x

Ukraine Crisis – UK Sanctions Update

UPDATE:

Week of October 10, 2022

  • PM Liz Truss Condemns Russian Attacks in Call With President Zelenskyy: On October 10, 2022, the British Prime Minister spoke to Ukrainian President Zelenskyy. Ms Truss strongly condemned Putin’s appalling attacks on civilian areas in Kyiv and elsewhere. The leaders also welcomed the deliveries of British military aid which continue to arrive in Ukraine. (https://www.gov.uk/government/news/pm-call-with-president-zelenskyy-10-october-2022).
  • BVI Court Question OFSI’s Delay in Granting License in Case Concerning Sanctioned Alfa Bank: On October 11, 2022, the judgment was published regarding Alfa Bank’s case against Kipford Ventures.  Alfa Bank applied for a freezing order against Kipford in the BVI in 2021. When Alfa Bank was sanctioned in 2022 its lawyers applied for a license to receive legal fees in the UK and the BVI. The BVI granted the license within 4 months, but OFSI had not granted it 6 months later.  The BVI court said “The reasons for OFSI’s delay is wholly unclear.  The Governor and OFSI are both emanations of the British State, so one would expect them to liaise to reach the same conclusion on the self-same set of facts”. (https://www.eccourts.org/ao-alfa-bank-v-kipford-ventures-ltd-4/).
  • LetterOne nears Holland & Barrett Debt Deal: On October 8, 2022, it was reported that UK-based investment group LetterOne is nearing a deal with lenders behind Holland & Barrett to buy out the £890 million debt used to acquire the high street healthcare retailer. LetterOne, which has not been subject to sanctions, has moved to cut ties with its Russian owners, including sanctioned oligarchs Mikhail Fridman and Petr Aven, separating their shareholdings and freezing their management rights. (https://www.ft.com/content/72615a93-ef2c-46bd-be40-cc0c890dc4e6).  

UPDATE:

Week of September 26, 2022

  • UK to extend professional services ban and expand trade sanctions

     

    On 30 September, 2022, the UK Government announced a new suite of sanctions in response to annexation of the Ukrainian regions of Donetsk, Luhansk, Kherson and Zaporizhzhia by Russia (see here). The announcement indicates that the UK will extend the professional services ban currently place and also expand existing trade sanctions targeting Russia. The precise scope of and guidance related to these measures is not clear from the announcement.  Under the new measures, we note the following:

    1. Extension of professional services ban: According to the announcement, Russia will lose access to major western services that Russia depends on, including: IT consultancy, architectural services, engineering services, transactional legal advisory services, and auditing services.  This could have a significant impact on companies operating in these sectors. We note that the UK professional services ban currently includes an exclusion for auditing services: based on the latest announcement, this exclusion may be removed in whole or in part. 

     

    1. Expansion of trade sanctions: The UK will ban the export of nearly 700 goods that are crucial to Russia’s industrial and technological capabilities.  This could have particular impacts for exporters of the goods to be included in the ban.  Moreover, these measures could have significant impacts on financial institutions and other parties who provide financial, technical or other forms of assistance in respect of the export of such goods to or for use in Russia.

     

    As with previous announcements over the past few months, these measures will come into force when the implementing legislation is laid before and passed through Parliament. This could happen in the coming days, weeks or months.  We will continue to monitor developments closely.

