraft or vessel is not for the purpose of: (i) transfer of ownership of the aircraft or vessel or any of its component parts or (ii) a change of the operator of the aircraft or vessel.
• an aero gas turbine engine and specially designed components form part of an aircraft specified above which is undertaking an activity in accordance with the above.,
• technical assistance and brokering services are not being provided to a person connected with Russia; and
• in the case of insurance and reinsurance services under Article 29A, they are not being provided to a person connected with Russia.

The General Licence also contains a number of conditions relating to insurance/reinsurance in respect of the above.

Use is subject to a notification requirement.

This replaces the previous licence dated 8 April 2022 (now revoked).

[A replacement general licence was granted on 18 January 2024 – see above.]

Permits, subject to reporting and record-keeping requirements:

• Individuals designated under the UK sanctions regime to make "Permitted Payments" to UK insurers from a frozen UK bank account; and UK insurers to receive such Permitted Payments;
• UK insurers to make "Return Payments" to frozen UK bank accounts, being the payment of funds due as a result of a claim made pursuant to the permitted payments, or as a result of an overpayment; and UK designated persons to receive Return Payments from UK insurers into a frozen UK bank account; and
• Relevant institutions to process payments in relation to the above.

"Permitted Payments" mean insurance premiums, reinsurance premiums and broker commissions relating to the provision of Buildings Insurance and Engineering Insurance provided to UK properties. [Definition extended on 18 August 2022 to also include: Terrorism Insurance; Property Owners' Liability Insurance; and Claims Preparation Insurance.]

This licence does not permit the provision of insurance to individuals who are also designated by the United Nations.

This General Licence is of indefinite duration.

21 July 2022

Explanatory Memorandum to The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022

Prohibition on the import/acquisition/supply/delivery, whether from Russia or a third country, of gold that originates in Russia on or after 21 July, as well as ancillary services, such as:

• Related technical assistance;
• Financial services and funds; and
• Brokering services

Gold originating from Russia that was exported from Russia before 21 July 2022 is not affected.

Trade restrictions – oil and coal

The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022

Prohibition on the import/acquisition/supply/delivery of:

• Oil and oil products (will take effect on 31 December 2022 5 December 2022) [Date amended on 3 November 2022 – see above]; and
• Coal and coal products (will take effect on 10 August 2022 to align with the equivalent EU measure)

That originate in or are consigned from Russia, as well as prohibitions on the provision of related services.

Trade restrictions -professional and business services

The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022

Prohibition on the provision, directly or indirectly, to persons connected with Russia, of:

• Accounting services;
• Business and management consulting services; and
• Public relations services

This includes Russian residents who are temporarily located in another country, including the UK.

The Regulation contains more detailed definitions of the services covered by the above.

"person connected with Russia" – see entry at 1 March 2022 below.

Exceptions exist where the services:

• Are provided in relation to the discharge of or compliance with UK statutory or regulatory obligations (and not under a contract);
• Are provided due to an obligation arising under a contract concluded before 20 July 2022, and the services are provided by 21 August 2022, and HM Treasury is informed 10 working days before the services are carried out; or
• Are necessary for official or diplomatic purposes.

Trade restrictions – energy-related goods and services

The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022

Expanded existing prohibitions, including:

• The export of energy-related goods to Russia, regardless of their eventual point of use even if this would be outside of Russia;
• Making available energy-related goods to a person connected with Russia;
• The provision of technical assistance, financial services and funds, and brokering services with regard to these activities; and
• Energy-related services (for instance drilling or well testing) to all production and exploration projects related to oil and gas in Russia.
   

Trade restrictions – G7 dependency and further goods list goods

The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022

Prohibits the export/supply/delivery of items listed on the G7 dependencies and further goods list. (as listed in Schedule 3E) to or for use in Russia or to a person connected with Russia.

These goods are significant to the Russian economy and goods for which the Russia particularly depends on the G7 partners and the UK.

The list is wide and includes:

• Chemicals;
• Materials;
• Machinery goods; and
• Electrical appliances.

Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology.

"person connected with Russia" – see entry at 1 March 2022 below.

Licences can be sought for humanitarian purposes.

Trade restrictions – import tariffs

The Customs (Additional Duty) (Russia and Belarus) (Amendment) (No. 2) Regulations 2022 

Updates the list of products from Russia and Belarus which are subject to the previously announced tariff increases of 35% (see further below at 21 April and 21 May 2022).

Access the Belarusian Additional Duties Document (version 1.2, dated 15 July 2022) and the Russian Additional Duties Document (version 1.2, dated 15 July 2022) here.

Overseas territories:
Order in Council extending UK sanctions

The Russia (Sanctions) (Overseas Territories) (Amendment) (No. 2) Order 2022

Where a person knows or has reasonable cause to suspect that they are carrying on such an activity, there is a prohibition on:

• Directly or indirectly establishing any joint venture with a person connected with Russia;
• Opening a representative office or establishing a branch or subsidiary located in Russia;
• (i) Directly or (ii) indirectly - for the purpose of making funds or economic resources available to or for the benefit of a person connected with Russia - acquiring any ownership interest in land located in Russia;
• (i) Directly or (ii) indirectly - for the purpose of making funds or economic resources available to or for the benefit of a person connected with Russia - acquiring any ownership interest in or control over
  • A person, other than an individual, connected with Russia;
  • A relevant entity
• Providing investment services directly related to any of the above activities.

"person connected with Russia" – see entry at 1 March 2022 below.

“branch” means, in relation to a person other than an individual, a place of business which forms a legally dependent part of that person and which carries out all or some of the transactions inherent in the business of that person.

"relevant entity" means a person, other than an individual, which has a place of business located in Russia but is not a person connected with Russia. [Words deleted on 16 December 2022 – see entry above]

"directly or indirectly acquiring any ownership interest in or control over a person or entity" means a person directly or indirectly acquiring:

• Any share in the person/entity;
• Any voting rights in the person/entity;
• Any right to appoint or remove a majority of the board of directors of the person/entity; or
• Any means of ensuring that the affairs of the person/entity are conducted in accordance with that person's wishes

Exceptions – investments in relation to Russia

The Russia (Sanctions) (EU Exit) (Amendment) (No 12) Regulations 2022

Exceptions to the prohibitions outlined above include:

• Acts satisfying a person's obligations arising under a contract concluded before 19 July 2022 or an ancillary contract necessary for the satisfaction of such a contract, so long as that person has notified the Treasury at least 5 working days before the act is carried out;
• Dealing directly or indirectly with:
  • A transferable security where such dealing is prohibited by regulation 16;
  • A relevant security issued by a person connected with Russia; or
  • A relevant security issued by a relevant entity.

"dealing with" includes purchasing/selling the security, providing investment services relating to the security or assisting in the issuance of the security.

"relevant security issued by a person connected with Russia" means (1) a security issued by a person connected with Russia or a person owned by, or acting on the behalf of, a person connected with Russia, (2) which is negotiable on the capital market, (3) which is a share, bond or other security and (4) was admitted to trading on a regulated market or multilateral trading facility before 19 July 2022 (full definition included in regulation 60ZZA)

"relevant security issued by a relevant entity" means (1) a security issued by a relevant entity, (2) which is negotiable on the capital market, (3) which is a share, bond or other security (full definition included in regulation 60ZZA).

Treasury licences – investments in relation to Russia

The Russia (Sanctions) (EU Exit) (Amendment) (No 12) Regulations 2022

The purpose of treasury licences can relate to:

• An extraordinary situation;
• Humanitarian assistance activity;
• Medical goods or services;
• Food;
• Diplomatic missions;
• Safety and soundness of a firm;
• Spaceflight activity.

Financial sanctions – reporting obligations – amendment of the definition of "relevant firms"

The Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2022

The definition of "relevant firms" (i.e. those who have financial sanctions reporting obligations) has been extended to include cryptoasset exchange providers and custodian wallet providers. These reporting obligations require "relevant firms" to provide OFSI with particular information when they encounter a designated person when conducting their business

"cryptoasset exchange provider" and "custodian wallet provider" are defined in the regulation.

This expanded definition will apply as of 30 August 2022.

There is a requirement for "relevant firms" to notify OFSI of certain information as soon as practicable when encountering a designated person in the course of their business. This requirement applies to relevant firms in the UK or under UK jurisdiction including people working for them. For more information about the obligations on relevant firms to report information to OFSI, see here.

The definition of being "involved in obtaining a benefit from or supporting the Government of Russia" has been extended to include "other managers", rather than just trustees, of Russian government-controlled entities and those carrying on business of economic or strategic significance to the Russian government.

As well as applying to persons involved in "destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine", the designation criteria also captures persons "obtaining a benefit from or supporting the Government of Russia", including but not limited to working as:

• an aide or advisor to the Russian President;
• a head or deputy-head of any public body, federal agency or service subordinate to the President;
• a member, secretary or deputy secretary of the Security Council of the Russian Federation;
• a minister or deputy minister of any Russian ministry

The definition of "being associated with" a person has been extended to those who are an "immediate family member" which is defined as:

• a wife or husband;
• a civil partner;
• a parent or step-parent;
• a child or step-child;
• a sibling or step-sibling;
• a niece or nephew;
• an aunt or uncle;
• a grandparent;
• a grandchild.

Trade: humanitarian exception

The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022

A new exception has been added for humanitarian assistance activity in non-government controlled areas of the Donetsk and Luhansk oblasts.

