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Ukraine Crisis – UK Sanctions Update – ARCHIVE

Mayer Brown
13/05/2022

UPDATE

May 11, 2022

  • Shell Selling Part of Russia Business to Lukoil as Part of Multi-Billion Dollar Exit From Market: British energy giant Shell has announced plans to sell some of its Russian business, primarily retail, to Lukoil on Thursday. The sale will cover 411 retail gas stations and a lubricant blending plant in Torzhok, northwest of Moscow. (https://www.bbc.com/news/business-61424715).  

  • UK Secretary of Defence Says in the Long Run Russia Has “Lost”: The UK Secretary of Defence, Ben Wallace, told reporters that Russia will emerge from the war as a “lesser” power, “especially as sanctions hinder Russia’s ability to import Western technology needed for much of its military equipment.” Wallace reiterated the UK’s policy to ensure that Russia is defeated in the war in Ukraine. (https://www.nbcnews.com/news/world/long-run-putin-lost-uk-defense-secretary-says-rcna28280).

  • Major Donation to the UK’s Conservative Party Flagged Over Russia Concerns: One of the biggest donors to Britain’s Conservative Party is reportedly suspected of secretly funnelling $630,225 to the party from a Russian account. The cash was part of a fund-raising blitz that helped propel Prime Minister Boris Johnson’s party to victory in 2019. (https://www.nytimes.com/2022/05/12/world/europe/russian-money-uk-tories.html).

  • Oligarch Vladmir Potanin is Still Not Sanctionedby UK, EU or US: Vladmir Potanin, a metals tycoon with close ties to the Kremlin, has not been hit with sanctions by the UK, EU or US. Norilsk Nickel, the Siberian miner that makes up the bulk of his $33.6bn fortune produces 15% of the world’s high-grade nickel used in batteries and 40% of its palladium. Hitting the company with sanctions could make the markets for both metals collapse. Potanin has, however, been sanctioned by Canada and Australia. (https://www.ft.com/content/50a48889-189f-4994-a5c6-8e725e9dfe57).

UPDATE

May 11, 2022

UPDATE

May 10, 2022

  • New Economic Crime Bill Announced in the Queen’s Speech: On May 10, 2022, in the Queen’s Speech (which was delivered by HRH The Prince of Wales) it was announced that a new economic crime bill will be brought forward by the UK Government to further strengthen powers to tackle illicit finance and reduce economic crime. The new bill is expected to further strengthen the effectiveness of sanctions by increasing visibility into corporate ownership.  (https://www.gov.uk/government/speeches/queens-speech-2022).

  • UK Government Holds Russia Responsible for February 24 Viasat Cyber Attack: On May 10, 2022, the UK, EU, US and allies announced that Russia is responsible for a series of cyber-attacks since the renewed of Ukraine. This included a cyber-attack against Viasat on February 24, appropriately one house before Russia laundered its major invasion of Ukraine.  Foreign Secretary, Liz Truss, said the UK “will continue to call out Russia’s malign behaviour and unprovoked aggression across land, sea and cyberspace, and ensure it faces severe consequences.” (https://www.gov.uk/government/news/russia-behind-cyber-attack-with-europe-wide-impact-an-hour-before-ukraine-invasion).

UPDATE

May 09, 2022

  • UK to Target £1.7 Billion of Russian and Belarussian Goods in New Round of Sanctions: The UK has announced import tariffs on Russia and Belarussian goods worth £1.4 billion, including precious metals such as platinum and palladium.  The UK will also impose export bans worth more than £250 million target Russia’s manufacturing and heavy machinery sectors, including key materials such as chemicals, plastics, rubber, and machinery. (https://www.gov.uk/government/news/uk-punishes-putin-with-new-round-of-sanctions-on-17-billion-of-goods).

  • Tax Loophole Impeding Sanctions: Efforts to stop sanctioned Russian money flowing into the UK are being hampered by a tax loophole that allows individuals to withhold details of their assets or income from authorities. The loophole allows individuals to not submit a tax return if they claim non-domiciled status and have no UK income.(https://www.independent.co.uk/politics/ghost-dom-tax-sanctions-russia-b2074680.html).

UPDATE

May 08, 2022

UPDATE

May 06, 2022

UPDATE

May 05, 2022

  • OFSI Issues General Licence relating to Evraz PLC:  Under the new General Licence (INT/2022/1710676), a person may continue business operations involving the North American Subsidiaries of Evraz in relation to, amongst other things, payments under any obligations or contracts; payments to or from any third party under any obligations or contracts; and receipt of payments for audit services. Evraz North America plc is also permitted to pay for the audit services referred to in the previous sentence. The General Licence expires on September 2, 2022.  (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1073553/GL_INT20221710676_Evraz.pdf)

UPDATE

May 04, 2022

  • UK Cuts Off Service Exports to Russia: The UK’s Foreign Secretary Liz Truss announced a ban on services exports. The new measures will mean Russia’s businesses can no longer benefit from the UK’s world class accountancy, management consultancy, and PR services, which account for 10 percent of Russian imports in these sectors. This includes the so-called Big Four accounting and consultancy firms – Deloitte, EY, KPMG and PwC.  Law firms will still be able to service Russian clients. (https://www.gov.uk/government/news/russia-cut-off-from-uk-services)

  • 63 Entries Added to the UK Sanctions List Targeting Media Organisations: On May 4, 2022, OFSI added an additional 63 entities and individuals to the UK Sanctions List. Many of these entries are actors and organisations from mainstream media organisations, including Evgeny Poddubny, a war correspondent for the All-Russia State Television and Radio Broadcasting Company; Alexander Kots, a war correspondent for Russian newspaper Komsomolskaya Pravda; All Russia State Television and Radio Broadcasting, a major state-owned broadcaster; and InfoRos, a news agency alleged to have links to Russian intelligence agencies. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1073146/Notice_Russia_040522_1.pdf)

UPDATE

May 03, 2022

  • Prime Minster Boris Johnson Claims West “Too Slow” to Impose Sanctions in Speech to Ukrainian Parliament: On Tuesday, UK Prime Minister Boris Johnson addressed the Ukrainianparliament via video, the first world leader to do so since the start of the invasion. The Prime Minister said that Ukraine’s allies “cannot make the same mistake” they did when Russia invaded Crimea, adding that the West had been “too slow to grasp what was really happening” and “failed” to collectively impose sanctions against Vladimir Putin. He used the address to highlight a 300 million pound military assistance package the UK was sending to Ukraine. (https://www.bbc.com/news/uk-61297478).