  • OFSI Add 92 Entries to Sanctions Consolidated List: On September 26, 2022, the UK imposed asset freeze restrictions on 89 individuals and 3 companies.  At the same time, 3 entries on the UK sanctions list were amended and 1 entry was corrected under the Russia financial sanctions regime. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1106555/Notice_Russia_260922.pdf).
  • UK Sanctions Collaborators of Russia’s Illegal Sham Referendums: On September 26, 2022, the UK announced that the imposition of new asset freeze designations was in response to the Russian regime’s illegal sham referendums in four regions of Ukraine, a clear violation of international law, including the UN Charter. The UK Foreign Secretary James Cleverly said: “[the] sanctions will target those behind these sham votes, as well as the individuals that continue to prop up the Russian regime’s war of aggression. We stand with the Ukrainian people and our support will continue as long as it takes to restore their sovereignty.” (https://www.gov.uk/government/news/uk-sanctions-collaborators-of-russias-illegal-sham-referendums).
  • Truss Tells Zelenskyy the UK Will Never Recognise Russian Annexation: On September 28, 2022, Ukrainian President Volodymyr Zelenskyy spoke with Liz Truss “in light of Russia’s sham referendums“, Downing Street said. The Prime Minister “made clear the UK would never recognise Russian attempts to annex sovereign territory“, while the Ukrainian president welcomed her “strong backing“, including at the UN last week. Truss also thanked Zelenksyy for his work in securing the release of five British nationals held by Russian-backed proxies in eastern Ukraine. The leaders also discussed how the UK and Ukraine could work together to secure Ukraine’s gas supplies in the long term. (https://www.bbc.co.uk/news/live/world-europe-63045333).
  • OFSI Imposes Monetary Penalty on UK-registered Wine Competition Company: On September 27, 2022, OFSI published details of a £30,000 monetary penalty imposed on Hong Kong International Wine and Spirits Competition Ltd (the “Company”) for violating sanctions relating to Ukraine. Between September 2017 and August 2020, the Company are said to have received 3 payments and 78 wine bottles from the State Unitary Enterprise of the ‘Republic of Crimea’ Production-Agrarian Union (“Massandra”), a listed entity, for entry into certain wine competitions. This resulted in the receipt of £3,919.62 in tangible economic resources by the Company from Massandra. Moreover, OFSI determined that publicity provided by the Company to Massandra was an intangible economic resource. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1106745/Notice_of_Imposition_of_MP_-_HKIWSC.pdf).
  • Sanctions Debates in the House of Commons: On September 22, 2022, two sanctions-related debates were held in the House of Commons in respect of sanctions and Ukraine. A couple of the key points were that (i) Russia is to be considered a state sponsor of terrorism and the seizure of frozen Russian state and state-linked assets (including frozen sanctioned individual assets) to be used for the reconstruction of Ukraine; and (ii) Ukraine should co-ordinate and approve any deal relating to a designated person “[buying] their way out of sanctions” and for any proceeds of such to go to the reconstruction of Ukraine. (https://hansard.parliament.uk/Commons/2022-09-22/debates/30ae837e-17b0-4fb9-8354-5496f8513b6e/CommonsChamber).
  • UK Amends Russia Sanctions List: On September 28, 2022, the UK amended entries of seven individuals subject to an asset freeze. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1107653/Notice_Russia_280922.pdf).
  • Jersey Allow Automatic Implementation of UK Sanctions on Russia: On September 29, 2022, a new amendment was made to the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 allowing automatic implementation of certain future amendments to the UK’s Russia (Sanctions) (EU Exit) Regulations 2019. This means: (i) if the UK amends their Russia Regulations to add a new prohibition, a breach of which is a criminal offence in the UK, then the existing Jersey offence of breaching implemented sanctions provisions will apply automatically; and (ii) if the UK grants a general licence under the UK Russia Regulations in relation to something other than an asset-freeze, then this will have automatic effect in Jersey.  (https://www.jerseyfsc.org/news-and-events/automatic-implementation-of-uk-sanctions-on-russia/)
  • Apple Removes VK Apps to Comply with UK Sanctions: On September 28, Apple announced that it had removed VKontakte (VK), a top Russian social media platform, and several other VK-connected apps from the app store. The company said that it made the decision to remove the apps in order to comply with new UK sanctions imposed on Russia. (https://www.cnn.com/2022/09/28/tech/apple-removes-russian-vk/index.html).

