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Tracker of Sanctions in response to Ukraine Crisis

This tracker is a high-level summary of the measures imposed by UK following Russia's invasion of Ukraine in February 2022. In the current circumstances, the status of these measures are subject to change on a daily basis. Certain measures were in place prior to February 2022 and these are not included in this tracker. Whilst every effort has been made to ensure the accuracy and completeness of this summary at the date of publication, no reliance should be placed on its content and it does not constitute legal advice. Please refer to the primary sources of the restrictions for their full content.

This tracker was last updated on 16 August 2022.

UK
Date of impositionSanction imposed Summary 
16 August 2022General LicenceMongolia energy payments

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.

5 August 2022General LicenceCompanies winding down operations in Russia 

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.

2 August 2022 Asset freeze2 individuals: Didier Casimiro and Zeljko Runje
29 July 2022Extension of Rosbank General LicenceThe General Licence permitting wind down of positions involving Rosbank (see entry from 30 June 2022) has been extended until 30 September 2022.
26 July 2022 Asset freeze41 individuals, including Kremlin-imposed "officials" in Luhansk and Donetsk, Russia's Minister and Deputy Minister of Justice, relatives of an oligarch, and Syrian individuals who have been recruiting Syrians to fight with Russia.

1 entity: Al-Sayyad Company for Guarding and Protection Services
22 July 2022General licencepayment to UK insurance companies for building and engineering insurance

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 the permitted payments
  • UK insurers to make return payments to frozen UK bank accounts, for the payment of funds due as a result of a claim made pursuant to the permitted payments, or as a result of an overpayment;
  • 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.

This licence does not permit the provision of insurance to those 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

Aviation technical assistance

The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022
Amendment of the measures introduced in the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 (see entry from 30 March 2022) to allow necessary technical assistance for temporarily detained aircraft in the ownership of suspected designated persons due to the rapid rate of aircraft degradation.
Trade restrictions – gold

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); 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.

20 July 2022

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.

19 July 2022General licenceinvestments in relation to RussiaPermits a person to carry out/wind down the prohibited activities in relation to outward investment to Russia detailed below for a period of 7 days.

This General Licence expires on 26 July 2022.
Financial and investment restrictions – investments in relation to Russia

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

o A person, other than an individual, connected with Russia;
o 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.

"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:

o A transferable security where such dealing is prohibited by regulation 16;

o A relevant security issued by a person connected with Russia; or

o 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.

18 July 2022Designation criteria

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

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:

o prohibited trade in relation to non-government controlled territory;

o prohibited infrastructure-related services relating to non-government controlled Ukrainian territory);

o 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.
Interpretation: ship and aircraft ownership

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

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
15 July 2022

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:

(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.

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)
Asset freeze 

2 individuals have been removed from the asset freeze list:

  • Didier Casimiro
  • Zeljko Runje
12 July 2022OFSI and NCA Red Alert – Evasion typologies

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.

7 July 2022General licencehumanitarian activities

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.

5 July 2022

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:

a) Belarus;

b) Belarusian authority;

c) a person, other than an individual, which is not a person within sub-paragraphs (d), (e) or (f) and which is wholly owned by Belarus or a Belarusian authority;

d) a credit or financial institution which is majority owned by Belarus or a Belarusian authority;

e) 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 (d);

f) a person acting on behalf of or at the direction of a person within sub-paragraph (d) or sub-paragraph (e).

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:
    o prohibiting port entry;
    o otherwise directing the movement of a ship;
    o 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.
Belarus: General Licence – Wind down of positions involving National Bank of Belarus

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. 

Belarus: General Licence – Transferable securities, money market instruments, loans and credit arrangements

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.

Asset freeze

2 individuals added:

  • Denis Yakovlevich Gafner
  • Veleriya Kalabayeva

2 individuals have been removed from the asset freeze list:

  • Yakov Vladimirovich Rezantsev
  • Galina Ulyutina
4 July 2022Asset freeze

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
30 June 2022General Licence – Wind down of positions involving Rosbank

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.

29 June 2022Asset freeze

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
G7 statement – Russian energy

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) 

Announcement of new measures to prevent Russia from accessing UK trust services (services which allow a person or business to manage the assets of another).
26 June 2022 

Trade restrictionsgold 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.

Trade restrictions –goods/technology relating to non-government controlled Ukrainian territory

The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) 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. 10) 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. 10) 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. 10) 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. 10) 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. 10) 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. 10) 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. 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)
 16 June 2022Asset freeze

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.
 10 June 2022 General Licence – Funds of non-designated third parties involving designated credit or financial institutions

 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.

 Financial sanctions - strict liability for breach

The Economic Crime (Transparency and Enforcement) Act 2022 (Commencement No. 2 and Saving Provision) Regulations 2022

 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."