UPDATE

May 02, 2022

  • Pelagic Trawler in UK Calls for Action Over Russian Factory Ships: The Altaire, a local pelagic trawler in the UK, is urging the UK Government to act over Russian factory ships fishing for blue whiting in UK waters around 100 miles off the coast. This is the latest attempt by the industry to get the government to close a loophole that enables Russian vessels to fish inside UK waters. (https://www.shetnews.co.uk/2022/05/02/boris-wheres-your-russian-sanctions-asks-altaire-skipper/).

  • UK Anti-Corruption Sanctions Regime Accused of Failures: A report by the UK Anti-Corruption Coalition found the effectiveness of UK anti-corruption sanctions had been “undermined by a lack of designations [against individuals and companies] . . . insufficient co-ordination and information sharing [between countries] . . . and limitations in enforcement and implementation”. (https://www.ft.com/content/d598b3b2-ad4b-43de-80b9-38ecfde31bbf).

UPDATE

May 01, 2022

  • UK Financial Conduct Authority Considers Side-Pockets for Ukraine-Impacted Funds: The UK Financial Conduct Authority (“FCA”) has asked for industry feedback on its proposals to create “side pockets” in funds, which would allow fund managers to separate Russian and Belarusian assets from the funds’ other core investments. This would stop funds with exposure to Russia and Belarus from being suspended.  (https://www.ftadviser.com/fca/2022/04/28/fca-consults-on-side-pockets-for-ukraine-impacted-funds/).

  • Kazakhstan Summons UK Ambassador Over Lawmaker’s Call For Sanctions: After a UK Member of Parliament (MP), Margaret Hodge, asked British Foreign Secretary Liz Truss if sanctions could be imposed on Kazakhstan and Azerbaijan for their so-called support of Putin and his policies, Kazakhstan’s Foreign Ministry has summoned the British ambassador to Kazakhstan for an explanation. (https://www.rferl.org/a/kazakhstan-uk-sanctions-russia/31732834.html)

UPDATE

April 29, 2022

  • UK’s Internet-Related Russia Sanctions Come Into Force: The UK’s trade sanctions on Russia related to internet based products come into force on April 29, 2022. They introduce new trade sanctions that require social media platforms, internet access services and application stores to take steps to prevent UK-based users from coming into contact with a designated persons/entities. (https://www.europeansanctions.com/2022/04/uk-introduces-internet-related-russia-trade-sanctions)

  • UK MP Responds to Russia Sanctioning 287 British Members of Parliament (MPs):  In a letter to His Excellency Ambassador Andrei Kelin, UK MP, Justin Madders, responded to Russia after 287 British MPs were sanctioned. Madders requested evidence to support Russian assertions, as well as formal written confirmation of the process, terms and duration of the sanctions reported to have been imposed on himself. (https://www.chesterstandard.co.uk/news/20103840.justin-madders-mp-responds-russian-ban-uk-politicians)

UPDATE

April 28, 2022

UPDATE

April 27, 2022

  • OFSI Issues New General Licence Relating to Law Enforcement and Regulatory Authorities Asset Recovery: On April 27, 2022, the UK OFSI issued a new general licence (General Licence INT/2022/1679676). This licence permits an officer of a Non-Crown Relevant Organisation to carry out their duties in relation to sanctioned individuals and entities for Asset Recovery Purposes. This includes giving effect to a negotiated settlement, to which a sanctioned individual is party and approving a deferred prosecution agreement. The licence is of indefinite duration. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1071873/GL_INT20221679676_notice.pdf).

UPDATE

April 26, 2022

  • UK Introduces New Trade Measures to Support Ukraine: On April 25, 2022, the UK announced that it will cut tariffs on all goods from Ukraine to zero and will remove all quotas under the free trade agreement. The UK will also introduce a new export ban on products and technology that Russia could use in its war, which could possibly include interception and monitoring equipment. (https://www.gov.uk/government/news/uk-announces-new-trade-measures-to-support-ukraine).

  • UK and US Ready to Increase Economic Pressure on Russia: In a joint statement on April 26, 2022, the UK Secretary of State for International Trade, Anne-Marie Trevelyan, and US Trade Representative Ambassador, Katherine Tai, announced that they are prepared to increase the economic pressure on Russia to bring an end to the war. They also pledged to “encourage other international partners, including the G7 and other WTO Members, to take action in support of Ukraine’s economic recovery”. (https://www.gov.uk/government/news/joint-statement-on-uk-us-dialogue-on-future-of-atlantic-trade-in-aberdeen).

UPDATE

April 25, 2022

  • Commons Treasury Committee Told Sanctions Have “Profound” Effect on London Insurers: At a committee meeting on April 25, 2022, the Commons Treasury Committee heard from insurance, economic and finance experts on how Russia’s economy but also London’s insurance sector have been impacted by UK Sanctions. “The impact on Russia — difficult to say: the impact on the U.K. insurance market — profound.” (https://www.law360.com/articles/1486814/russia-sanctions-effect-on-uk-insurers-profound-mps-told).

UPDATE

April 22, 2022

  • OFSI Amends General License Relating to Certain Russian Banks: On April 22, 2022, OFSI amended general license INT/2022/1280876 relating to certain basic needs, routine holding and maintenance, and the payment of legal fees and insolvency related payments to include Sberbank CIB (UK) Ltd.  Under the general license, VTB Capital plc, Sberbank CIB (UK) Ltd and their UK-incorporated owned or controlled subsidiaries caninter alia pay their basic needs expenses, pay reasonable fees or services charges relating to routine holding and maintenance and make payment of reasonable professional fees for the provision of legal services. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070607/INT.2022.1280876_GL.pdf).

  • House of Commons Publishes Research Briefing on Russian Energy Imports: On April 22, 2022, the UK Parliament published a research briefing on energy imports from Russia. Among other things, the briefing found that imports of Russian gas made up 4% of UK supply in 2021. Oil and coal were higher at 9% and 22%. (https://commonslibrary.parliament.uk/research-briefings/cbp-9523/).

UPDATE

April 21, 2022

  • UK Announces Further Import Sanctions Against Russia: The UK has expanded the list of products facing import bans and increasing tariffs. From April 21, 2022, the import bans now include bans on silver, wood products and high-end products from Russia including caviar. The UK has also increased tariffs by 35% on around £130m worth of products from Russia and Belarus, including diamonds and rubber. (https://www.gov.uk/government/news/uk-announces-further-import-sanctions-against-russia).