This exception applies when:

• a person carries out an activity which would otherwise contravene a prohibition such as:
  • prohibited trade in relation to non-government controlled territory;
  • prohibited infrastructure-related services relating to non-government controlled Ukrainian territory);
  • brokering services: non-UK activity relating to infrastructure-related goods and goods from non-government controlled Ukrainian territory, except for prohibitions relating to an arrangement whose object or effect is the import of goods which originate in non-government controlled Ukrainian territory;
• that person believes that carrying out that activity is so necessary; and
• there is no reasonable cause for that person to suspect otherwise.

The concept of ownership of a ship and aircraft has been extended to include:

• a person owned or controlled directly or indirectly by the person in whom legal title is vested; or
• a person owned or controlled directly or indirectly by a person with a beneficial interest in the aircraft/ship

Trade restrictions – defence and security, and maritime goods

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Prohibition on the export/supply/delivery etc of: (1) defence and security goods; and (2) maritime goods/technology:

• to Russia;
• to a person connected with Russia;
• for use in Russia;
• in the case of maritime goods/technology, by placing on a Russian-flagged vessel

Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology.

"person connected with Russia" – see entry at 1 March 2022 below.

"defence and security goods/technology" means:

1. "interception and monitoring goods/technology" (complex definition, but see Part 2 of Schedule 3C) – does not include software which is publicly available
2. "internal repression goods/technology" (complex definition, but see Part 3 of Schedule 3C)
3. "goods/technology relating to chemical and biological weapons" (complex definition, but see Part 4 of Schedule 3C) – does not include medicines/medicinal products or medical devices

"maritime goods/technology" means any goods and technology specified in Chapter 4 (Navigation Equipment) and Chapter 5 (Radio-Communication Equipment) of Annex 1 of the Merchant Shipping Notice 1874, subject to certain exceptions.

Introduction of certain new exceptions to the prohibitions for maritime goods/technology.

Trade restrictions – goods/technology relating to non-government controlled Ukrainian territory

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Prohibition on the export/supply/delivery etc of military goods/technology to or for use in non-government controlled Ukrainian territory.

Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology.

"non-government controlled Ukrainian territory" means Crimea and non-government controlled areas of the Donetsk and Luhansk oblasts

Trade restrictions – iron and steel products – amendment

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Expansion of the existing restrictions on Russian iron and steel products (see 14 April 2022 below) to include new prohibitions on the provision of technical assistance; financial services and funds; and brokering services in respect of:

• the import/acquisition of iron and steel products originating/consigned from Russia or located in Russia
• the supply of iron and steel products from Russia to a third country. 

Trade restrictions – Interception and monitoring

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Prohibition on the provision/supply/delivery of interception and monitoring services to or for the benefit of the Government of Russia.

"interception and monitoring services" means any service that has as its object or effect the interception of a communication in the course of its transmission by means of a telecommunication system (full definition included in regulation 21A).

Trade restrictions – Banknotes

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Prohibition on the export/supply/delivery of banknotes

• to Russia;
• to a person connected with Russia; and
• for use in Russia.

"banknotes" means (1) sterling denominated banknotes issued by the Bank of England and banks in Scotland and Northern Ireland; and (2) banknotes denominated in any official currency of the EU.

"person connected with Russia" – see entry at 1 March 2022 below.
Introduction of certain new exceptions to the prohibitions for banknotes.

Trade restrictions – jet fuel and fuel additives

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 

Prohibition on the export/supply/delivery etc of jet fuel and fuel additives:

• to Russia;
• to a person connected with Russia;
• for use in Russia;

Includes a prohibition on related technical assistance, financial services, funds and brokering services.

"person connected with Russia" – see entry at 1 March 2022 below.

"jet fuel and fuel additives" means the goods listed under that heading in Part 8 of Schedule 2A

Trade restrictions – revenue generating goods

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Prohibition on the import/acquisition/supply/delivery of revenue generating goods into the UK which:

• are consigned from Russia
• originate in Russia
• are located in Russia,

Includes a prohibition on related technical assistance, financial services, funds and brokering services.

"revenue generating goods" means anything specified in Schedule 3D. This list includes: caviar, cement, chemicals, fertilisers, tyres, wood, paper, glass, metals, jets, propellers, turbines, ships and furniture.

Introduction of certain new exceptions to the prohibitions for revenue generating goods.

Trade restrictions – expansion of restrictions to non-government controlled Ukrainian territory

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Certain of the existing prohibitions in relation to:

• Critical-industry goods / technology (see entry at 1 March below)
• Energy-related and infrastructure-related goods
• Defence and security goods / technology (see first entry at 23 June above),

Are expanded to apply equally to non-government controlled Ukrainian territory (i.e. Crimea, Donetsk and Luhansk)

Trade restrictions – expansion of existing restrictions

The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

Expansion of the existing lists of the prohibited goods/technology, as follows:

• critical-industry goods / technology, to include certain microorganisms and toxins, and materials processing items (additions to Schedule 2A)
• oil refining goods / technology, to include certain LNG-related goods (additions to Schedule 2D)
• energy-related goods, to include certain exploration data and hydraulic fracturing items (additions to Schedule 3)

2 individuals have been removed from the asset freeze list:

• Didier Casimiro
• Zeljko Runje

In conjunction with OFSI, the JMLIT+ Sanctions Facilitators Cell, law enforcement, private industry and regulators, the National Crime Agency (NCA) have issued a 'Red Alert' on financial sanctions evasion typologies by Russian elites and enablers.

The purpose of the alert is to provide information from law enforcement and the legal and financial services sectors on some of the common techniques designated persons and their UK enablers are suspected to be using to evade financial sanctions.

Certain humanitarian organisations seeking to undertake humanitarian activity in relation to the conflict in Ukraine do not need to apply for individual licences from OFSI, but instead can rely on the permissions within this General Licence to undertake certain humanitarian activity.

OFSI has also published a blog outlining the details of the General Licence

This licence takes effect from 11:59 pm on 7 July 2022. There is no stated expiry date.

Belarus: Financial restrictions – dealing with transferable securities or money-market instruments

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022

Extension on existing capital markets restrictions to include a new prohibition on dealing, directly or indirectly, with a transferable security or money-market instrument issued after 5 July 2022 by a person "connected with Belarus".

"connected with Belarus" means:

• an individual/group of individuals who are ordinarily resident or located in Belarus
• an entity which is incorporated/constituted under the law of Belarus or domiciled in Belarus.

The prohibition does not apply to entities which on 5 July 2022: (i) were not domiciled in Belarus or (ii) were a branch or subsidiary of an entity in (i), wherever located.

Belarus: Financial restrictions – loans and credit arrangements

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022

Extends the existing prohibition on granting new loans and credit to the following 3 categories of loan:

"Category A loan" [This category was the subject of the restrictions in place prior to these changes]

• A loan or credit which has a maturity exceeding 90 days;
• Is made or granted to a "relevant person"; and
• Is first made or granted after 14 October 2021 2021, and before 5 July 2022.

"Category B loan"

• Any loan or credit which is made or granted to a "relevant person"; and
• Is first made or granted after 5 July 2022.

"Category C loan"

• A loan or credit which has a maturity exceeding 30 days;
• Is made or granted to a person, other than an individual, which is "connected with Belarus" but is not: (i) domiciled in a country other than Belarus, or (ii) majority owned by a person domiciled outside of Belarus;
• Is first made or granted after 5 July 2022; and
• Is not a category B loan.

"relevant person" means:

1. Belarus;
2. Belarusian authority;
3. a person, other than an individual, which is not a person within sub-paragraphs 4, 5 or 6 and which is wholly owned by Belarus or a Belarusian authority;
4. a credit or financial institution which is majority owned by Belarus or a Belarusian authority;
5. a person, other than an individual, which is (i) incorporated or constituted under the law of a non-UK country, and (ii) majority owned by a person within sub-paragraph 4;
6. a person acting on behalf of or at the direction of a person within sub-paragraph 4 or sub-paragraph 5.

Belarus: Financial restrictions – foreign exchange reserve and asset management

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022

Prohibition on the provision of financial services for the purpose of foreign exchange reserve and asset management to:

• The National Bank of Belarus;
• The Ministry of Finance of Belarus;
• A person owned or controlled directly or indirectly by either of the above; and
• A person acting on behalf, or at the direction, of either of the above.

"financial services" and "foreign exchange reserve and asset management" are both defined widely. 

Belarus: Trade sanctions – exports to Belarus

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022

Expands the existing trade restrictions to include new and amended prohibitions on the export, supply and delivery, and making available of the following (i) to or for use in Belarus or (ii) to a person connected with Belarus:

• Critical-industry goods/technology (see Schedule 2C and associated definitions)
• Dual-use goods/technology [existing prohibition]
• Interception and monitoring goods/technology [existing prohibition] (see Schedule 2A and associated definitions)
• Internal repression goods/technology [existing prohibition] (see Schedule 2 and associated definitions)
• Luxury goods (see Schedule 2E and associated definitions)
• Military goods/technology [existing prohibition] (see Schedule 2 to the to the Export Control Order 2008 and associated definitions)
• Oil refining goods/technology (see Schedule 2F and associated definitions)
• Quantum computing and advanced materials goods/technology (see Schedule 2G and associated definitions)
• Tobacco industry goods [existing prohibition] (see Schedule 2B and associated definitions)

Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology (except luxury and tobacco industry goods).

