This tracker was last updated on 16 August 2022.
UK
Date of imposition | Sanction imposed | Summary |
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16 August 2022 | General Licence – Mongolia energy payments | Permits:
"Person" means an individual, a body of persons corporate or incorporate, any organisation or any association or combination of persons. The "Sanctioned Banks" are:
This General Licence expires on 14 August 2023. |
5 August 2022 | General Licence – Companies winding down operations in Russia | Permits, subject to reporting requirements:
"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. |
2 August 2022 | Asset freeze | 2 individuals: Didier Casimiro and Zeljko Runje |
29 July 2022 | Extension of Rosbank General Licence | The 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 freeze | 41 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 2022 | General licence – payment to UK insurance companies for building and engineering insurance | Permits, subject to reporting and record-keeping requirements:
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:
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:
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:
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:
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Trade restrictions – energy-related goods and services The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022 | Expanded existing prohibitions, including:
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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:
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 2022 | General licence – investments in relation to Russia | Permits 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:
o A person, other than an individual, connected with Russia;
"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:
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Exceptions – investments in relation to Russia The Russia (Sanctions) (EU Exit) (Amendment) (No 12) Regulations 2022 | Exceptions to the prohibitions outlined above include:
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:
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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 2022 | Designation 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:
The definition of "being associated with" a person has been extended to those who are an "immediate family member" which is defined as:
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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:
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;
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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:
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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:
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:
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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
"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. | |
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:
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:
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:
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:
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Asset freeze | 2 individuals have been removed from the asset freeze list:
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12 July 2022 | OFSI 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 2022 | General licence – humanitarian 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:
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]
"Category B loan"
"Category C 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:
"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:
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:
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Belarus: Enabling or facilitating military activities The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 | A person must not directly or indirectly provide:
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 "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:
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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:
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:
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:
2 individuals have been removed from the asset freeze list:
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4 July 2022 | Asset freeze | 6 individuals:
1 entity:
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30 June 2022 | General 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:
A person, relevant institution, Rosbank or a subsidiary can carry out any activity reasonably necessary to effect this.
This General Licence has been extended on 29 July 2022 and now expires on 30 September 2022. |
29 June 2022 | Asset freeze | 8 individuals including:
5 entities:
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G7 statement – Russian energy | The G7 Leaders' Communiqué from the summit in Elmau contained the following statements regarding Russian energy:
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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 restrictions – gold exports (announced but not yet implemented) | Announcement of a prohibition on new exports of Russian gold entering the UK. This import ban will apply to newly mined or refined gold and will not impact Russian-origin gold previously exported from Russia. The ban will be introduced "shortly". Canada, US and Japan are due to introduce similar measures. |
23 June 2022 [THESE REGULATIONS HAVE BEEN REVOKED AND REPLACED BY A SIMILAR SET OF REGULATIONS THROUGH THE RUSSIA (SANCTIONS) (EU EXIT) (AMENDMENT) (NO 11) REGULATIONS 2022] |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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16 June 2022 | Asset freeze | 12 individuals including:
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10 June 2022 | General Licence – Funds of non-designated third parties involving designated credit or financial institutions | Permits:
Subject to specific reporting and record-keeping requirements. |
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. "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." | |
8 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:
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:
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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 Licence – Telecommunications Services and News Media Services (Continuation of Business and Basic Needs) | Permits certain activity which would otherwise breach the prohibitions in Regulations 11 to 17A of the Russia Regulations (i.e. the asset freeze provisions and the capital markets restrictions): 1. A person (other than a designated person) may continue business operations involving the provision of "Civilian Telecommunication Services" including:
2. A person (other than a designated person) may continue business operations involving the provision of "News Media Services" including: 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 General Licence also permits an Interim Manager and/or trustee to authorise:
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:
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 2022 | Asset Freeze | 3 entities:
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14 May 2022 | Further sanctions announced - G7 Foreign Ministers' statement | In a further statement, the G7 Foreign Ministers stated that:
For the UK Government's press release on this, see here |
13 May 2022 | Asset Freeze | 12 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:
This General Licence expires on 12 May 2023. | |
8 May 2022 | Further sanctions announcement - G7 meeting | A collective commitment from the G7 to taking the following measures:
[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 2022 | General 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 Freeze | One 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:
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29 April 2022 | Social media and internet services restrictions The Russia (Sanctions) (EU Exit) (Amendment) (No.9) Regulations 2022 | Imposes obligations on internet companies, including requirements that :
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 2022 | General licence - Law Enforcement and Regulatory Authorities Asset Recovery | Permits certain specified activities in connection with law enforcement and asset recovery, including:
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]
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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).