  • OFSI Adds 26 New Entries to the UK Sanctions List: On April 21, 2022, OFSI added 26 new entries to the UK Sanctions list in response to the Russian invasion of Ukraine. The new entries largely target members of the Russian Military including Lt Col Azatbek Omurbekov, known as the Butcher of Bucha; Colonel General Andrey Serdyukov, the commander of Airborne Forces; and, Major General Valery Flyustikov, Commander of Special Operations Forces. The sanctions also include companies that supply the Russian military, such as JSC Kalashnikov Concern, a Russian developer and manufacturer of army Russian equipment; GTLK, Russia’s largest leasing company which operates in different types of transport and special equipment for Russian companies in the transport industry; and, JSC ARZ MACHINEBUILDING PLANT, part of a Military Industrial Company which manufactures the BTR-80 amphibious armoured personnel carriers. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070063/Notice_Russia_210422.pdf).

  • OFSI Amends General License Relating to Certain Russian Banks: On April 21, 2022, OFSI amended general license INT/2022/1424276 relating to Alfa Bank JSC, Gazprombank, Rosselkhozbank, SMP Bank and the Ural Bank for Reconstruction and Development.  In particular, OFSI made the following clarification: “Regarding whether funds owed by the DPs ought to be placed into a blocked account, General Licence INT/2022/1424276 does not contain a requirement that funds becoming payable to the DPs as a necessary part of a person winding down any transactions they have with the DPs be paid into a frozen account. With regard to funds becoming payable to any subsidiary of the DPs as a necessary part of a person winding down any transactions they have with those subsidiaries needing to be paid into a frozen account, OFSI does not provide legal advice but without prejudice to that we suggest you consider how the ownership and control provisions in the Russia Regulations could apply to such payment.”  The general license expires on April 23, 2022. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070502/GL_INT20221424276_notice.pdf).

  • Boris Johnson Will Not Pressure India on Sanctions During Visit: Speaking to reports during a two-day visit to India, UK Prime Minister Boris Johnson confirmed that he raised the issue of sanctions on Russia and Ukraine during his visit, but he stated, “India and Russia have historically had a very different relationship than Russia and the UK have had over the last couple of decades. We have to reflect that reality.” He also praised Indian Prime Minister Narendra Modi’s statements condemning atrocities in Bucha, Ukraine. (https://www.cnn.com/europe/live-news/ukraine-russia-putin-news-04-21-22/h_aa235eaafdc170ab7935a62784ce3127).

UPDATE

April 20, 2022

  • Wimbledon Bans Russian and Belarusian Players: On Wednesday, the All England Lawn Tennis Club announced that it would ban Russian Belarusian tennis players from this year’s Wimbledon tournament in response to the invasion of Ukraine. The Club stated that its goal was to “limit Russia’s global influence through the strongest means possible.” The announcement means that the world’s second-ranked tennis player Daniil Medvedev cannot participate in the tournament, along with 11 other Russian and Belarusian players in the top 30 men’s and top 40 women’s tennis players worldwide. (https://www.cnn.com/2022/04/20/tennis/kremlin-wimbledon-russian-players-ban-spt-intl/index.html).

UPDATE

April 19, 2022

  •  UK to Revoke Moscow Stock Exchange’s Recognized Status: On April 19, 2022, the UK’s HM Revenue & Customs announced its intention to revoke the Moscow Stock Exchange’s (“MOEX”)  status as a recognized stock exchange. This means investors will not be able to access certain UK tax benefits in future when trading securities on MOEX, although existing investments will be protected. (https://www.gov.uk/government/news/uk-to-revoke-moscow-stock-exchanges-recognised-status).

UPDATE

April 18, 2022

  •  Sanctioned Russian Oligarchs Linked to £800m Worth of UK Property: An investigation carried out by the BBC has shown that a dozen sanctioned Russians are linked to an estimated £800m worth of property in the UK. This includes the £230 million property empire of Roman Abramovich. (https://www.bbc.co.uk/news/world-europe-61080536).

  • Prime Minister, President Zelenskyy Discuss Security Assistance and Sanctions: On Saturday, UK Prime Minister Boris Johnson and Ukrainian President Volodymyr Zelenskyy held a phone call. The two discussed security assistance to Ukraine, and the Prime Minister “updated President Zelenskyy on new sanctions from the UK that came into force last week, and said the UK would continue to provide the means for Ukraine to defend itself.” (https://www.gov.uk/government/news/pm-call-with-president-zelenskyy-of-ukraine-16-april-2022).

UPDATE

April 15, 2022

UPDATE

April 14, 2022

  • UK Introduces New Sanctions on Luxury Goods, and Iron and Steel Products: The UK Parliament adopted new rules on April 14, 2022, prohibiting:

    o   the export of luxury goods to, or for use in, Russia. A person must not directly or indirectly—

    –  supply or deliver luxury goods from a third country to a place in Russia;

    –  make luxury goods available to a person connected with Russia;

    –  make luxury goods available for use in Russia.

    o   the import of iron and steel products which are consigned from Russia;

    o   the import of iron and steel products which originate in Russia.

    o   the direct or indirect acquisition of iron and steel products –

    –  which originate in Russia;

    –  which are located in Russia (https://www.legislation.gov.uk/uksi/2022/452/contents/made).

  • London-Listed Petropavlovsk Plc Considering Sale of Business: Russian gold producer, Petropavlovsk Plc, which is listed on the London Stock Exchange, said on April 14, 2022, that it was considering the sale of the business, as Russian sanctions have left the group struggling to refinance its debt. 

    (https://www.ft.com/content/bc61a669-09ca-4b6c-b614-5b4df61fc65a).

UPDATE

April 13, 2022

UPDATE

April 12, 2022

  • UK, US Agree to “Ratchet Up” Sanctions on Russia: In a Tuesday call, US President Joe Biden and UK Prime Minister Boris Johnson discussed the conflict in Ukraine. Regarding sanctions, “the pair agreed to continue joint efforts to ratchet up the economic pressure on Putin and decisively end Western reliance on Russian oil and gas.” (https://www.gov.uk/government/news/pm-call-with-president-biden-12-april-2022).

UPDATE

April 11, 2022

UPDATE

April 9, 2022

UPDATE

April 8, 2022

  • Sanctioned Russian Billionaires Look to Sell Two UK Fintechs:  FIBR Tech Ltd., an online lender to businesses, and ANNA Money, which offers business accounts and administrative services, began searches for buyers in recent weeks after indirect shareholders including Mikhail Fridman and Petr Aven were hit by sanctions. They are exploring sale options after sanctions on their Russian billionaire backers have left them struggling to find funding. (https://www.bloomberg.com/news/articles/2022-04-08/sanctioned-russian-billionaires-look-to-exit-two-u-k-fintechs).