Belarus: Trade sanctions – imports from Belarus

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022

Extends and amends the existing import prohibitions to include import prohibitions on the following:

• arms and related material ("military goods" and anything which falls within chapter 93 of the Goods Classification Table;
• iron and steel products (see Schedule 2B and associated definitions);
• mineral products (see Schedule 2B and associated definitions); and
• potash [existing prohibition] (see Schedule 2B and associated definitions)

Belarus: Enabling or facilitating military activities

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022

A person must not directly or indirectly provide:

• Technical assistance;
• Armed personnel;
• Financial services or funds; or
• Brokering services in relation to an arrangement whose object or effect is to provide, in a non-UK country, any of the above,

where such provision enables or facilitates the conduct of military activities carried on by the Belarusian military or other military end-user connected with the Belarusian military.

Belarus: Movement of aircraft

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 

Extension of existing aircraft restrictions, to include:

• A prohibition on Belarusian aircraft overflying or landing in the UK;
• The power for aircraft operators to direct Belarusian aircraft to not take off, take off, land or not to land at an airport managed by that operator;
• The power for the Secretary of State to give a direction under the point above, secure the detention or movement of a Belarusian aircraft;
• A requirement for the CAA to refuse to register, or terminate the registration of, an aircraft owned/chartered by a designated person.

A "Belarusian aircraft" means an aircraft: (a) owned, chartered or operated by a designated person, or a person connected with Belarus, or (b) registered in Belarus.

Belarus: Ships

The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022

Introduction of new restrictions relating to ships, including:

• A prohibition on entry to UK ports to ships owned/controlled/chartered by a designated person or person connected with Belarus, flying the flag of Belarus, or registered in Belarus;
• The ability of the Secretary of State or port authority to issue directions:
  • prohibiting port entry;
  • otherwise directing the movement of a ship;
  • detaining a ship
• A requirement to refuse to register in the UK ships owned/controlled/operated etc by a designated person or person connected with Belarus.
• A prohibition on the provision of technical assistance for certain ships.

Permits a person to provide financial services for the purpose of winding down any of the following transactions that were entered into prior to 5 July with (i) the National Bank of Belarus, (ii) the Ministry of Finance of Belarus or (ii) persons owned/controlled or acting on behalf/at the direction of those persons:

• derivatives,
• repurchase transactions, and
• reverse repurchase transactions

A person or relevant institution is permitted to carry out any activity reasonable necessary to effect this.

This General Licence expires on 4 August 2022. 

Permits a person to:

• Deal, directly or indirectly, with a transferable security or money-market instrument issued after 5 July 2022 by a person connected with Belarus;
• Grant, directly or indirectly, a Category C loan,
• Directly or indirectly enter into an agreement to grant a Category C loan.

Relevant institutions may process GBP payments made in accordance with the above.

This General Licence expires at 23:59 on 12 July 2022.

2 individuals added:

• Denis Yakovlevich Gafner
• Veleriya Kalabayeva

2 individuals have been removed from the asset freeze list:

• Yakov Vladimirovich Rezantsev
• Galina Ulyutina

6 individuals:

• Aleyona Anatolyevna Chuguleva
• Yuriy Sergeyevich Fedin
• Darya Aleksandrovna Dugina
• Yevgeniy Eduardovich Glotov
• Aelita Leonidovna Mamakova
• Mikhail Anatolyevich Sinelin

1 entity:

• United World International

Permits a person (other than Rosbank or a subsidiary) to wind down transactions to which it is a party involving Rosbank or a subsidiary, including:

• The closing out of any positions
• Repayment of loans
• Withdrawal of deposits
• Closing of accounts

A person, relevant institution, Rosbank or a subsidiary can carry out any activity reasonably necessary to effect this.

This General Licence expires on 30 July 2022

This General Licence has been extended on 29 July 2022 and now expires on 30 September 2022.

8 individuals including:

• Vladimir Potanin, owner of Rosbank and major shareholder in Norilsk Nickel
• Anna Tsivileva, cousin of Vladimir Putin's and president of JSC Kolmar

5 entities:

• JSC Marshal.Global
• JSCy Moscow Industrial Bank
• JSC Kolmar Group
• JSC New Opportunities
• R-Style Softlab

The G7 Leaders' Communiqué from the summit in Elmau contained the following statements regarding Russian energy:

• We will seek to develop solutions that meet our objectives of reducing Russian revenues from hydrocarbons, and supporting stability in global energy markets, while minimising negative economic impacts.
• We welcomed the decision of the European Union to explore with international partners ways to curb rising energy prices, including the feasibility of introducing temporary import price caps.
• We will consider a range of approaches, including options for a possible comprehensive prohibition of all services, which enable transportation of Russian seaborne crude oil and petroleum products globally, unless the oil is purchased at or below a price to be agreed in consultation with international partners.
• We will also consider mitigation mechanisms alongside our restrictive measures to ensure that most vulnerable and impacted countries maintain access to energy markets including from Russia.

Further sanctions – restrictions on trust services

(announced but not yet implemented) 

Trade restrictions – gold exports

(announced but not yet implemented)

Announcement of a prohibition on new exports of Russian gold entering the UK. This import ban will apply to newly mined or refined gold and will not impact Russian-origin gold previously exported from Russia. The ban will be introduced "shortly".

Canada, US and Japan are due to introduce similar measures.

 23 June 2022

[THESE REGULATIONS HAVE BEEN REVOKED AND REPLACED BY A SIMILAR SET OF REGULATIONS THROUGH THE RUSSIA (SANCTIONS) (EU EXIT) (AMENDMENT) (NO 11) REGULATIONS 2022]

Trade restrictions – defence and security, and maritime goods/technology

The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022

Prohibition on the export/supply/delivery etc of: (1) defence and security goods/technology; and (2) maritime goods/technology:

• to Russia;
• to a person connected with Russia;
• for use in Russia;
• in the case of maritime goods/technology, by placing on a Russian-flagged vessel

Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology.

"person connected with Russia" – see entry at 1 March 2022 below.

"defence and security goods/technology" means:

(a) "interception and monitoring goods/technology" (complex definition, but see Part 2 of Schedule 3C) – does not include software which is publicly available

(b) "internal repression goods/technology" (complex definition, but see Part 3 of Schedule 3C)

(c) "goods/technology relating to chemical and biological weapons" (complex definition, but see Part 4 of Schedule 3C) – does not include medicines/medicinal products or medical devices

"maritime goods/technology" means any goods and technology specified in Chapter 4 (Navigation Equipment) and Chapter 5 (Radio-Communication Equipment) of Annex 1 of the Merchant Shipping Notice 1874, subject to certain exceptions.

Introduction of certain new exceptions to the prohibitions for maritime goods/technology.

Prohibition on the export/supply/delivery etc of military goods/technology to or for use in non-government controlled Ukrainian territory.

Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology.

"non-government controlled Ukrainian territory" means Crimea and non-government controlled areas of the Donetsk and Luhansk oblasts

Expansion of the existing restrictions on Russian iron and steel products (see 14 April 2022 below) to include new prohibitions on the provision of technical assistance; financial services and funds; and brokering services in respect of:

• the import/acquisition of iron and steel products originating/consigned from Russia or located in Russia
• the supply of iron and steel products from Russia to a third country.

Prohibition on the provision/supply/delivery of interception and monitoring services to or for the benefit of the Government of Russia.

"interception and monitoring services" means any service that has as its object or effect the interception of a communication in the course of its transmission by means of a telecommunication system (full definition included in regulation 21A).

Prohibition on the export/supply/delivery of banknotes

• to Russia;
• to a person connected with Russia; and
• for use in Russia.

"banknotes" means (1) sterling denominated banknotes issued by the Bank of England and banks in Scotland and Northern Ireland; and (2) banknotes denominated in any official currency of the EU.

"person connected with Russia" – see entry at 1 March 2022 below.
Introduction of certain new exceptions to the prohibitions for banknotes.

Prohibition on the export/supply/delivery etc of jet fuel and fuel additives:

• to Russia;
• to a person connected with Russia;
• for use in Russia;

Includes a prohibition on related technical assistance, financial services, funds and brokering services.

"person connected with Russia" – see entry at 1 March 2022 below.

"jet fuel and fuel additives" means the goods listed under that heading in Part 8 of Schedule 2A

Prohibition on the import/acquisition/supply/delivery of revenue generating goods into the UK which:

• are consigned from Russia
• originate in Russia
• are located in Russia,

Includes a prohibition on related technical assistance, financial services, funds and brokering services.

"revenue generating goods" means anything specified in Schedule 3D. This list includes: caviar, cement, chemicals, fertilisers, tyres, wood, paper, glass, metals, jets, propellers, turbines, ships and furniture.

Introduction of certain new exceptions to the prohibitions for revenue generating goods.

Certain of the existing prohibitions in relation to:

• Critical-industry goods / technology (see entry at 1 March below)
• Energy-related and infrastructure-related goods
• Defence and security goods / technology (see first entry at 23 June above),

are expanded to apply equally to non-government controlled Ukrainian territory (i.e. Crimea, Donetsk and Luhansk)

Trade restrictions – expansion of existing restrictions

The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022

Expansion of the existing lists of the prohibited goods/technology, as follows:

• critical-industry goods / technology, to include certain microorganisms and toxins, and materials processing items (additions to Schedule 2A)
• oil refining goods / technology, to include certain LNG-related goods (additions to Schedule 2D)
• energy-related goods, to include certain exploration data and hydraulic fracturing items (additions to Schedule 3)

12 individuals including:

• The Russian Children's Rights Commissioner, who has been involved with the forced transfer and adoption of Ukrainian children;
• The head of the Russian Orthodox Church; and
• Putin's allies and military commanders.