UPDATE:

Week of September 19, 2022

  • OFSI Updates Russia Guidance on Food Security Licensing: On September 21, 2022 OFSI, updated its Russia guidance, adding three new questions (questions 24 to 26) which further clarify how to use the food security licensing provision in the Russia (Sanctions) (EU Exit) Regulations 2019, particularly with regard to providing insurance. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1105463/Russia_guidance_21.09.22.pdf).
  • Sanctions: Issues for Commercial Lawyers – Combar Seminar: On Monday 26 September, 2022, Maya Lester KC and Stephen Horan will be discussing “sanctions: issues for commercial lawyers” for the UK Commercial Bar Association in the Ashworth Centre in Lincoln’s Inn at 5:30pm UK time. Emailadmin@combar.com to register your attendance. Please note that attendance is only available for Combar members. (https://www.combar.com/event/27th-july-sanctions-issues-for-commercial-lawyers-by-maya-lester-qc-and-stephen-horan/).
  • UK Amends De-lists ZAO Interavtomatika: On September 16, 2022, the UK removed ZAO Interavtomatika from the UK sanctions lists.  A number of other UK asset freeze listings were updated or amended at the same time. (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1104918/Notice_Russia_160922.pdf).
  • Marathon Petroleum Opens UK Office Ahead of EU’s Russia Sanctions: On September 21, 2022, Marathon Petroleum Corp, the largest fuel maker in the US, is opening a small office in London. The office’s focus will be on trading diesel-type fuel, possibly including jet fuel. There is currently no plan for crude oil. Marathon’s decision was likely driven, at least in part, by upcoming European Union sanctions on Russia that will all but cut the continent off from its single biggest external diesel supplier. The US refiner regularly sells oil products for export, including from its Garyville and Galveston Bay refineries on the Gulf Coast, according to its 2021 annual report. It may be looking to ramp up fuel sales into Europe, helping to fill the void left by Russian barrels. The EU’s sanctions on Russia which ban seaborne imports of refined petroleum from early next year are set to redraw the global map of trade flows for diesel and at least some other oil products. (https://www.bloomberg.com/news/articles/2022-09-21/us-oil-refining-giant-opens-uk-office-ahead-of-eu-fuel-sanctions).
  • Polymetal Scraps Dividend as Sanctions Bite: On September 22, 2022, Polymetal announced that they have scrapped dividend payments and will resume them only if it manages to exchange shares frozen by EU sanctions, as the West’s financial penalties on Moscow push the Russian gold and silver miner towards a liquidity crunch. The London-listed precious metals producer said it had permanently cancelled its full-year 2021 dividend because of a “significant decline in operating cash flows, challenges in establishing new sales channels and the short-term liquidity headwinds.” (https://www.ft.com/content/6ba0e513-b8b3-4066-acdc-762128f1fff0).
  • UK Foreign Secretary to Confront Russia Over Atrocities at UN Meeting: The UK foreign secretary will demand justice for the victims of war crimes in Ukraine when he faces his Russian counterpart for the first time. James Cleverly will meet Russian Foreign Minister Sergei Lavrov at a UN summit in New York on Thursday. The event has been overshadowed by the Russian president’s nuclear threat and call-up of military reservists. Downing Street said Vladimir Putin’s move was a “clear admission” his invasion of Ukraine was failing. The escalation came as world leaders and senior diplomats gathered at the UN General Assembly in New York this week. Mr. Cleverly is attending as part of a UK delegation headed by Prime Minister Liz Truss, who will rally support for Ukraine in a speech to the assembly. In her summit speech, Ms. Truss will pledge that the UK under her leadership would work with allies to counter authoritarianism and champion freedom, sovereignty and democracy. (https://www.bbc.co.uk/news/uk-politics-62989500).
  • Liz Truss Commits UK to Give Ukraine at least £2.3bn in Military Aid: The Prime Minister pledged the UK will match or exceed the record support given to Volodymyr Zelenskyy’s “inspirational” troops. Ms Truss announced the support as she prepared to fly to New York, where she will use a United Nations summit in the US to rally support in helping Ukraine fight Russia. She will also try to rally world leaders to end energy dependence on Mr Putin’s gas as he turns the taps off on the Nord Stream 2 pipeline. (https://news.sky.com/story/uk-will-match-military-aid-spent-on-ukraine-next-year-liz-truss-pledges-12701552).