UPDATE

April 7, 2022

UPDATE

April 6, 2022

  • UK Aims to End All Dependency on Russian Coal and Oil by End of 2022 and Will ban Export of Oil Refining Equipment by Next Week: On April 6, 2022, Liz Truss promised that, 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, degrading Russia’s ability to produce and export oil. (https://www.gov.uk/government/news/uk-imposes-sweeping-new-sanctions-to-starve-putins-war-machine).

  • UK Arm of Russian Bank VTB Prepares to Enter Administration: A UK High Court decision on April 6, 2022, declared that the British unit of Russian bank VTB will be placed in administration in the coming days, subject to a licence being granted to do so by United States sanctions authorities. The decision comes after VTB Capital plc was unable to operate and pay its debts due to sanctions imposed on the bank. (https://www.reuters.com/business/finance/vtbs-uk-arm-poised-enter-administration-2022-04-06/).

UPDATE

April 5, 2022

UPDATE

April 4, 2022

  • Abramovich-Linked Yacht Leaves Turkish Port Run by UK-Listed Group: A yacht reportedly owned by sanctioned individual, Roman Abramovich has left a port in Turkey after the port operator, Global Ports Holding, was at risk of violating UK sanctions. Global Ports Holding, which is listed on the London Stock Exchange would not take berthing fees from the vessel in an attempt to protect itself from the accusation of accepting funds from an individual or entity under sanctions. (https://www.ft.com/content/a9589574-49e4-4654-bf45-f53d090a7024).

  • Russian Lender, VTB, Unable to Pay London Rent: Russia’s second-largest lender, VTB, has been blocked from making rent payments for its City of London offices. The banking system will not allow money to move from a Russian bank to a British bank without a licence, leaving the rent unpaid until the licence is processed. (https://www.ft.com/content/fa8e858c-5a9d-498d-8ab6-b27c36712dfa).

UPDATE

April 3, 2022

  • UK Receives Diesel Delivery From Russia: On April 2, 2022, a tanker carrying 33,000 tons of Russian diesel delivered its cargo in Essex. The delivery did not fall foul of UK sanctions, but highlights the UK’s dependence on Russian diesel. Russia supplies nearly a fifth of the UK’s diesel, despite pledges from the UK to stop importing Russian hydrocarbons by the end of the year (https://www.bbc.co.uk/news/business-60948439).

UPDATE

April 2, 2022

  • UK-listed Evraz Abandons Coal Assets Demerger After Russia Sanctions: Russian steelmaker Evraz, whose biggest shareholder is sanctioned billionaire Roman Abramovich, on Friday, April 1, scrapped plans to separate its coal assets, citing sanctions on Moscow following its invasion of Ukraine.  The London-listed company said the sanctions made it “technically impossible” to execute the demerger it proposed early last year to concentrate on its core steel business. (https://www.rappler.com/business/uk-listed-evraz-abandons-coal-assets-demerger-after-russia-sanctions/).

  • UK Sanctions on Gazprombank Impact Shell Transactions: In a statement to reporters on April 2, Kremlin Spokesman Dmitry Peskov stated that the UK’s sanctions on Gazprombank are hindering Shell’s ability to buy energy products from Russia. Russia has designated Gazprombank as a bank where customers from “unfriendly countries” can set up accounts to exchange non-ruble currencies to rubles for energy transactions; UK sanctions would block customers from creating such accounts, according to Peskov’s allegations. (https://tass.com/economy/1431389).

UPDATE

April 1, 2022

  • UK Issues General License Authorizing Certain Payments by the Central Bank of Russia, the National Wealth Fund, and the Ministry of Finance: On April 1, 2022, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a new general license (INT/2022/1495176) that authorizes the provision of financial services relating to 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 March 1, 2022.  The general license expires on June 30, 2022. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1065790/INT.2022.1495176.pdf).

  • Sberbank’s UK Arm Faces Collapse Amid Russia Sanctions: The UK arm of Russia’s biggest lender Sberbank of Russia PJSC is facing collapse, becoming London’s highest profile financial casualty in the aftermath of the invasion of Ukraine. According to reports, the directors of Sberbank CIB U.K. Ltd. are applying for special administration, a form of insolvency that means the administrator ensures there’s minimal disruption to financial markets as a result of a firm’s collapse. (https://www.aljazeera.com/economy/2022/4/1/sberbanks-uk-arm-faces-collapse-amid-russia-sanctions).

UPDATE

March 31, 2022

UPDATE

March 30, 2022

  • UK Department for International Trade Issues Notice to Importers Prohibiting Russian Imports: Notice to Importers 2953 was issued on March 30, 2022, by the Department for International Trade. The notice provides an overview of the import prohibitions in force on certain goods imported into the UK that have originated in or have been consigned from the Russian Federation and non-government controlled Ukrainian territory. The notice also sets out the licensing process for traders looking to import goods subject to prohibitions.

    (https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/nti-2953-russia-import-sanctions).

  • UK Prime Minister Boris Johnson Calls for Tougher Sanctions on Russia Until it Withdraws All Troops From Ukraine: At a hearing in the UK Parliament on March 30, 2022, the UK Prime Minister told lawmakers that to lift G7 sanctions in return for a Russian ceasefire in Ukraine would go “straight into (Vladimir) Putin’s playbook“. Boris Johnson called for a tightening of sanctions until all Russian troops have been withdrawn from Ukraine. 

    (https://www.france24.com/en/live-news/20220330-russia-sanctions-should-increase-until-full-ukraine-withdrawal-uk) .

  • Holland & Barrett Payment Held Up by HSBC Over Sanction Concerns: Russian-backed owners of UK healthcare company Holland & Barrett made a crucial interest payment on a €415mn loan last week. HSBC has held up the payment due to concerns about links between the UK company and sanctioned Russian oligarchs. (https://www.ft.com/content/686b7816-5046-446a-92fb-a600c5ac11c7).

UPDATE

March 29, 2022

  • Russian-owned Superyacht Detained in London under Russia Sanctions: The UK government announced on March 29, 2022, it has ordered its first detention of a superyacht in UK waters. The £38m vessel is owned by an unnamed Russian businessman, the ownership of which ministers said is “deliberately well hidden.” The UK Department for Transport would not comment on why it was not naming the individual who owns the yacht, however the Transport Secretary Grant Shapps said the individual was not currently sanctioned but had “close connections” to Russian President Vladimir Putin. (https://www.bbc.co.uk/news/business-60912754).