 Permits:

• a person to make use of the retail banking services of a Russian credit or financial institution which is a "designated person" provided that the payments made or received are intended for the personal use of that person;
• the value of such payments cannot exceed £50,000; and
• a relevant institution may process payments made in accordance with the above provided that the total value of such payments processed by that relevant institution does not exceed £50,000.

Subject to specific reporting and record-keeping requirements.

This General Licence expires on 10 September 2022. [Note: The general licence was extended to 10 November 2023- see entry dated 10 November 2022 above]

 The provisions of the Economic Crime Act (see 15 March below) introducing a new strict civil liability test for imposing monetary penalties (section 54) will come into force on 15 June 2022.

The operative part of the relevant provision provides:

"In determining for the purposes of subsection (1) [of Section 146 of the Policing and Crime Act 2017] whether a person has breached a prohibition, or failed to comply with an obligation, imposed by or under financial sanctions legislation, any requirement imposed by or under that legislation for the person to have known, suspected or believed any matter is to be ignored."

OFSI has published an updated version of its enforcement and monetary penalty guidance reflecting measures in the Economic Crime (Transparency and Enforcement) Act 2022, including:

• A new strict civil liability test for imposing monetary penalties;
• Changes to the review of monetary penalties; and
• The new OFSI ability to publish details of breaches where a monetary penalty has not been imposed.

This guidance comes into force on 15 June 2022.

Read more in the OFSI article accompanying this update.

The Department for International Trade has published guidance on what import and export restrictions apply due to sanctions for UK companies when trading with Russia. It outlines the rules in respect of:

• Trade Sanctions;
• Import and export control licensing;
• Tariffs on Russian and Belarusian goods;
• Financial sanctions;
• Getting paid; and
• Transport sanctions

Trade restrictions – increased import tariffs

The Customs (Additional Duty) (Russia and Belarus) (Amendment) Regulations 2022

Updates the list of products from Russia and Belarus which are subject to the previously announced tariff increases of 35% (see further below at 21 April and 21 May 2022). This comes into force from 1 June 2022.

Access the Belarusian Additional Duties Document (version 1.1, dated 24 May 2022) and the Russian Additional Duties Document (version 1.1, dated 24 May 2022) here.

30 May 2022

General Licence – Telecommunications Services and News Media Services (Continuation of Business and Basic Needs)

Permits certain activity which would otherwise breach the prohibitions in Regulations 11 to 17A of the Russia Regulations (i.e. the asset freeze provisions and the capital markets restrictions):

• A person (other than a designated person) may continue business operations involving the provision of "Civilian Telecommunication Services" including:

• payments to or from ZAO TransTeleCom Company ("ZAO") under any contracts or other obligations;
• payments to or from any third party necessary to the continuation of any such contracts with ZAO for obligations; and
• any activity reasonably necessary to effect the provision or receipt of Civilian Telecommunications Services from ZAO.

• A person (other than a designated person) may continue business operations involving the provision of "News Media Services" including:

• payments to/from a designated credit / financial institution for the payment of salaries, invoices or fees;
• payments to/from any third party necessary to continue those business operations; and
• any activity reasonably necessary to effect the provision or receipt of News Media Services.

A relevant institution may process any of the above payments.

The permissions are subject to specified notification and record-keeping requirements.

This General Licence expires on 30 May 2024.

This General Licence has been amended – please see 26 June 2023 entry.

Permits an Interim Manager and/or trustee of a charity associated with a Designated Person (a "Charity") to authorise certain payments for:

• the basic needs of a Charity, including payment of: insurance premiums, reasonable fees for property management services, and rent or mortgage;
• reasonable fees or service charges arising from the routine holding and maintenance of a Charity's frozen funds or economic resources; and
• reasonable professional fees, for instance legal, accountancy and audit services or reasonable expenses associated therewith.

The General Licence also permits an Interim Manager and/or trustee to authorise:

• receipt, distribution and investment of charitable funds, and
• payments associated with the wind up of a Charity.

The General Licence expires on 30 May 2023.

This General Licence has been amended – please see 26 June 2023 and 23 August 2023 entries.

Permits a UK national/entity to purchase tickets from the following designated Russian travel companies, or any subsidiary, for flights or rail journeys within Russia or originating in Russia:

• PJSC Aeroflot;
• JSC Rossiya Airlines;
• JSC Ural Airlines;
• Russian Railways

Permits a UK national/entity, relevant institution or designated person to carry out reasonably necessary activities to enable the purchase of tickets for those journeys.

This General Licence expires on 23 May 2023 23 May 2024. [Note: This general licence was further amended on 16 February 2023 – see entry above for the detail of the amendments]

3 entities:

• JSC Rossiya Airlines
• JSC Ural Airlines
• PJSC Aeroflot

In a further statement, the G7 Foreign Ministers stated that:

• the sanctions and export controls against Russia do not and will not target essential food exports and agricultural inputs to developing countries, and will include measures to avoid any negative consequences for the production and distribution of food;
• they will work together to address Russia's policy of information manipulation and interference;
• they will take steps to: (i) impose coordinated further restrictive measures on Russia's economy and financial system; (ii) further target Russian elites including economic actors, the central government institutions and the military; and (iii) isolate Russia from their economies, the international financial system, and within global institutions;
• they will broaden their sanctions measures to include sectors on which Russia depends; and
• their efforts to reduce, and ultimately end, reliance on Russian energy supplies will be expedited.

For the UK Government's press release on this, see here

Permits:

• Amsterdam Trade Bank (ATB) to make payment for its basic needs including: payment of remuneration, allowances or pensions of employees; payment of tax and payments to suppliers of goods and services,
• any person to take any action in connection with insolvency proceedings relating to ATB,
• the winding down of transactions involving ATB or a subsidiary

This General Licence expires on 12 May 2023.

A collective commitment from the G7 to taking the following measures:

• Phasing out dependency on Russian energy, including by phasing out or banning the import of Russian oil;
• Prohibiting or otherwise preventing the provision of key services to Russia;
• Continuing to take action against Russian banks;
• Continuing efforts to fight off the Russian regime's attempts to spread propaganda; and
• Continuing and elevating measures against the financial elites and family members who support President Putin in his war, including imposing sanctions on additional individuals.

[The UK has already taken steps to enact these measures, for instance announcing on 7 March that it will phase out Russian oil imports, announcing on 4 May a ban on services exports to Russia, and continuing to impose asset freezes on Russian individuals and entities – all detailed below.]

See also the latest press release from the UK Government, published on 14 May 2022, which discusses the G7 Foreign Ministers' Statement on Russia's war against Ukraine. The Ministers reaffirmed their commitment "to reduce and end reliance on Russian energy supplies as quickly as possible" For more information, see here.

Permits the continuation of business operations involving the North American subsidiaries of Evraz plc, including payments to and from those subsidiaries and any third party under any obligations or contracts.

The General Licence expires on 2 September 2022 31 March 2023 30 September 2023 31 March 2024 30 September 2024 [Validity extended on 18 August 2022, 16 February 2023, 26 June 2023 and again on 22 December 2023]

Trade restrictions – a ban on services exports to Russia

(announced but not yet implemented)

13 individuals including war correspondents from Channel One, a major state-owned outlet in Russia

32 entities, including a number of strategic propaganda organisations such as:

• All Russia State Television and Radio Broadcasting, a state-owned broadcaster
• InfoRos, a news agency spreading destabilising disinformation
• SouthFront, a disinformation site
• the Strategic Culture Foundation, an online journal spreading disinformation

Imposes obligations on internet companies, including requirements that :

• social media services, including video sharing platforms, must take reasonable steps to prevent content that is generated, uploaded or shared by a designated person/entity being encountered by a UK-based user of that service
• internet access services must take reasonable steps to prevent a UK-based user of that service from accessing an internet service provided by a designated person/entity
• application stores must take reasonable steps to prevent a UK-based user of the application store from downloading or otherwise accessing an internet service provided by a designated person/entity

The Secretary of State can designate persons to whom these restrictions will apply.

Grants new powers to OFCOM to request information/documents in relation to internet services. OFCOM is also granted new enforcement rights, including the power to impose civil monetary penalties

Creates information offences in relation to internet services. Failure to comply is also a criminal offence.

Permits certain specified activities in connection with law enforcement and asset recovery, including:

• Permitting regulators to carry out their duties, including through making use of powers available to them under UK legislation (e.g. POCA) or common law for asset recovery purposes (broadly, investigating and enforcing proceeds of crime); and
• Permitting persons to comply with court orders / forfeiture notices and negotiated settlements / deferred prosecution agreements for the same purposes.

Subject to a prior authorisation requirement in certain circumstances and reporting requirements.

The licence is of indefinite duration.

General licence – Russian banks UK subsidiaries (basic needs) -amendment

(Sberbank UK subsidiary)

Extended the VTB basic needs General Licence granted on 1 March 2022 to include Sberbank CIB (UK) Ltd (the UK subsidiary of Sberbank). The General Licence expires on 3 April 2023.

(Sberbank CIB (UK) entered special administration on 1 April 2022 – see here.)

General licence – Gazprombank Energy Payments

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Permits payments to Gazprombank or a subsidiary for the purpose of making gas available in the EU under contracts entered into prior to 21 April 2022, and any activity reasonably necessary to effect this including the opening and closing of bank accounts.

The General Licence expires on 31 May 2022.

Amendment to publication notice accompanying the existing wind-down licence for to Alfa Bank, GazPromBank, Rosselkhozbank, SMP Bank and the Ural Bank for Reconstruction and Development issued on 24 March 2022 (see below).