UPDATE:

Week of September 12, 2022

  • Investors Fume at Licensing Delays for Payments Linked to Russian Firms: According to Bloomberg, frustrations are mounting among investors at delays at the UK’s Office of Financial Sanctions Implementation (“OFSI”) in assessing license applications.  According to reports, some $28.9 billion worth of Russian company bonds are in default and non-Russia investors are unable to receive payments under those bonds without a license from OFSI. (https://www.bloomberg.com/news/articles/2022-09-13/investors-fume-at-uk-treasury-s-license-delays-for-russian-firms)
  • Russian Billionaire Mikhail Fridman Offers $1 Billion to Ukraine in Hope of Sanctions Relief: Russian businessman Mikhail Fridman is offering to transfer $1 billion of his personal wealth into a Ukrainian bank he co-founded, a proposal that people familiar with the issue said is intended to persuade the U.K. to lift sanctions against him. Mr. Fridman’s proposal is among a number of overtures that blacklisted business executives, banks and companies are quietly making to Western authorities as those nations prosecute a campaign to economically cripple Russia in response to its war in Ukraine, according to U.S. officials. Mr. Fridman denied having made a quid pro quo offer to Ukraine. (https://www.wsj.com/articles/russian-billionaire-mikhail-fridman-offers-1-billion-to-ukraine-in-hope-of-sanctions-relief-11662659071)
  • ‘Profoundly Immoral’ for Russia Not to be Invited to Queen’s Funeral: The Russian foreign ministry has reacted to news the country was not invited to send a delegate to the Queen’s funeral on Monday. It said the decision was “profoundly immoral,” adding: “We view this British attempt to use a national tragedy that has touched the hearts of millions of people around the world for geopolitical purposes to settle scores with our country during the days of mourning as profoundly immoral… For our part, we express our profound condolences to the British people for the great loss that befell them.” (https://news.sky.com/story/ukraine-war-latest-updates-putin-rejected-deal-that-met-his-demands-on-ukraine-before-war-12541713?postid=4473163#liveblog-body)

UPDATE:

Week of August 29, 2022

UPDATE:

Week of August 22, 2022

UPDATE:

August 08, 2022

  • Tighter Export Controls on Electronics Could Hamper Russia’s War Effort: According to a report published by UK think tank the Royal United Services Institute, Russia’s military could be unable to operate the high-tech weapons and communications systems it has been using in Ukraine if the West were to tighten its export control regime. The report states that almost all of Moscow’s modern military systems depend on western-made microelectronics. (https://www.bbc.co.uk/news/world-europe-62464459).

UPDATE:

August 05, 2022

UPDATE:

August 04, 2022

  • UK Energy Bills to Increase to £4000 by January 2023: The annual price cap is predicted to hit £3,523 in October before rising to £4,210 in January. That compares to a cap of £1,977 in place as at 4 August 2022 and £1,271 in October last year. Ofgem confirmed plans to reset the price cap on British household energy bills every three months instead of every six months. The change will help suppliers manage high and volatile energy costs in the wake of Russia’s invasion of Ukraine(https://www.telegraph.co.uk/business/2022/08/04/ftse-100-markets-live-news-boe-interest-rate-energy/).

UPDATE:

August 03, 2022

  • Gazprom Seeks Guarantees from Siemen’s UK on Gas Turbine: The delivery of a turbine crucial for Russian gas supplies to Europe has been delayed. Russia claims this is because of the sanctions from the West, a claim denied by the German chancellor Olaf Scholz. Dmitry Peskov, Russian president Vladimir Putin’s spokesman, said Russia wants guarantees that Siemens’ UK arm will not shut off the turbine remotely (https://www.ft.com/content/d926a768-f976-4bee-823c-0f255afb7087).
  • The UK is Yet to Decide on a Potential Oil Cargo Insurance Ban on Russia: The UK, along with the EU, have delayed a potential oil cargo insurance ban on Russia with fear of seeing further increases in oil prices. Both the UK and EU agreed to join the ban in May 2022. A ban on the insurance market would threaten Russia’s ability to export oil to other countries (https://www.energylivenews.com/2022/08/03/why-has-the-uk-delayed-the-decision-to-cut-off-russia-from-oil-insurance-market/).
  • Three British Men to Stand Trial in Russia-backed Separatist Court Accused of Being Mercenaries: John Harding, Dylan Healy and Andrew Hill will be put on trial in the Donetsk People’s Republic. The three men were allegedly fighting for the Azov Battalion for Ukraine against the Russian army and were captured in the eastern Ukrainian city of Mariupol (https://www.lbc.co.uk/news/three-british-men-to-stand-trial-in-russian-separatist-court/).