  • National Cybersecurity Centre Warns Against Russian Products in Supply Chain: In a blog post on March 29, 2022, the National Cybersecurity Centre urged British companies to reconsider the use of Russian IT technology in their supply chains, saying that supplying the UK with critical infrastructure technology would be considered a “win” for the Russian state. The Centre also stated that it did not expect large-scale cyberattacks on UK networks. (https://www.ncsc.gov.uk/blog-post/use-of-russian-technology-products-services-following-invasion-ukraine).

UPDATE

March 28, 2022

  • London-listed Polymetal Considers Splitting Off Russian Business:  Polymetal is considering splitting its Russian business from the rest of the company in an attempt by the London-listed gold and silver miner to insulate its international business from the knock-on effects of western sanctions. Any such move would provide a strategy for other London-listed Russia-linked groups whose stock has tumbled as investors look to get out of companies that could fall foul of UK, US, or EU sanctions, or be hit by western economic and financial restrictions. (https://www.ft.com/content/9fc2c1b9-8393-444f-a673-1c24901c9986).

UPDATE

March 27, 2022

UPDATE

March 26, 2022

  • UK Says Russian Sanctions Could be Lifted with Ukraine Withdrawal: On March 26, 2022, UK Foreign Minister Liz Truss said that sanctions imposed on Russian individuals and companies could be lifted if Russia withdraws from Ukraine and commits to end aggression. Truss said, “there needs to be hard levers. Of course, sanctions are a hard lever… Those sanctions should only come off with a full ceasefire and withdrawal, but also commitments that there will be no further aggression. And also, there’s the opportunity to have snapback sanctions if there is further aggression in future. That is a real lever that I think can be used.” (https://www.reuters.com/world/uk/uk-says-russian-sanctions-could-be-lifted-with-ukraine-withdrawal-report-2022-03-26/).

UPDATE

March 25, 2022

  • Russian-focused Gold Producer Petropavlovsk Blocked from Loan Payment: The London-listed gold miner Petropavlovsk, which mines gold in Russia’s far east and has its headquarters in Moscow, said it was prohibited from making a $560,000 interest payment due on March 25, 2022, after the UK froze the assets of its main lender Gazprombank (https://www.ft.com/content/6612673b-3c08-4e03-9fdd-7cd07d5e0772).

UPDATE

March 24, 2022

  • UK Imposes 65 Further Sanctions Designations:  On March 24, 2022, UK Foreign Secretary Liz Truss announced 65 new sanctions, targeting strategic industries, banks and business elites. The 26 companies targeted include Russian Railways and defense company Kronshtadt, the organization Russian mercenaries reportedly tasked with assassinating President Zelenskyy, the Wagner Group, six more banks (including Alfa Bank and Gazprombank) and Alrosa, the world’s largest diamond producer. The 33 individuals targeted include the billionaire oil tycoon Eugene Shvidler, founder of Tinkoff bank, Oleg Tinkov, the CEO of Sberbank, Herman Gref, and Foreign Minister Lavrov’s step daughter, Polina Kovaleva.

    https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1062892/Notice_Russia_240322.pdf

  • OFSI Amends General Licence Relating to Provision of Financial Services: On March 24, 2022, OFSI amended General Licence INT/2022/1381276. The amendment clarifies that: “Under General Licence INT/2022/1381276 a Person may provide financial services for the purposes of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 1 March 2022 with the CBR, the NWF or the MF or those persons set out in regulation 18A d to e of the Russia Regulations. A Person or Relevant Institution can carry out any activity reasonably necessary to effect this.

    (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1063230/GENERAL__LICENCE_276.pdf).

  • Financial Conduct Authority (FCA) Issues Notice to Regulated Firms with Cryptoasset Exposure: On March 24, 2022, the FCA released guidance stating that, in addition to steps taken to identify customers and monitor transactions under the Money Laundering Regulations 2017, the financial sector, including the cryptoasset sector, must have in place appropriate systems and controls and must not interact with companies listed on the FCA’s Unregistered Cryptoasset Businesses page. (https://www.fca.org.uk/news/statements/notice-regulated-firms-exposure-cryptoassets).

  • UK Prime Minister Says Russia is Attempting to Circumvent Sanctions on its Gold: Following a summit of NATO and G7, the UK Prime Minister made a statement saying “On gold reserves, there is evidence that the Russians may be trying to get . . . around the sanctions on their gold.” The statement comes after agreements earlier in the day between the G7 countries to crack down on Russia’s ability to sell its gold. (https://www.ft.com/content/9a3bdc8c-0bfe-494d-a6c3-71fa5a4250d6).

UPDATE

March 23, 2022

  • UK Prime Minister makes promises to Ukrainian President: On March 23, 2022, UK Prime Minister Boris Johnson spoke with Ukrainian President, Volodymyr Zelenskyy and promised to use the G7 and NATO meetings on March 24, 2022 to increase the pressure on Vladimir Putin’s regime and work with partners to substantively increase defensive lethal aid to Ukraine. The Prime Minister also confirmed he aims to ensure President Zelenskyy is in the strongest possible position in ongoing peace talks (https://www.gov.uk/government/news/pm-call-with-president-zelenskyy-23-march-2022).

  • UK Minister Holds Discussions on Tackling Loopholes in British Virgin Islands: A UKForeign Office representative, Amanda Milling, is holding discussions in the British Virgin Islands on how sanctions against Russian oligarchs with cash stored there can be implemented. UK sanctions laws apply in the overseas territories, and enforcement officers are supposed to have full access to registers of beneficial ownerships. However, UK tax havens may provide a loophole for those trying to escape the international clampdown (https://www.theguardian.com/world/2022/mar/23/uk-minister-in-bvi-for-urgent-talks-on-sanctioning-russian-oligarchs).

UPDATE

March 22, 2022

  • OFSI Updates Ownership and Control Guidance: OFSI has updated Chapter 4 of its guidance on financial sanctions in relation to ownership and control to update the rules on aggregation. The new paragraph (4.14) clarifies OFSI’s position on aggregation and states:  “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.”(https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1062452/General_Guidance_-_UK_Financial_Sanctions.pdf)

  • UK Issues Wind Down General Licence for Services to Three Russian financial institutions purposes: On March 22, 2022, OFSI issued a new General Licence (INT/2022/1381276) allowing the provision of financial services to the following entities for the purpose of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to March 1, 2022 with (i) the Central Bank of the Russian Federation; (ii) the National Wealth Fund of the Russian Federation; and (iii) the Ministry of Finance of the Russian Federation.  The general licence expires on May 2, 2022 (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1062349/GENERAL_LICENCE_.pdf).