• OFSI confirmed that the existing wind-down General Licence does not contain a requirement that funds payable to those banks as part of winding down any transactions with those banks be paid into a frozen account.
• If funds become payable to a subsidiary of the banks as part of winding down any transactions with the banks' subsidiaries, OFSI suggests considering how the ownership and control provisions in the 2019 Russia Regulations could apply to such payment.

Trade restrictions – Russian goods

(announced but not yet implemented)

The UK Government announced further trade sanctions which will impose tariffs and bans on over £1bn of additional Russian goods. This will include import bans on silver, wood products and high-end products from Russia including caviar. Tariffs will be increased by 35% on around £130m worth of products from Russia and Belarus, including diamonds and rubber. A full list of products targeted is available here.

16 individuals including individuals who are members of or linked to Russia's military

10 entities:

• Aleksandrov Scientific Research Technological Institute NITI
• Central Research Institute of Machine Building JSC
• Federal State Unitary Enterprise Dukhov Automatics Research Institute
• JSC Arzamas Machine-Building Plant
• JSC GTLK
• JSC Kalashnikov Concern
• LLC Military Industrial Company
• Promtech-Dubna JSC
• Radiotechnical and Information Systems Concern
• Rocket and Space Centre Progress JSC

Financial sanctions - Moscow Stock Exchange

(announced but not yet implemented)

HMRC has announced its intention to revoke the Moscow Stock Exchange's (MOEX) status as a recognised stock exchange, limiting access to certain UK treatments and reliefs for future investments in securities traded on MOEX. Access to those treatments and reliefs for existing investments will remain unaffected.

Financial Secretary to the Treasury, Lucy Frazer, said:

"As we continue to isolate Russia in response to their illegal war on Ukraine, revoking Moscow Stock Exchange's recognised status sends a clear message – there is no case for new investments in Russia."

2 individuals:

• Eugene Tenenbaum - a Director at Chelsea Football Club and business associate of Abramovich
• David Davidovich - business associate of Abramovich

Trade restrictions – luxury goods

The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022

Prohibition on the export/supply/delivery etc of luxury goods:

• to Russia;
• to a person connected with Russia; and/or
• for use in Russia.

"person connected with Russia" – see entry at 1 March 2022 below.

"luxury goods" are listed in Schedule 3A along with the specified sales price threshold and include: horses, caviar, truffles, alcoholic drinks, cigars, perfume, leather goods, clothing/accessories/shoes, rugs, precious stones, coins/banknotes, silverware, tableware, lead crystal, electronic items for personal use / recording, vehicles, clocks/watches, musical instruments, art, sports equipment, and gambling equipment.

Extension of certain existing exceptions to luxury goods.

Trade restrictions – iron and steel products

The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022

Prohibition on

• the import/acquisition of iron and steel products originating/consigned from Russia or located in Russia
• the supply of iron and steel products from Russia to a third country.

"iron and steel products" are listed in Schedule 3B

Extension of certain existing exceptions to iron and steel products.

Trade restrictions – oil refining and quantum computing goods/technology

The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022

Prohibition on the export/supply/delivery etc of oil refining and quantum computing goods/technology:

• to Russia;
• to a person connected with Russia; and/or
• for use in Russia.

Includes a prohibition on related technical assistance, financial services, funds and brokering services.

"person connected with Russia" – see entry at 1 March 2022 below.

"oil refining goods/technology" are listed in Schedule 2D.

"quantum computing goods/technology" are listed in Schedule 2E

Extension of certain existing exceptions.

British overseas territories – extension of recent changes to the UK sanctions on Russia

The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022

Amendments to the legislation extending the UK's sanctions regime in relation to Russia (re Ukraine) to British overseas territories to bring it in line with the amendments to that regime since Russia's invasion of Ukraine (as set out below).

That regime is extended to all British overseas territories by way of the Russia (Sanctions) (Overseas Territories) Order 2020. This Order does not apply to Bermuda and Gibraltar which implement sanctions under their own legislative arrangements.

General Trade Licence - Vessels

NOW REVOKED

[THIS GENERAL TRADE LICENCE WAS REVOKED ON 1 AUGUST 2022]

Permits the provision of technical assistance, financial services and funds, and brokering services relating to vessels, aircrafts and aero gas turbine engines / their component parts / associated technology, where;

• the aircraft or vessel is moving from a third country to Russia, or to the UK or a third country from Russia, or transiting Russian territorial waters or airspace or moving between two third countries,
• in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers,
• the aircraft or vessel is moving under its own power, and
• the movement of the aircraft or vessel is not for the purpose of: (i) transfer of ownership of the aircraft or vessel or any of its component parts or (ii) a change of the operator of the aircraft or vessel.

The General Licence also contains a number of conditions relating to insurance/reinsurance in respect of the above.

Use is subject to a notification requirement.

This replaces the previous licence dated 17 March 2022 (now revoked).

[A replacement general licence was granted on 1 August 2022 – see above.]

7 April 2022 

Further sanctions – announcement (G7 foreign ministers' statement) 

8 individuals:

• Viatcheslav (Moshe) Kantor, the largest shareholder of Acron - fertilizer company
• Andrey Guryev - founder of PhosAgro - fertilizer company
• Sergey Kogogin, director of Kamaz – manufacturer of trucks and buses.
• Sergey Sergeyevich Ivanov, President of Alrosa - diamond producer (also a DP)
• Leonid Mikhelson, the founder and CEO of Novatek - Russian natural gas producer
• Andrey Akimov, the CEO of Gazprombank.
• Aleksander Dyukov, the CEO of GazpromNeft.
• Boris Borisovich Rotenberg, son of the co-owner of SGM - gas pipeline producer.

2 entities: Credit Bank of Moscow and PJSC Sberbank

Further sanctions – announcement

(announced but not yet implemented)

Other sanctions announced, but yet to be implemented, include:

• An outright ban on all new outward investment to Russia.
• By the end of 2022, the UK will end all dependency on Russian coal and oil, and end imports of gas as soon as possible thereafter. From next week, the export of key oil refining equipment and catalysts will also be banned.
• Action against key Russian strategic industries and state owned enterprises. This includes a ban on imports of iron and steel products.

General licence – GEFCO (amendment)

[NOW REVOKED]

[THIS GENERAL TRADE LICENCE HAS BEEN REVOKED – SEE BELOW]

GEFCO General Licence (see 25 March 2022 below) amended to permit persons or a relevant institution to process payments or transactions related to the sale and transfer of GEFCO's shares by Russian Railways. 

Further wave of sanctions – announcement

(announced but not yet implemented)

In a speech delivered at a the British Embassy in Poland, Foreign Secretary Liz Truss announced a "tough new wave of sanctions", said to comprise:

• "banning Russian ships from our ports";
• "cracking down on Russian banks";
• "going after new industries filling Putin’s war chest like gold"; and
• "agreeing a clear timetable to eliminate our imports of Russian oil, gas and coal".

[Update on 5 April 2022: In a speech delivered at the Polish Ministry of Foreign Affairs on 5 April 2022, the Foreign Secretary explained that she would be urging the UK's NATO and G7 partners to go further in sanctions by joining the UK in introducing the above restrictions, which the UK has already introduced.]

The Foreign Secretary also said that "There should be no talk of removing sanctions whilst Putin’s troops are in Ukraine and the threat of Russian aggression looms over Europe".

General licence - Payments by the Central Bank of the Russian Federation and others

(exemption to Regulation 18A restrictions)

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Permits until 30 June 2022 the provision of financial services for the purposes of the receipt and onward transfer of non-rouble denominated interest/coupon or maturity/principal payments from:

• the Central Bank of the Russian Federation,
• the National Wealth Fund of the Russian Federation, or
• the Ministry of Finance of the Russian Federation,

in connection with debt issued by them before 1 March 2022.

Amendment of the VTB basic needs general licence (see 1 March 2022 below) to allow any payments in connection with the insolvency proceedings of the UK subsidiary of VTB.

Any person, including any subsidiary of VTB incorporated in the UK, may make, receive or process any payments, or take any other action, in connection with any insolvency proceedings relating to VTB Capital plc. Permits the receipt and processing of any such payments.

"insolvency proceedings" includes all those set out in the Insolvency Act 1986 and the Banking Act 2009

12 individuals: including Russian propagandists and military personnel.

2 entities: Rossiya Segodnya and TV-Novosti (both Russian media organisations)

3 entities: Photon Pro LLP; Majory LLP; Djeco Group LP

[Note: Each of these entities has a UK address, and has been designated under the new "urgent" procedure on the basis that they have been sanctioned by the US. No other reasons were given by OFSI. An OFAC press release said that these entities were part of an international "sanctions evasion network" which conceals the Russian military and intelligence end-users of western technology.]

Financial restrictions – investments in Donetsk and Luhansk regions

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022

(amendments to Regulation 18)

Extension of the existing investment restrictions in respect of Crimea to the Donetsk and Luhansk regions (defined as "non-government controlled Ukrainian territory"). Those restrictions comprise a prohibition on:

• acquiring any ownership interest in land located in Crimea/Donetsk/Luhansk
• acquiring any ownership interest in or control over, an entity located in Crimea/ Donetsk/Luhansk
• granting any loan or credit, or otherwise providing funds, to or for the purposes of financing an entity located in Crimea/ Donetsk/Luhansk
• establishing any joint venture in Crimea/ Donetsk/Luhansk or with an entity located in Crimea/ Donetsk/Luhansk
• providing investment services in relation to any of the above

The exceptions to these restrictions have been similarly extended.