UPDATE:

August 02, 2022

UPDATE:

August 01, 2022

  • UK Amends General Trade Licence on Vessels: The General Licence provides regulation on the provision of technical assistance, financial services and funds, and brokering services related to vessels. This amendment, which comes into force on August 1, 2022, enables the provision of insurance and reinsurance to a person connected with Russia in relation to vessels, aircrafts and aero gas turbine engines, subject to the wider restrictions and conditions of the licence. (https://www.gov.uk/government/publications/general-trade-licence-russia-sanctions-vessels).

UPDATE:

July 29, 2022

UPDATE:

July 28, 2022

  • OFSI Updates its General Guidance on Licensing Time Frame: On July 28, 2022, OFSI announced that, due to exceptionally high demand at present, it will be unable to provide substantive engagement on specific licence applications within four weeks. OFSI stated that it is prioritising cases where there are issues of personal basic needs and/or wider humanitarian issues at stake which are of material impact or urgency, or which are deemed to be of particular strategic, economic or administrative importance. (https://www.gov.uk/government/publications/financial-sanctions-faqs#full-publication-update-history)
  • Report: British Ships Help Russia Avoid Oil Sanctions: Investigations have discovered that British ships are being used to transport Russian oil, helping the Russian oil industry avoid sanctions. British vessels facilitated the transfer of Russian oil between tankers at least twice this May. At least £165m worth of oil was then sent to the Persian Gulf and Singapore. These British transfers—the total number of which is unknown—are completely legal and help Russia shift oil sales to Asia. (https://www.independent.co.uk/news/business/russian-oil-sanctions-embargo-uk-suffolk-putin-b2111228.html).

UPDATE:

July 27, 2022

  • UK Government Sanctions YouTuber for Spreading Russian Propaganda: The UK government named the YouTuber Graham Phillips in its latest round of sanctions, freezing his UK assets. The government accused Phillips of publishing content that promotes actions and policies that undermine the territorial integrity and independence of Ukraine. A British MP previously accused Phillips of committing a warm crime by interviewing British national Aiden Aslin, who was handcuffed and bruised after being captured by Russian troops while fighting for Ukraine. (https://www.bbc.com/news/uk-scotland-62308671).
  • UK Household Energy Bill Predicted to Surpass £500 Due to Russian Supply Cuts: Experts predict that UK households will see record energy prices this winter due to Russia cutting its supply of natural gas to Europe. The average British household is expected to pay just over £500, three times higher than last year’s average monthly bill. A UK parliamentary committee determined this week that the government needs to provide greater consumer relief. (https://www.bloomberg.com/news/articles/2022-07-27/uk-energy-bills-are-set-to-top-500-per-month-as-russia-cuts-gas).

UPDATE:

July 26, 2022

  • UK Imposes 42 New Sanctions Designations: On July 26, 2022, OFSI imposed asset freeze sanctions on 41 individuals and 1 entity.  The new designations include 29 regional governors from across Russia, Russia’s minister and deputy minister of justice, and two nephews of sanctioned Russian billionaire Alisher Usmanov. (https://www.gov.uk/government/news/uk-sanctions-russian-officials-propping-up-putins-proxy-administrations-in-ukraine).
  • UK Treasury Blocks ‘Non-Essential’ Overseas Aid Payments: UK Treasury Chief Secretary Simon Clark directed the Foreign Office and other departments to suspend “non-essential” aid spending for the rest of the summer until Conservative Party chooses a new Prime Minister. The freeze is in part due to concerns that the cost of relief work in Ukraine will breach the UK’s foreign aid spending cap. Though essential programs may continue, it is unclear what the government considers an essential program. (https://www.ft.com/content/df86bc7e-5f9d-488a-8eaa-1335c4b56182).