  • London-listed Steelmaker Says Bond Payment Blocked over Russia Sanctions: On March 21, 2022,Evraz plc, the Russian steelmaker whose biggest shareholder is Roman Abramovich, said a bond coupon payment of nearly $19 million had not been received by its principal paying agent. It believes the block is related to the UK sanctions against Abramovich. Evraz warned that its inability to pay the coupon on a $700mn bond that matures in March 2023 could push it to default on its debt (https://www.ft.com/content/00b8e832-4a08-4f6e-9644-46b00f7e8b1d).

  • Oligarch Says He Ditched Mansions Before Sanctions: Russian billionaire and UK asset freeze target, Alisher Usmanov, says he no longer owns many former properties, potentially putting them beyond the reach of the law.  This raises questions over the effectiveness of sanctions imposed since the invasion of Ukraine began (https://www.bbc.co.uk/news/business-60825983).

  • UK Government Webinar Recording: On March 17, 2022, the UK government held a webinar briefing on UK sanctions relating to Russia. A recording of the webinar have been made available athttps://www.youtube.com/watch?v=zbzqX4lo3NE.

UPDATE

March 21, 2022

  • UK Government Mulls Taking Over UK Arm of Gazprom: The UK government is reportedly preparing to step in and temporarily run Russian gas giant Gazprom’s UK arm, Gazprom Marketing & Trading Retail Ltd, which supplies thousands of organizations across the UK. The company could be placed into administration in the coming days (https://www.bbc.co.uk/news/business-60825804). 

UPDATE

March 20, 2022

UPDATE

March 19, 2022

  • UK Grounds Plane with Possible Russian Links: On March 19, 2022, the UK Secretary of State for Transport confirmed a Luxembourg registered aircraft has been impounded by the UK as authorities investigate its “possible Russian links” (https://www.bbc.co.uk/news/uk-60808690).

UPDATE

March 18, 2022

UPDATE

March 17, 2022

UPDATE

March 16, 2022

UPDATE

March 15, 2022

  • UK Announces New Sanctions Against Russia: On March 15, 2022, the UK Government announced a ban on exports to Russia of high-end luxury goods, while also hitting hundreds of key products with new import tariffs.  The UK said that it will (i) deny Russia and Belarus access to “Most Favoured Nation” tariff for hundreds of their exports, depriving both nations key benefits of WTO membership, (ii) impose an additional 35% tariff on a list of goods worth £900 million (including vodka), and (iii) ban the exports of luxury goods to Russia (https://www.gov.uk/government/news/uk-announces-new-economic-sanctions-against-russia).

UPDATE

March 14, 2022

  • UK Expected to Expand the Russia Sanctions List as Economic Crime Bill is Fast-Tracked: The Economic Crime Bill (the “Bill”) is expected to pass late on March 14, 2022. The Bill will reform Companies House in an attempt to verify the identity of every company director and beneficial owner, with the aim of preventing criminals or kleptocrats from hiding behind UK shell companies. Following passage of the Bill, the UK Foreign Secretary is expected to name hundreds of oligarchs, individuals and organizations to be added to the UK’s sanctions list on March 15, 2022 (https://www.theguardian.com/world/2022/mar/14/uk-to-expand-russia-sanctions-list-fast-tracked-bill) .

UPDATE

March 13, 2022

  • Financial Conduct Authority Asks UK banks to Provide Information on Sanctioned Russian Oligarchs:The UK financial regulator has asked UK banks to share information on how individuals and businesses subject to sanctions move their money around the world. Any banks that withhold information on matters, including attempts to avoid sanctions, will be judged as not having the “open and transparent relationship” they are required to have with their regulators (https://www.ft.com/content/8ee01734-f392-401f-908b-555fce71fb39).

  • Grants for UK-Russian Research Projects Suspended: UK Research and Innovation, the UK’s main public funding agency for research at UK universities, has suspended grant payments to projects involving scientists in Russia. This will affect almost 50 grants for projects at UK universities(https://www.ft.com/content/e60b3ab1-63f8-48b8-8677-c92400562f7c).

UPDATE

March 12, 2022

  • G7 Commit to Taking Further Measures as Soon as Possible:  On March 11, 2022, the joint leaders of the G7 released a statement on the Ukraine committing to inter alia taking action that will deny Russia Most-Favoured-Nation status relating to key products and preventing Russia from obtaining financing from the leading multilateral financial institutions such as the IMF and the World Bank (https://www.gov.uk/government/news/g7-leaders-statement-on-ukraine-11-march-2022).

UPDATE

March 11, 2022

  • UK Financial Regulators Issue Joint Statement on Cryptoassets: On March 11, 2022, the UK’s financial regulatory authorities have published a joint statement on sanctions and the cryptoasset sector emphasizing that financial sanctions regulations do not differentiate between cryptoassets and other forms of assets and  reminding authorized financial institutions of their responsibilities to comply with UK sanctions (https://www.fca.org.uk/news/statements/uk-financial-regulatory-authorities-sanctions-cryptoasset-sector).

  • UK Sanctions Authority Publishes overview of Recent Amendments to Russia Sanctions Regime:The Office of Financial Sanctions Implementation has published a blog entitled “Russia: What has changed and what do I need to do?”, which provides an overview of recent amendments to its Russia sanctions regime and highlights points of contact, including for licencing and reporting purposes (https://ofsi.blog.gov.uk/2022/03/10/russia-what-has-changed-and-what-do-i-need-to-do/).

  • Eight Russia-linked Aircraft Stripped of Isle of Man Registration: Following the UK ban on Russia aircraft on 10 March 2022, eight aircraft have with Russia connections removed from the Isle of Man’s Aircraft Registry as part of an ongoing review of the Isle of Man’s ship and air registries (https://www.bbc.co.uk/news/world-europe-isle-of-man-60707290).

UPDATE

March 10, 2022

UPDATE

March 09, 2022

  • UK “Fully Intends” to End Dependency on Russian Hydrocarbons: In a statement, the UK Secretary of State for Business, Energy and Industrial Strategy stated that the UK “fully intend[s]… [to] end our dependency on all Russian hydrocarbons” and reaffirmed that UK Government’s intention to set out an energy strategy to explain the UK’s long-term plans for greater energy security (https://www.gov.uk/government/speeches/statement-on-the-phasing-out-of-russian-oil-imports).