Trade restrictions - Donetsk and Luhansk regions

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022

(amendments to Chapter 5 and 6)

Extension of the existing trade restrictions in respect of Crimea to the Donetsk and Luhansk regions (defined as "non-government controlled Ukrainian territory"). Those restrictions comprise a prohibition on:

• The import of goods which originate in Crimea/Donetsk/Luhansk
• The export/supply/delivery etc of infrastructure-related goods to, or for use in, Crimea/Donetsk/Luhansk, including related technical assistance, financial services and funds, and/or brokering
• The provision of services relating to a relevant infrastructure sector (transport; telecommunications; energy; exploration/production of oil, gas and mineral resources) or tourism in Crimea/Donetsk/Luhansk

The exceptions to these restrictions have been similarly extended. Specific exceptions to the Donetsk/Luhansk restrictions have also been introduced – see new Regulation 60ZA.

Technical assistance relating to aircraft and ships

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022

(new Regulation 46A)

Prohibition on the provision of technical assistance to or for the benefit of a designated person relating to an aircraft or a ship.

"technical assistance" means (a) technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or (b) any other technical service relating to the goods or technology.

Ships - Donetsk and Luhansk regions

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022

(amendments to Regulation 57)

Extension of existing shipping restrictions in respect of Crimea (see 1 March 2022 below) to the Donetsk and Luhansk regions.

A British cruise ship may be directed not to enter a port in Crimea/Donetsk/Luhansk.

General licence - Wind down of positions involving Sovcomflot

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Permits the wind down of any transactions involving Sovocomflot (or a subsidiary) including the closing out of any positions, and any activity reasonably necessary to effect this, until 15 May 2022.

Procurement Policy Note - contracts with suppliers from Russia or Belarus

(accompanying FAQs)

Guidance issued by the Cabinet Office asks all public sector organisations to review contracts to identify any with Russian and Belarusian companies and, if possible to switch suppliers with minimal disruption, pursue legal routes of cancelling them.

The PPN also suggests that public sector organisations consider whether there are Russian/Belarusian subcontractors (being relied on to deliver the contract) in supply chains, but confirms that there is no requirement to ask contractors to consider terminating subcontracts with Russian/Belarusian subcontractors at this stage.

Suspension of publicly funded research and innovation collaborations with Russian Universities and companies of strategic benefit to the Russian state:

• Pause of all payments for projects delivered through UK public research funds with a Russian dimension.
• Further assessment of UK public research funders, to isolate and freeze activities which benefit the Russian regime.
• No funding of any new collaborative projects with Russia through UK research and innovation organisations.
• Suspension of existing government to government dialogue through the UK's science and innovation network team in Russia including their collaborative science projects.
• Where the UK is a member of multilateral organisations, working with partners to respond appropriately to hold Russia to account for its actions while diminishing and isolating its influence.

General licence - continuation of business and basic needs of GEFCO UK subsidiaries 

[NOW REVOKED]

[THIS GENERAL LICENCE WAS REVOKED ON 12 APRIL 2022: following the sale of Russian Railways' stake in GEFCO to non-designated persons, GEFCO is no longer impacted by UK sanctions]

Applies to GEFCO and subsidiaries (including GEFCO UK Ltd, GEFCO Forwarding UK, Auto XP Limited and XP Tech Limited)

GEFCO is a joint venture owned by Russian Railways (designated on 24 March 2022- see below) and Stellantis, GEFCO S.A Rue Jean Jaures, 20-22, 92800 Puteaux, France.

Permits the continuation of business operations involving GECFO or its subsidiaries including:

• Payments to or from GEFCO or its subsidiaries under any obligations or contracts; and
• Payments to or from any third party necessary to the continuation of any obligations or contracts.

A "Relevant Institution" may process payments made in accordance with the above.

Permits GEFCO subsidiaries to make basic needs payments, including insurance, property management, remuneration, pensions, tax, mortgage and utility payments.

[Amendment on 4 April 2022] A Person or a Relevant Institution may process payments or transactions related to the sale and transfer of GEFCO's shares by the Russian Railways.

Licence expires on 23 May 2022.

33 individuals, including:

• Eugene Markovich Shvidler, a businessman with close business links to Roman Abramovich.
• Oleg Tinkov, founder of Tinkoff Bank.
• Herman Gref, Chief Executive Officer of Sberbank
• Oleg E Aksyutin, the Deputy Chairman of the Management Board at Gazprom PJSC.
• Didier Casimiro, the First Vice President of Rosneft.
• Zeljko Runje, the Deputy Chairman of the Management Board and First Vice Pesident for Oil, Gas, and Offshore Business Development of Rosneft.
• Galina Danilchenko, installed as ‘mayor’ of Melitopol by Russian authorities.
• Polina Kovaleva, stepdaughter of Russian Foreign Minister, Sergey Lavrov.

26 entities, including:

• Five banks: Alfa-Bank (Alfa-Bank Ukraine has not been designated), Gazprombank, Russian Agricultural Bank (aka Rosselkhozbank), SMP Bank, Ural Bank for Reconstruction and Development
• Russian Railways
• Sovocomflot, Russia's largest shipping company.
• Kronshtadt, defence company and the main producer of Russian drones.
• The Wagner Group – the organisation Russian mercenaries reportedly tasked with assassinating President Zelenskyy.
• Alrosa, the world’s largest diamond mining company.

Six entities:

• Bank Dabrabyt
• CJSC Belbizneslizing
• Industrial-Commercial Private Unitary Enterprise Minotor-Service
• JSC Transaviaexport Airlines
• Belinvest-Engineering
• OJSC KB Radar-Managing Company Holding Radar System

General licence – wind down of positions with five designated banks

[EXPIRED]

Permits the wind down of any transactions involving:

• Alfa Bank JSC
• GazPromBank
• Rosselkhozbank
• SMP Bank
• Ural Bank for Reconstruction and Development
• subsidiaries owned/controlled by any of the above

including the closing out of any positions, and any activity reasonably necessary to effect this, until 23 April 2022.

Belarus: General licence – wind down of positions with Bank Dabrabyt

[EXPIRED]

Trade restrictions – increased import tariffs

The Customs (Additional Duty) (Russia and Belarus) Regulations 2022

Additional 35 per cent duty payable on imports of key products from Russia and Belarus. The products include:

• Russia: paper, cement, glass, silver, iron, steel, copper, aluminium, lead, nuclear reactors, electrical machinery/equipment, ships, works of art and antiques.
• Belarus: cereals, oil seeds, fruit and seeds, beverages spirits and vinegar, food waste, cement, fertilisers, tyres, fur, wood, paper, cement, glass, silver, iron, steel, copper, aluminium, lead, nuclear reactors, electrical machinery/equipment, ships, works of art and antiques.

The full lists of impacted products, including commodity codes, are available here.

Four existing OGELs have been amended to require registration before first use of the licence:

1. export after repair/replacement under warranty: dual-use items
2. export after repair/replacement under warranty: dual-use items – from June 2019
3. PCBs and components for dual-use items
4. PCBs and components for dual-use items – from June 2019
5.  export after repair/replacement under warranty: military goods – updated to allow items to be exported from the UK, after repair in the UK, or the country of original manufacture
6. export after repair/replacement under warranty: military goods – from June 2019 – updated to allow items to be exported from the UK, after repair in the UK, or the country of original manufacture

In addition, the export of dual-use items to EU member states OGEL has been updated to include Iceland as a permitted destination.

General licence - Wind down of certain transactions with the Central Bank, National Wealth Fund and Ministry of Finance

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Permits the provision of financial services for the purposes of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 1 March 2022 with:

• the Central Bank of the Russian Federation
• the National Wealth Fund of the Russian Federation
• the Ministry of Finance of the Russian Federation

A Person or Relevant Institution can carry out any activity reasonably necessary to effect this.

The licence expires on 2 May 2022.

Amended on 24 March 2022 to clarify that the licence includes persons owned/controlled or acting on behalf of the three named entities.

OFSI has added a new paragraph (4.1.4) to its general guidance on ownership and control which clarifies OFSI's position on aggregation, including the following:

"When making an assessment on ownership and control, OFSI would not simply aggregate different designated persons’ holdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated parties or one party controls the rights of another. Consequently, if each of the designated person's holdings falls below the 50% threshold in respect of share ownership and there is no evidence of a joint arrangement or that the shares are held jointly, the company would not be directly or indirectly owned by a designated person." (emphasis added)

Inaugural ministerial meeting of the Russian Elites, Proxies and Oligarchs Task Force (the "Task Force"). Joint statement confirmed:

• a commitment to prioritizing resources and working together to take all available legal steps to find, restrain, freeze, seize, and, where appropriate, confiscate or forfeit the assets of those individuals and entities that have been sanctioned in connection with Russia’s invasion of Ukraine; and
• a commitment to holding accountable those who have complicity in Russia’s unjust war and a determination to deny them the ability to hide and benefit from their assets in all jurisdictions and to undermine the integrity of the international financial system.

Signatories include representatives from: the US, Australia, Canada, France, Germany, Italy, Japan, the UK and the EU.

General Trade Licence – vessels

[NOW REVOKED]

[THIS GENERAL TRADE LICENCE WAS REVOKED ON 8 APRIL 2022]

• the vessel is moving from a third country to Russia, or to the UK or a third country from Russia, or transiting Russian territorial waters,
• the vessel is moving under its own power, and
• the movement of the vessel is not for the purpose of: (i) transfer of ownership of the vessel or any of its component parts, or (ii) a change of the operator of the vessel.

[A replacement general licence was granted on 8 April 2022 – see above.]