UPDATE:

July 25, 2022

  • UK Treasury Blocks ‘Non-Essential’ Overseas Aid Payments: The UK overseas aid programme has been thrown into confusion after the government blocked “non-essential” new payments for the rest of the summer over concerns the cost of relief work in Ukraine will breach a spending cap. (https://www.ft.com/content/df86bc7e-5f9d-488a-8eaa-1335c4b56182).
  • UK Establishes New Unit to Combat Kleptocrats & Money Laundering: The UK’s National Crime Agency has established a new unit, the Combating Kleptocracy Cell (CKC). It has mandate to investigate corrupt elites, sanction evaders, and enablers of money laundering. Specifically, the CKC will target corrupt elites holding their assets in the UK, including individuals closely linked to Putin and his authoritarian regime who have thus far managed to evade sanctions or hide their assets from authorities. (https://www.occrp.org/en/daily/16603-uk-establishes-new-unit-to-combat-kleptocrats-money-laundering).
  • Nornickel’s Metal Will Not be Banned from the London Metal Exchange: It has been reported by Reuters that the London Metal Exchange (LME) has told some of its committee members it will not ban Nornickel’s metal from its system.  This report follows the designation of Nornickel’s Chief Executive Vladimir Potanin as a UK sanctions target and amid concerns that a ban on Nornickel’s metals would destabilise the LME nickel market. (https://www.nasdaq.com/articles/lme-wont-ban-nornickels-metal-as-russian-firm-isnt-under-uk-sanctions-sources-0).

UPDATE:

July 22, 2022

  • British Parliament Debates Effectiveness of UK Sanctions: In a Backbench Business Committee debate on “Human Rights Abuses and Corruption: UK Sanctions” on July 21, 2022, British MPs called for sanctions to be imposed on Russians and Ukrainians linked to human rights violations and corruption, and for further coordination on sanctions with international partners. Sir Iain Duncan Smith also urged for increased Government reporting on the use of sanctions and for further commitment on the confiscation of frozen Russian assets by the Government. (https://www.parallelparliament.co.uk/debate/2022-07-21/commons/commons-chamber/human-rights-abuses-and-corruption-uk-sanctions).

  • MP Confirms Sanctions Do Not Affect Medicines and Food Supplies: In answer to a question on  the TheyWorkForYou website on July 21, Andrew Griffith, Parliamentary Under-Secretary for the Department for International Trade, confirmed that UK “sanctions against Russia do not target exports of medicines, nor do they seek to impede delivery of food supplies or humanitarian assistance”.  (https://www.theyworkforyou.com/wrans/?id=2022-07-13.35926.h&s=russia).

UPDATE:

July 21, 2022

  • UK Introduces New Sanctions Including Professional Services Ban and Expanded Trade Sanctions:  On July 21, 2022, the UK adopted the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022, imposing further restrictions. The new restrictions include:

    o   Prohibitions on the export, supply and delivery, and making available of items listed on the G7 Dependencies and Further Goods List to, or for use in Russia, as well as related services. The list includes chemicals, materials, machinery goods and electrical appliances.

    o   Expanded prohibitions on energy-related goods and services, which now include:

    –  the export of energy-related goods to Russia, regardless of their eventual point of use;

    –  the making available of energy-related goods to a person connected with Russia; and

    –  the provision of energy-related services (such as drilling or well testing) to all oil and gas exploration and production projects in Russia.

    o   Prohibitions on the provision of accounting, business and management consulting, and public relations services to persons connected to Russia, including Russian residents who are temporarily located in another country, such as the UK (see also the item below).

    o   Prohibitions on the import, acquisition and supply or delivery of:

    –  oil and oil products (enters into force on 31 December 2022); and

    –  coal and coal products (enters into force on 10 August 2022);

    that originate in Russia, as well as the provision of related services.

    o   Prohibitions on the import, acquisition or supply and delivery of gold that originates in Russia on or after the 21 July 2022, as well as ancillary services.

    (https://www.legislation.gov.uk/uksi/2022/850/contents/made).

  • UK Amends Ban On Aviation Technical Assistance: Aviation technical assistance measures introduced in the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 which apply to “Russian aircraft” have now been amended to allow necessary technical assistance for temporarily detained aircraft in the ownership of suspected designated persons. (https://www.legislation.gov.uk/uksi/2022/850/regulation/17/made).