UPDATE

March 08, 2022

  • UK to Phase Out Russian Oil Imports by End of 2022: The UK government has announced plans to phase out Russian oil imports by the end of 2022. Prime Minister Boris Johnson said: “the UK will move away from dependence on Russian oil throughout this year, building on our severe package of international economic sanctions.”  The UK government is expected to set out an energy strategy that sets out the UK’s long term plans for greater energy security, including in relation to both renewable and domestic oil and gas supplies (https://www.gov.uk/government/news/uk-to-phase-out-russian-oil-imports).

  • UK Implements Further Sanctions: On March 8, 2022, the UK passed The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022, which implement certain further sanctions (https://www.legislation.gov.uk/uksi/2022/241/made).  In particular:

    o   Russia aircraft are now prohibited from entering UK airspace or landing in the UK;

    o   Insurance and reinsurance services relating to aviation and space goods or technology to a person connected with Russia or for use in Russia are now prohibited;

    o   Export control restrictions have been expanded to expressly include “aviation and space” goods and technology within the definitions of restricted goods and restricted technology;

  • UK Economic Crime Bill Passes Through House of Commons: The Economic Crime Bill will now go to the House of Lords and is expected to become law later this month. The government says the Bill will prohibit wealthy Russians using the City of London for money laundering. The bill simplifies the process for UK authorities to sanction individuals already punished by allies such as the US and EU (https://www.bbc.co.uk/news/uk-politics-60646119).

  • Shell To Stop Purchasing Russian Crude: On Tuesday, Shell announced that it would immediately stop purchasing Russian crude oil on the spot market and not renew contracts with Russian suppliers. It added that it would reconfigure its supply chain to cut out Russian crude altogether, but warned that completing this process would take time. The move comes after the company announced it would dump its investments in Russia last week. (https://www.cnn.com/2022/03/08/energy/shell-russia-oil-ban/index.html).

UPDATE

March 07, 2022

  • UK Prime Minister Insists Russian Oil Sanctions “On the Table”: UK Prime Minister Boris Johnson has insisted that Russian oil sanctions are “very much on the table” despite his German and Dutch counterparts signaling their discomfort with the idea. Asked about the prospect of banning Russian oil imports to the UK, he said: “Something that perhaps three or four weeks ago we would never have considered is now very much on the table.” (https://www.politico.eu/article/uks-johnson-insists-russian-oil-sanctions-very-much-on-the-table/).
  • UK to Fast Track Economic Crime Bill to Toughen Russia Sanctions: A law designed to harden and speed up sanctions against oligarchs and firms with links to Vladimir Putin is being rushed through the UK Parliament (https://www.bbc.co.uk/news/uk-politics-60646119).

UPDATE

March 06, 2022

  • UK Promises Quicker Sanctions Against Russian Oligarchs: The UK government is to change the law to make it easier to introduce sanctions against Russian oligarchs after criticism the UK is acting too slowly (https://www.bbc.co.uk/news/uk-politics-60624518).

UPDATE

March 04, 2022

UPDATE

March 03, 2022

UPDATE

March 02, 2022

  • UK Ports Refusing to Unload Tankers Carrying Russian Oil and Gas: The UK ban on Russian ships arriving at UK ports does not cover the origin of cargo and therefore does not currently prohibit ships carrying Russian oil and gas from arriving in UK ports.  However, it has been reported that some docks have vowed not to unload tankers carrying Russian oil and gas (https://www.theguardian.com/world/2022/mar/02/pluto-tanker-oil-russia-uk-ban-loophole).

UPDATE

March 01, 2022

On March 1, 2022, the UK published three new statutory instruments implementing a number of the sanctions measures announced in recent days by the Prime Minister and the Foreign Secretary.  OFSI also issued five general licenses that, subject to certain terms and conditions, authorize certain activities that would otherwise be prohibited by UK sanctions.

Sanctions

o A Prohibition on Dealings in Certain Transferable Securities and Money Market Instruments of Certain Russian Persons. A prohibition on dealing with transferable securities and money market instruments issued on or after 1 March 2022 by:

– A UK subsidiary of an entity listed in Schedule 2 (which includes Sberbank (see Notice), VTB Bank, Gazprombank, and VEB), or an entity acting on behalf of or at the direction of such an entity, where the security/instrument has a maturity exceeding 30 days;

– A “person connected with Russia” (subject to certain exceptions) or an entity owned by or acting on behalf or at the direction of a “person connected with Russia”; or

– The Government of Russia (i.e. Russian sovereign debt).

o An Expansion of Prohibitions Relating to Loans or Credit of Certain Russian Persons. A prohibition on issuing loans or credit granted on or after March 1, 2022:

– Where such loan or credit has a maturity exceeding 30 days, to:

– A UK subsidiary of an entity listed in Schedule 2;

– An entity “connected with Russia” or owned or acting on behalf or at the direction of a person “connected with Russia”; or

– To the Government of Russia.

o Correspondent Banking Restrictions. A prohibition on UK credit or financial institutions establishing or continuing a correspondent banking relationship, and from processing sterling payments to, from or via a designated person or a credit or financial institution owned or controlled by them.

  • Prohibition on the Provisions of Financial Services for the Purposes of Foreign Exchange Reserve and Asset Management. The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022 prohibits a UK person from providing financial services for the purpose of foreign exchange reserve and asset management to:

o  the Central Bank of the Russian Federation;

o  the National Wealth Fund of the Russian Federation;

o  the Ministry of Finance of the Russian Federation;

o  a person owned or controlled directly or indirectly by any of the persons above; or

o  a person acting on behalf of or at the direction of any of the persons above.