345 individuals, including a number of designations under the newly-introduced urgent procedure in the Economic Crime (Transparency and Enforcement) Act pursuant to the new "mirroring provisions" (i.e. because those individuals have already been sanctioned by the US, EU, Canada or Australia).

5 entities: Gas Industry Insurance Company SOGAZ, Geopolitica, Internet Research Agency, New Eastern Outlook, Oriental Review
Significant individuals included in the designations include:

Oligarchs:

• Mickhail Fridman, founder of Alfa Bank. He also owns shares in LetterOne.
• German Khan, a business partner of Aven and Fridman in both Alfa Bank and LetterOne.
• Petr Aven, who was President of Alfa Bank and co-founder of LetterOne.
• Alexey Mordashov, a majority shareholder in steel company Severstal
• Andrey Melnichenko, the founder of EuroChem Group.
• Viktor Vekselberg, owner of the Renova Group.
• Alexander Ponomarenko, chairman of the board of Sheremetyevo, the biggest airport in Russia.
• Dmitry Pumpyansky, owner and chairman of OAO TMK.
• Vadim Moshkovich, chairman of the board of directors of Rusagro Group.

Political allies:

• Dmitry Medvedev, deputy chairman of the Security Council of Russia
• Mikhail Mishustin, current Prime Minister of Russia
• Sergei Shoigu, Defence Minister.

Propagandists:

• Dmitry Peskov, Putin’s press secretary and a Kremlin spokesperson
• Maria Zakharova, the Director of the Information and Press Department of the Ministry of Foreign Affairs of the Russian Federation.

12 individuals

2 entities: Rosneft Aero and JSC Zelenodolsk Shipyard
All designated under the newly-introduced urgent procedure in the Economic Crime (Transparency and Enforcement) Act pursuant to the new "mirroring provisions", i.e. on the basis that those persons have already been sanctioned by the EU.

Economic Crime (Transparency and Enforcement) Act (the "2022 Act") receives Royal Assent. In terms of sanctions, the key provisions are as follows:

• Introduction of strict liability for any sanctions breaches (by removing any requirement for a party to "to have known, suspected or believed any matter"). [This provision comes into force on 15 June 2022 – see above].
• Introduction of a new urgent procedure for designations, including if a person/entity has been designated by the US, the EU, Australia or Canada, or if there is a public interest in that person/entity being designated.

Statement from the Chancellor, Rishi Sunak:

• "I welcome commitments already made by a number of firms to divest from Russian assets – and I want to make it crystal clear that the government supports further signals of intent."
• "I am urging firms to think very carefully about their investments in Russia and how they may aid the Putin regime – and I am also clear that there is no case for new investment in Russia."

The government recognises that some firms may find winding down their positions is a long-term process, given market conditions and the ability to sell assets due to the global sanctions placed on the Russian economy. The Chancellor said the government would do all it could to stand behind and support businesses who want to divest.

Trade – revocation of "most favoured nation" status

(announced but not yet implemented – G7 leaders' joint statement)

Denial of Russia's Most-Favoured-Nation (MFN) status relating to key products - the products of Russian companies will no longer receive Most-Favoured-Nation treatment in those economies.

[Implemented in part - by way of import tariff increases on key products from Russia (see 24 March 2022 above).]

A statement by a broad coalition of WTO members, including the G7, announcing their revocation of Russia’s Most-Favoured-Nation status is being prepared. [Update: the statement was published in 15 March 2022 – accessible here.]

Financial restrictions – removal of access to leading multilateral financial institutions

(announced but not yet implemented – G7 leaders' joint statement)

Prohibition on Russia from obtaining financing from the leading multilateral financial institutions, including the International Monetary Fund, the World Bank and the European Bank for Reconstruction and Development.

[See equivalent entry for the EU for further detail.]

Financial restrictions – closing loop-holes

(announced but not yet implemented – G7 leaders' joint statement)

Financial restrictions – new debt/equity

(announced but not yet implemented – G7 leaders' joint statement)
 

Prohibition on Russian entities who are directly or indirectly supporting the war accessing new debt and equity investments and other forms of international capital.

Seven individuals:

• Roman Arkadyevich ABRAMOVICH (owner of Chelsea FC and has stakes in steel giant Evraz and Norilsk Nickel);
• Igor Ivanovich SECHIN (Chief Executive of Rosneft);
• Oleg Vladimirovich DERIPASKA (has stakes in En+ Group);
• Dmitri Alekseevich LEBEDEV (Chairman of the Board of Directors of Bank Rossiya);
• Alexei Borisovich MILLER (CEO of energy company Gazprom);
• Andrei Leonidovich KOSTIN (Chairman of VTB Bank); and
• Nikolai Petrovich TOKAREV (president of the Russia state-owned pipeline company Transneft)

General licence – Chelsea football club

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Exemption to the asset freeze restrictions for Chelsea football club (by virtue of it being owned/controlled by Roman Abramovich) to permit it to make various payments associated with its continued operation, and for individuals/entities to make/receive payments in respect of the same.

The licence confirms that:

• the purchase or production of new merchandise by a third party is not permitted, unless there was an obligation to do so prior to 10 March 2022; and
• any funds which the Club receives must be frozen.

This licence expires on 31 May 2022

General licence – amendment to VTB wind-down licence (payment into frozen accounts)

[EXPIRED]

Amendments to the publication notice to the existing licence (see 25 February entry below):

• OFSI confirmed that the existing VTB wind-down General Licence does not contain a requirement that funds payable to VTB as part of winding down any transactions with VTB be paid into a frozen account.
• If funds become payable to a subsidiary of VTB as part of winding down any transactions with VTB subsidiaries, OFSI suggests considering how the ownership and control provisions in the 2019 Russia Regulations could apply to such payment.

Exemption to the existing asset freeze provisions to permit Belaeronavigatsia (the provider of air navigation services in Belarus) to provide navigational data to civilian aircraft, and for flight data providers to make payments to Belaeronavigatsia in respect of the same.

This licence is of indefinite duration.

The UK Government announced that:

• the UK will phase out the import of Russian oil during the course of the year in response to the illegal invasion of Ukraine; and
• it will establish a new joint taskforce with industry to work together on an orderly transition,

in order to move will increase the growing pressure on Russia’s economy by choking off a valuable source of income.

Note: no associated sanctions have been announced.

See also the further statement from Kwasi Kwarteng, Secretary of State for Business, Energy and Industrial Strategy, on 10 March 2022.

General licence – amendment (VTB wind-down) 

[EXPIRED]

Amendments to existing licence (see 25 February entry below) was amended to update references to UK legislation and expand the definition of a subsidiary. No amendments to activity covered by the licence or the validity period.

General trade licence – aviation insurance 

[NOW REVOKED]

[THIS GENERAL TRADE LICENCE WAS REVOKED ON 29 MARCH 2022]

Provides authorisation for certain prohibited insurance/reinsurance services relating to aviation and space goods or technology:

• Insurance services if, before 8 March, the provider: (i) did not reinsure any of their obligations; or (ii) reinsured any of their obligations to provide those insurance services and no such reinsurance cover has been rendered unenforceable, suspended, frustrated or prohibited by any applicable sanctions; or

Trade sanctions - aviation and space goods or technology

The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022

Prohibition on the export/supply/delivery etc of certain specified aviation and space goods or technology:

• to Russia
• to a person connected with Russia; or
• for use in Russia.

"person connected with Russia" – see entry at 1 March 2022 below.

"aviation and space goods or technology" – specified in Schedule 2C of the 2019 Regulations (as amended. Includes "any tangible storage medium on which aviation and space technology is recorded".

Also includes a prohibition on the provision, directly or indirectly, of insurance or reinsurance services relating to aviation and space goods or technology

Extension of certain existing exceptions to aviation and space goods or technology.

Ships - prohibition on port entry

The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022

Amendments to the existing prohibitions introduced on 1 March 2022 (see entry below):

• A detention direction may also now be given to "a ship registered in Russia".
• Clarification that a ship is not "operated" by its master or crew unless that master or crew are designated persons for the purposes of the shipping restrictions.

Prohibition on Russian aircraft

The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022

Prohibition on Russian aircraft overflying or landing in the UK. Air traffic controllers may (or may be instructed to) give such directions to Russian aircraft.

Airport operators may (or may be instructed to) give instructions to Russian aircraft not to take off, to take off or not to land at an airport. Airport operators giving instructions not to take off must take reasonable steps to detain the aircraft.

The Civil Aviation Authority (CAA) may also be required to refuse certain permissions under the Air Navigation Order (ANO).

"Russian aircraft" means an aircraft (i) registered in Russia; or (ii) owned, chartered or operated by a designated person (under these aircraft restrictions), or a person connected with Russia.

Persons/entities can be "designated" for the purposes of the above restrictions/prohibitions.

Exceptions on grounds of safety to other aircraft, passengers or people on the ground.

General licence - Wind Down of Positions Sberbank 

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Grants an exemption to 3 April 2022 to permit the wind down of activity which would be caught by the prohibition on the provision of financial services for the purpose of foreign exchange reserve and asset management (under Regulation 18A – by virtue of Sberbank being owned or controlled directly or indirectly by the Central Bank, the National Wealth Fund or the Ministry of Finance).

General licence - Wind Down of Positions Involving Various Designated Banks 

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Grants an exemption to 3 April 2022 to permit non-designated persons/entities to wind-down any transactions with Bank Otkritie, Promsvyazbank, Bank Rossiya, Sovcombank, Vnesheconombank (VEB), Novikombank, or any subsidiary thereof.