June 2022 Updated OFSI guidance – Monetary penalties

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.

Guidance from the Department for International Trade: Trading under sanctions with Russia

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
 
31 May 2022

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 LicenceTelecommunications 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):

1. 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.

    2. 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.

General Licence – Charities associated with designated persons

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.

23 May 2022
General Licence – Russian travel

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.

19 May 2022Asset Freeze

3 entities:

  • JSC Rossiya Airlines
  • JSC Ural Airlines
  • PJSC Aeroflot
14 May 2022Further sanctions announced - G7 Foreign Ministers' statement

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

13 May 2022Asset Freeze12 individuals including Putin's ex-wife, cousins and childhood friends who support him financially
General Licence – Amsterdam Trade Bank (basic needs and wind down)

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.

8 May 2022Further sanctions announcement - G7 meeting

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.

5 May 2022General Licence – Evraz

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

Asset FreezeOne entity, Evraz plc, a major manufacturer of Russian steel
4 May 2022

Trade restrictions – a ban on services exports to Russia

(announced but not yet implemented)

The UK has announced a ban on services exports to Russia, including management consulting, accounting and PR services.
Asset Freeze

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
29 April 2022Social media and internet services restrictions

The Russia (Sanctions) (EU Exit) (Amendment) (No.9) Regulations 2022

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.

27 April 2022General licence - Law Enforcement and Regulatory Authorities Asset Recovery

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.

22 April 2022

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.)

21 April 2022

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.

General licence – Russian banks (wind-down) – amendment to publication notice

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.

Asset Freeze

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
19 April 2022

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."

14 April 2022Asset Freeze

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.

13 April 2022Asset Freeze 206 individuals, including: 178 separatists who have been supporting Russian-backed breakaway regions of Ukraine, 6 oligarchs, close associates and employees, and an additional 22 individuals.
8 April 2022 
Asset freeze
3 individuals: Katerina Vladimirovna Tikhonova and Maria Vladimirovna Vorontsova (daughters of Vladimir Putin); and Yekaterina Sergeyevna Vinokurova (daughter of Sergey Lavrov)
General Trade Licence - Vessels

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).

7 April 2022 

Further sanctions – announcement (G7 foreign ministers' statement) 

 "We stress the necessity of further increasing the economic pressure inflicted on Russia and the Lukashenka regime in Belarus. Together with international partners, the G7 will sustain and increase pressure on Russia by imposing coordinated additional restrictive measures to effectively thwart Russian abilities to continue the aggression against Ukraine. We will work together to stop any attempts to circumvent sanctions or to aid Russia by other means. We are taking further steps to expedite plans to reduce our reliance on Russian energy, and will work together to this end."
6 April 2022Asset Freeze

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 - Credit Bank of Moscow (wind-down)Permits the wind down of any transactions involving Credit Bank of Moscow (or a subsidiary) including the closing out of any positions, and any activity reasonably necessary to effect this, until 6 May 2022.
General licenceSberbank (energy) - amendmentsAmendment to the General Licence granted on 1 March 2022 in respect of energy-related payments (see below). The amendment ensures that the General Licence in respect of energy related payments may continue to be used since Sberbank became subject to an asset freeze on 6 April 2022.
4 April 2022

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".

1 April 2022

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.

General licence – VTB (basic needs) – amendment

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

31 March 2022Asset freeze 

12 individuals: including Russian propagandists and military personnel.

2 entities: Rossiya Segodnya and TV-Novosti (both Russian media organisations)

Asset freeze

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.]

30 March 2022 

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.

29 March 2022

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.

28 March 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.

27 March 2022Research and innovation sanctions

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.
25 March 2022

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.

24 March 2022Asset freeze

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.
Belarus: asset freeze

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]

Permits the wind down of any transactions involving Bank Dabrabyt including the closing out of any positions, and any activity reasonably necessary to effect this, until 23 April 2022.

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.

Open general export licence ("OGEL") - amendments

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. Two existing OGELs have been revised 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 – updated to allow items to be exported from the UK, after repair in the UK, or the country of original manufacture
  7. 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.

22 March 2022

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.

Update to OFSI guidance – ownership and control

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)

17 March 2022Tax – suspension of cooperationThe UK has suspended all exchange of tax information with Russia and Belarus under the UK’s exchange of information agreements, including the Convention on Mutual Administrative Assistance in Tax Matters and under bilateral Double Tax Agreements.
Oligarch Task Force - meeting

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]

Permits the provision of technical assistance, financial services and funds, and brokering services relating to vessels / their component parts / associated technology, where:

  • 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.

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.

The licence is stated to be "a temporary measure which will address a shortcoming" in the relevant regulation.