  • New Asset Freeze Designations, including on RDIF. The UK imposed asset freeze restrictions on five individuals (Kirill Alexandrovich Dmitriev, Andrei Burdyko, Victor Vladimirovich Gulevich, Sergei Simonenko, Andrey Zhuk) and three entities (Russian Direct Investment Fund, JSC 558 Aircraft Repair Plant; JSC Integral).
  • New General Licenses. On March 1, 2021, the UK issued five new General Licenses:

o  General License – INT/2022/1277777 authorises until March 8, 2022 certain dealings with transferable security or money-market instrument otherwise prohibited by the Russia regulations(https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057862/Notice_INT.2022.1277777_.pdf).

o  General Licence – INT/2022/1277778 authorises until March 31, 2022 correspondent banking relationships between UK credit/financial institutions and Sberbank (and connected entities), and the processing of certain sterling payments between these entities (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057864/Notice_INT.2022.1277778_.pdf)

o  General Licence – INT/2022/1277877 authorises until June 24, 2022 the processing of sterling paymentsbetween UK credit/financial institutions and Sberbank (and connected entities) for the purposes of making Relevant Energy Products available for use in the UK(https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057866/Notice_INT.2022.1277877.pdf).

o  General Licence – INT/2022/1280976 authorises until March 1, 2023 relevant financial authorities to do anything with regard to VTB Capital and its UK subsidiaries related to prudential supervision, or protecting, maintaining or enhancing the financial stability of the UK(https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058126/Relevant_authority_GL_01.03.22.pdf)

o  General Licence – INT/2022/1280876 allows until March 1, 2023 VTB Capital and its UK subsidiaries to make payments, including for basic needs, reasonable fees or service charges arising from routine holding and maintenance of its frozen funds and economic resources, and reasonable professional fees for the provision of legal services (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058121/VTB_GL_01.03.22.pdf).

Export controls

Expand Trade Restrictions Relating to Russia.  Expand the scope of the existing ban on the export, supply and delivery, making available and transfer of military goods and technology to and for use in Russia, to include critical-industry goods and technology and dual-use goods and technology, and military goods and technology.  Critical-industry goods and technology include certain electronics, computers, telecommunications equipment and information security, sensors and lasers, marine-related items and aerospace and propulsion-related items.

Extend the Trade Restrictions to Cover Related Activities.  Extend the related prohibition on the provision of technical assistance, financial services, funds and brokering services to these additional categories of goods/technologies.

  • The UK has also:

o Removed Russia as a permitted destination from numerous open general export licences (OGELs) (https://www.gov.uk/government/publications/notice-to-exporters-202203-licence-suspensions-and-ogels-revised/nte-202203-licence-suspensions-and-ogels-revised), and

o Suspended the approval of new export licences for dual-use items to Russia with immediate effect (https://hansard.parliament.uk/Commons/2022-02-28/debates/2202289000005/RussiaSanctions?highlight=russia#contribution-57284ED8-FCCD-44E6-8B7D-8F5F6C8A6F19).

UPDATE

February 28, 2022

Sanctions on Russian Central Bank, National Wealth Fund and Ministry of Finance:  Restrictions that prohibit UK persons from undertaking financial transactions involving the Central Bank of the Russian Federation, the Russian National Wealth Fund, and the Ministry of Finance of the Russian Federation. 

Restrictions against Russian financial institutions: In particular, we note that three more Russian banks were designated as subject to asset freeze restrictions today (see below).

Russian Companies to be Banned from Issuing Transferable Securities and Money Market Instruments: Measures to prevent Russian companies from issuing transferable securities and money market instruments in the UK. This will form a sweeping addition to existing financial restrictions. This is in addition to the prohibition of the Russian state raising sovereign debt in the UK already announced.

Designated Banks Prevents from Accessing Sterling and Clearing Payments Through the UK: A power to prevent designated banks from accessing Sterling and clearing payments through the UK. This will match the power the US already has. Banks subject to this measure will be unable to process any payments through the UK or have access to UK financial markets.

Expanded Export Control Restrictions: A set of measures to strengthen significantly our trade restrictions against Russia. This will include a prohibition against the export of a range of high-end and critical technical equipment and components in sectors including electronics, telecommunications, and aerospace

Extension of Financial and Trade Measures on DNR and LNR: The previously announced extension of financial and trade measures applying to Crimea to the DNR and LNR region.

UPDATE

February 27, 2022

UPDATE

February 26, 2022

  • UK Signs on to US and EU SWIFT, Central Bank, and Passport Restrictions: The UK is listed as one of the countries participating in the joint effort to remove certain Russian banks from SWIFT, sanction the Russian Central Bank, limit passport issuance, and participate in transatlantic sanctions coordination.
  • UK Issues Wind Down License for Positions Involving VTB: The UK has issued a general license stating enabling a person or relevant institution to wind down any transaction to which it is party involving VTB Bank or its UK subsidiary. The license took effect on February 25, 2022 and expires on March 27, 2022.
  •  

UPDATE

February 25, 2022

  • Further Sanctions Legislation Coming Tuesday: Following Prime Minister Boris Johnson’s statement previewing new sanctions legislation yesterday, British outlets are expecting legislation outlining the content of the sanctions to be tabled before Parliament on Tuesday. These measures are expected to block Russian companies from raising finance in UK markets and the Russian government from raising sovereign debt in UK markets. The legislation is expected to pass in one day. (https://www.theguardian.com/world/2022/feb/24/boris-johnson-announces-largest-ever-set-of-sanctions-against-russia).

UPDATE

February 24, 2022

  • New Sanctions Legislation: On February 24, 2022, the UK Prime Minister announced plans for the “largest and most severe” package of economic sanctions that Russia “has ever seen.” The legislation imposing the proposed measures, listed below, will be laid before parliament next week.  Among other things, the Prime Minister announced that the UK will:

o    Impose assets freeze restrictions on more than 100 entities and individuals, including VTB Bank and major Russian manufacturers;

o    Introduce powers to exclude Russian banks from the UK financial system, including  preventing access by such banks to GBP and clearing services in the UK;

o    Limit the amount of money Russian nationals can deposit in UK bank accounts;

o    Introduce a ban on Aeroflot landing in the UK;

o    Ban the export of all dual use items to Russia, including items relating to the electronics, telecommunications and aerospace sectors; and

o    In parallel, introduce new sanctions against Belarus. (https://www.gov.uk/government/speeches/pm-statement-to-the-house-of-commons-on-ukraine-24-february-2022)

  • Investigations of Russian Wealth in the UK: In his speech announcing new sanctions legislation, Prime Minister Johnson announced plans to reinforce the UK’s Unexplained Wealth Order Regime and introduce a new “Kleptocracy Cell” in the National Crime Agency.

  • SWIFT Restrictions Considered: The Prime Minister’s statement to the House of Commons indicated that the UK is considering restricting Russia’s access to SWIFT, the financial messaging service used in international transactions.

February 23, 2022

    • Boris Johnson: “More to Come”  –  “There is more to come and we will be stopping Russia from raising sovereign debt, stopping companies from raising money and stopping Russian companies… even clearing in sterling and dollars on international markets.”https://www.bbc.com/news/uk-politics-60494130

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