Exemption permits the winding down of any transactions and "any activity reasonably necessary to effect this".

Asset freeze – all Russian Banks

(announced but not yet implemented)

The Government announced that it intends to "asset freeze every Russian bank".

The Foreign Secretary also stated at a press conference that "We need to make sure no Russian bank has access to SWIFT".  Boris Johnson repeated this message in an article published on 6 March 2022 ("We must go further on economic sanctions, expelling every Russian bank from SWIFT.")

Financial restrictions – dealing with Central Bank and others

The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022

Prohibition on UK individuals/entities from providing financial services for the purpose of foreign exchange reserve and asset management to:

• the Central Bank of the Russian Federation
• the National Wealth Fund of the Russian Federation
• the Ministry of Finance of the Russian Federation
• a person owned or controlled, or acting by, or on behalf of/at the direction of, any of the persons above

"foreign exchange reserve and asset management" includes money market instruments (including cheques, bills and certificates of deposit); foreign exchange; derivative products (including futures and options); exchange rate and interest rate instruments (including products such as swaps and forward rate agreements); transferable securities; other negotiable instruments and financial assets (including bullion); and/or special drawing rights.

Licences may be granted in certain circumstances, including humanitarian assistance, financial regulation, financial stability, soundness of a firm or extraordinary circumstances.

Grants an exemption to UK financial regulators in relation to VTB Capital plc / any other VTB UK subsidiary "for the purposes of the functions of that authority including as they relate to prudential supervision or protecting, maintaining or enhancing the stability of the financial system of the United Kingdom" until 1 March 2023 3 April 2025.

[Note: This general licence was extended on 24 February 2023, please see entry above for more information]

Relevant UK regulators include the FCA, FSCS, PRA and Bank of England.

Grants an exemption to VTB Capital plc / any other VTB UK subsidiary to permit it to make payments for basic needs, including:

• insurance premiums, property management, salaries, tax, mortgage and utility payments;
• charges arising from the routine holding and maintenance of its frozen funds or economic resources; and
• legal fees.

Grants an exemption to allow persons to receive, and UK financial institution to process, such payments.

[Amendment on 1 April 2022] Any person, including any subsidiary of VTB incorporated in the UK, may make, receive or process any payments, or take any other action, in connection with any insolvency proceedings relating to VTB Capital plc. Permits the receipt and processing of any such payments.

• "insolvency proceedings" includes all those set out in the Insolvency Act 1986 and the Banking Act 2009

 [Amendment on 22 April 2022] The General Licence now also includes Sberbank CIB (UK) Ltd, the UK subsidiary of Sberbank.

[Amendment on 22 August 2022] The General Licence now also includes Guernsey subsidiary VTBC Asset Management International Limited and EU subsidiary VTB Bank (Europe) SE (VTBE) and any entity owned or controlled by VTBE incorporated in Germany.

[Amendment on 6 October 2022] The General Licence now includes payments related to Insolvency Proceedings under the German Banking Act. The General Licence expires on 3 April 2023.

[Amendment on 24 February 2023] The general licence was extended to expire on 3 April 2025 at 23:59- please see the entry above for more information].

Prohibition on port entry

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022

Ban on Russian ships entering UK ports. Includes ships:

• Owned/controlled/chartered by a designated person or a person "connected with Russia" (see definition below);
• Flying the flag of Russia or registered in Russia; or
• Specified ships [Note – as far as we are aware, none have yet been "specified"]

Any such ship can be directed to enter or leave a port in a specific direction, proceed to a specific location or remain where it is, including that a ship be detained in a UK port.

A British cruise ship may be directed not to enter a Crimean port.

Persons/entities can be "designated" for the purposes of the above restrictions

Financial restrictions – capital markets / loans

The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022

Extended the existing capital markets prohibition, as follows:

1. Prohibition on dealing with a transferable security or money-market instrument a maturity exceeding 30 days and issued on or after 1 March 2022 by:

• a UK entity owned by Sberbank, VTB Bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank, OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft, Gazprom Neft (each a "Schedule 2 Entity") or someone acting at their direction/on their behalf [Note: These banks were previously subject to capital markets restrictions]

2. Prohibition on dealing with any transferable security or money-market instrument issued on or after 1 March 2022 by:

• a person connected with Russia which is not: (i) a Schedule 2 Entity, (ii) an entity domiciled outside of Russia; or (iii) a branch/subsidiary of (ii) – effectively any Russian domiciled-entities which are not branches or subsidiaries of a non-Russian entity – or an entity which is owned by, or acting at the direction of such an entity.
• the Government of Russia, or an entity acting on its behalf

Extended the existing restrictions on the granting of loans/credit. It is prohibited to grant the following loans/credit:

1. Category 1 Loan: loan/credit with a maturity exceeding 30 days to a Schedule 2 Entity, or a non-UK entity owned by a Schedule 2 Entity, or any entity acting on their behalf, at any time after 31 December 2020. [Note: existing exemptions still apply.]
2. Category 2 Loan: loan/credit with a maturity exceeding 30 days to a UK entity owned by a Schedule 2 Entity, or any entity acting on their behalf, at any time after 1 March 2022.
3. Category 3 Loan: loan/credit with a maturity exceeding 30 days to an entity connected with Russia (or to an entity owned by a person connected with Russia, or acting at its direction/behalf), except if that entity is not Russian-domiciled or owned by an entity which is not Russian-domiciled, at any time after 1 March 2022.
4. Category 4 Loan: loan/credit to the Government of Russia at any time after 1 March 2022.

"connected with Russia" means:

• an individual/group of individuals who are ordinarily resident or located in Russia
• an entity which is incorporated/constituted under Russian law or domiciled in Russia.

Financial restrictions - correspondent banking relationships

The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022

Prohibition on UK credit/financial institutions:

• having a correspondent banking relationship with; or
• processing sterling payments to/from/via,

any designated person or any credit/financial institutions owned/controlled by a designated person.

Note: OFSI has expressly confirmed that these restrictions apply to Sberbank (but when the restriction was introduced, Sberbank was not subject to an asset-freeze). Sberbank became subject to an asset freeze on 6 April 2022.

Trade restrictions

The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2022

Extension of existing trade restrictions applicable to military goods/technology to dual-use goods and certain specified goods referred to as "critical-industry goods/technology" (set out in Schedule 2A), which include:

• electronic devices/components and related equipment
• computers and related equipment
• telecommunications and information security equipment
• sensors and lasers
• navigation and avionics equipment
• marine vessels and equipment
• aerospace and propulsion equipment, including engines and aircraft

Certain exceptions for: personal effects, consumer communication devices and software updates

General Licence – capital markets restrictions

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Grants an exemption to the extended capital markets restrictions until 23:59 on 08 March 2022 for:

General Licence – correspondent banking relationships & processing sterling payments - Sberbank 

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Grants an exemption to the prohibition on maintaining a correspondent banking relationship and processing sterling payments in respect of Sberbank until 23:59 on 31 March 2022.

Grants an exemption to the prohibition on the processing of sterling payments from/to/via:

• Sberbank ; or
• any non-UK financial institution owned/controlled by Sberbank,

for the purposes of making crude oil, petroleum products or gas available for use in the UK until on 24 June 2022.

[General licence was amended on 6 April 2022 – see above]

Four individuals: Andrei Burdyko, Victor Vladimirovich Gulevich, Sergei Simonenko and Andrey Zhuk (all senior members of the Belarussian Military/Ministry of Defence)

Two entities: JSC 558 Aircraft Repair Plant, JSC Integral (both Belarussian defence companies)

Financial restrictions – Russian Central Bank and others

(announced but not yet implemented) ¹

General Licence– Wind Down of Positions Involving VTB

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

Allows until 27 March 2022 to wind down any transactions with VTB/any UK subsidiary, including closing out any positions. Any activity "reasonably necessary" to effect this is permitted.

1. Rostec (Russia's largest defence company).
2. Uralvagonzavod (one of the world’s largest tank manufacturers).
3. Tactical Missile Corporation (Russia’s leading supplier of air and sea missiles).
4. United Aircraft Corporation (a holding company that includes all major Russian aircraft manufacturers).
5. United Shipbuilding Corporation (the largest shipbuilding company in Russia).

Asset freeze (announced, awaiting implementation) ²

Financial and investment restrictions

(announced, awaiting implementation) ³

Prohibition on Russian individuals' access to UK banks, including £50,000 limits on bank accounts.

Additional basis for designation under UK sanctions regime:

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022

Amended the Russia (Sanctions) (EU Exit) Regulations 2019 to include an additional basis for designation under the UK sanctions regime, namely if a person is/has been involved in "obtaining a benefit from or supporting the Government of Russia". This is defined as including:

a) carrying on business as a Government of Russia-affiliated entity;

b) carrying on business of economic significance to the Government of Russia; or

c) carrying on business in a sector of strategic significance to the Government of Russia, those sectors being: chemicals, construction, defence, electronics, energy, extractives, financial services, information, communications and digital technologies, and transport.

Designated person/asset freeze (Russia-specific) 

Investment ban targets (Russia-specific

Consolidated list search tool (not Russia-specific)

OFSI Financial sanctions - Russia

OFSI Financial sanctions - Belarus

General Licences (OFSI)

Financial sanctions: general guidance (OFSI)

Statutory guidance (Russia sanctions)

Russia guidance (OFSI)

Enforcement and monetary penalties guidance (OFSI)

Statutory guidance (Republic of Belarus sanctions)

Guidance (Trading under sanctions with Russia)