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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:
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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 2022 | Asset Freeze | 2 individuals:
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Trade restrictions – luxury goods
| Prohibition on the export/supply/delivery etc of luxury goods:
"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
"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:
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 2022 | Asset 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 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 2022 | Asset Freeze | 8 individuals:
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:
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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 licence – Sberbank (energy) - amendments | Amendment 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]
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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:
[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]
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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 2022 | Asset 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:
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 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]
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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 2022 | Research and innovation sanctions | Suspension of publicly funded research and innovation collaborations with Russian Universities and companies of strategic benefit to the Russian state:
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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]
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24 March 2022 | Asset freeze | 33 individuals, including:
26 entities, including:
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Belarus: asset freeze | Six entities:
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General licence – wind down of positions with five designated banks [EXPIRED] |
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Belarus: General licence – wind down of positions with Bank Dabrabyt [EXPIRED] | ||
Trade restrictions – increased import tariffs The Customs (Additional Duty) (Russia and Belarus) Regulations 2022 | Additional 35 per cent duty payable on imports of key products from Russia and Belarus. The products include:
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:
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: 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]
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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 2022 | Tax – suspension of cooperation | The 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:
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 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 2022 | Asset 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 Oligarchs:
Political allies:
Propagandists:
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Asset freeze | 12 individuals 2 entities: Rosneft Aero and JSC Zelenodolsk Shipyard | |
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:
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Trade/financial restrictions: Export finance | The UK government announced it will no longer issue any new guarantees, loans and insurance for exports to Russia and Belarus. | |
13 March 2022 | Investments in Russia – Government statement | Statement from the Chancellor, Rishi Sunak:
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 2022 | Asset freeze – individuals | Seven individuals:
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General licence – Chelsea football club [EXPIRED] | [THIS GENERAL LICENCE HAS NOW EXPIRED]
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9 March 2022 | General licence – amendment to VTB wind-down licence (payment into frozen accounts) [EXPIRED] |
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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 2022 | Russian oil imports – announcement | The UK Government announced that:
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] |
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General trade licence – aviation insurance [NOW REVOKED] | [THIS GENERAL TRADE LICENCE WAS REVOKED ON 29 MARCH 2022]
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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:
"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):
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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]
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General licence - Wind Down of Positions Involving Various Designated Banks [EXPIRED] | [THIS GENERAL LICENCE HAS NOW EXPIRED]
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3 March 2022 | Asset freeze | Two 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:
"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:
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.
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:
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 freeze | One 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:
Extended the existing restrictions on the granting of loans/credit. It is prohibited to grant the following loans/credit:
"connected with Russia" means:
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Financial restrictions - correspondent banking relationships The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022 | Prohibition on UK credit/financial institutions:
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:
Certain exceptions for: personal effects, consumer communication devices and software updates | |
General Licence – capital markets restrictions [EXPIRED] | [THIS GENERAL LICENCE HAS NOW EXPIRED]
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General Licence – correspondent banking relationships & processing sterling payments - Sberbank [EXPIRED] | [THIS GENERAL LICENCE HAS NOW EXPIRED]
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General Licence - processing sterling payments – energy/Sberbank | Grants an exemption to the prohibition on the processing of sterling payments from/to/via:
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 2022 | Asset 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 2022 | Asset freeze | Two individuals: Vladimir Putin and Sergei Lavrov. |
General Licence– Wind Down of Positions Involving VTB [EXPIRED] | [THIS GENERAL LICENCE HAS NOW EXPIRED]
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24 February 2022 | Asset freeze and travel ban | Five individuals: Kirill Shamalov, Petr Fradkov, Denis Bortnikov, Yury Slyusar and Elena Aleksandrovna Georgieva (described as being part of "Putin’s inner circle"). |
Asset freeze | VTB Bank (one of Russia's largest banks) – see General Licence below. Five Russian defence companies:
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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 | Prohibition on Russian individuals' access to UK banks, including £50,000 limits on bank accounts. | |
22 February 2022 | Asset freeze and travel ban | Three individuals: Gennady Timchenko, Igor Rotenberg and Boris Rotenberg. |
Asset freeze | Five 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. |