 

[A replacement general licence was granted on 8 April 2022 – see above.]

15 March 2022Asset freeze

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.
Asset freeze

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 2022 – strict liability and new designation procedure

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.
Trade/financial restrictions: Export financeThe UK government announced it will no longer issue any new guarantees, loans and insurance for exports to Russia and Belarus.
13 March 2022Investments in Russia – Government statement

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.

11 March 2022

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 below for further detail.]

Financial restrictions – closing loop-holes

(announced but not yet implemented – G7 leaders' joint statement)

Focus on cracking down on evasion and to closing loop-holes in existing sanctions. Specifically, ensuring that existing measures include digital / crypto-assets.

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.

Asset freeze – individuals
386 individuals: members of the State Duma of the Russian Federation who voted in favour of the laws which recognised the Donetsk People’s Republic and the Luhansk People’s Republic as independent states.
10 March 2022Asset freeze – individuals

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

9 March 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.
Belarus: General licence - Provision of navigational data to civilian aircrafts for flight safety

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.

7 March 2022Russian oil imports – announcement

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
  • Reinsurance services if the insurance obligations they are reinsuring have not been rendered unenforceable, suspended, frustrated or prohibited by any applicable sanctions.

Authorisation applies until 28 March 2022 under contracts concluded before 8 March 2022 in pursuance of or in connection with an arrangement for financial services relating to the provision of military goods to a person connected with Russia / for use in Russia etc.

Trade sanctions - aviation and space goods or technology

The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022

Prohibition on the 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.

4 March 2022

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".

3 March 2022Asset freezeTwo individuals: Igor Ivanovich Shuvalov (Chairman of VEB) and Alisher Burkhanovich Usmanov (prominent Russian businessman and pro-Kremlin oligarch)

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.")

1 March 2022

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.

General licence – financial restrictions – VTB (regulators)

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.

Relevant UK regulators include the FCA, FSCS, PRA and Bank of England.

General licence - financial restrictions – VTB (basic needs)

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.

The General Licence takes effect in its amended form from 22 April 2022 and expires on 3 April 2023.

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

Asset freezeOne individual: Kirill Alexandrovich Dmitriev (CEO of Russian Direct Investment Fund)

One entity: Russian Direct Investment Fund (Russia's sovereign wealth fund)

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:

a) dealing with a transferable security or money-market instrument

b) granting a Category 1, 2 or 3 Loan

c) processing GBP payments in respect of a) or b).

Note: that there is no exemption for a Category 4 Loan (to the Russian Government).

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.

General Licence - processing sterling payments – energy/Sberbank

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]

Asset freeze

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)

28 February 2022Asset freeze Three entities: VEB, Bank Otkritie, Sovocombank.
28 February 2022

Financial restrictions – Russian Central Bank and others

(announced but not yet implemented) 1

In addition to those measures announced on 24 February 2022 (see below), new sanctions will include a prohibition on any UK natural or legal persons from undertaking financial transactions involving the CBR or the Ministry of Finance of the Russian Federation. [Implemented in part – see above (1 March ) - but not subject to asset freezes.]
26 February 2022
(announced but not yet implemented)
Visa restrictions – "golden passports"Introduction of measures to limit the sale of citizenship—so called golden passports—that let wealthy Russians connected to the Russian government become citizens of Western countries and gain access to their financial systems. [Note: the UK ended its Tier-1 investor visa scheme on 17 February 2022.]
25 February 2022Asset freeze Two individuals: Vladimir Putin and Sergei Lavrov.

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.

24 February 2022
Asset freeze and travel banFive individuals: Kirill Shamalov, Petr Fradkov, Denis Bortnikov, Yury Slyusar and Elena Aleksandrovna Georgieva (described as being part of "Putin’s inner circle").
Asset freezeVTB Bank (one of Russia's largest banks) – see General Licence below.
Five Russian defence companies:
  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).
24 February 2022

Asset freeze (announced, awaiting implementation) 2

All Russian banks (to the extent not already covered) – implemented in part (see below/above)

Financial and investment restrictions

(announced, awaiting implementation) 3

Prohibition on Russian individuals' access to UK banks, including £50,000 limits on bank accounts.

22 February 2022Asset freeze and travel banThree individuals: Gennady Timchenko, Igor Rotenberg and Boris Rotenberg.
Asset freezeFive Russian banks: Bank Rossiya, Black Sea Bank, Genbank, IS Bank, and Promsvyazbank.
10 February 2022

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.

Additional contributors: Adela Mackie and Aaron Marchant

Footnotes

1. Any measures which have been implemented since their announcement have not been listed here.
2. Any measures which have been implemented since their announcement have not been listed here.
3. Any measures which have been implemented since their announcement have not been listed here.

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