UPDATE:

July 20, 2022

UPDATE:

July 19, 2022

  • UK Updates Investment Restrictions Relating to Russia: On July 19, 2022 the UK’s Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 came into force, introducing new investment restrictions. The new restrictions prohibit certain investment activities, including: the acquisition of Russian land, entities or places of business; establishing joint ventures; and, the provision of investment services for these purposes. (https://www.legislation.gov.uk/uksi/2022/801/contents/made).

  • Scope of Firms With Financial Sanctions Reporting Obligations Increased: On July 19, 2022, OFSI adopted The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2022 and The Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2022, which extend the definition of “relevant firms” that have financial sanctions reporting obligations. From August 30, 2022, cryptoasset exchange providers and custodian wallet providers will be required to notify OFSI of certain information as soon as practicable when encountering a designated person in the course of their business. (https://www.legislation.gov.uk/uksi/2022/819/contents/made; https://www.legislation.gov.uk/uksi/2022/818/contents/made).

  • YouGov Survey Finds Less Britons Now Support Sanctions: Surveys published by YouGov on Tuesday show that only 38% of Britons say they would support keeping the current sanctions against Russia if it means an increase in the overall cost of living, down from 48% in March. Further, 45% of Britons say they would support the current sanctions against Russia even in the face of “an increase in energy prices”, but 41% disagree. Those in the lowest income households appear less likely to support keeping current sanctions. (https://yougov.co.uk/topics/politics/articles-reports/2022/07/19/britons-tend-support-keeping-russia-sanctions-face).

UPDATE:

July 18, 2022

  • UK Updates Trade Sanctions Instruments Relating to Russia: On July 15, 2022, the UK adopted the Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 to revoke and replace the Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022. The Amendment corrects a small number of errors in the revoked statutory instrument but otherwise maintains the same provisions.  These primarily focus on trade restrictions relating to inter alia interception and monitoring services, maritime goods and maritime technology, goods and technology exported to non-government controlled Ukrainian territory and certain iron and steel goods. (The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 (legislation.gov.uk)).

  • UK Updates Designation Criteria under Russia Sanctions: On July 18, 2022, the UK adopted the Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022. The Amendment specifies additional activities for which a person may be designated and broadens the interpretation of being “associated” with a designated person. The Amendment also provides for a new exception from trade sanctions measures for humanitarian assistance activity, and corrects drafting errors. (The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 (legislation.gov.uk)).

  • UK Summons Russian Ambassador: The Foreign, Commonwealth & Development Office has summoned the Russian Ambassador over reports of the death of a British aid worker. Foreign Secretary Liz Truss said “[t]he Russian government and its proxies are continuing to commit atrocities. Those responsible will be held to account.” (UK summons Russian Ambassador – GOV.UK (www.gov.uk)).

  • HMRC Answers Questions on Russia Sanctions from Treasury Committee: On July 18, 2022, the UK Treasury Committee published a letter from HM Revenue and Customs (HMRC) dated 8 July providing responses to certain questions raised as to HMRC’s responsibilities regarding trade sanctions, including the extent of HMRC’s involvement in designing the recent trade sanctions against Russia. (https://committees.parliament.uk/publications/23112/documents/169297/default/).

  • UK Intelligence Indicates Russia is Using Private Mercenary Group: In an intelligence update released on Monday, British military intelligence claims that the Wagner Group, a Russian paramilitary organization, is lowering its recruiting standards – hiring convicts and formerly blacklisted individuals in an attempt to reinforce Russian front-lines. Both Prigozhin and the Kremlin denied any connection to the organization. (https://www.cnbc.com/2022/07/18/russia-relying-on-wagner-in-ukraine-that-is-hiring-convicts-uk-says.html).

UPDATE:

July 15, 2022

  • UK Confirms Position on Payment of State Pensions Following Sanctions: In answer to a question on the TheyWorkForYou website, the Secretary of State for Work and Pensions, Guy Opperman, confirmed that due to sanctions on Russian banks, the payment of the State Pension to claimants, where payment was going directly to any Russian bank which has been sanctioned, has been suspended. If those claimants open an alternative account with a non-sanctioned bank, then payment will resume. (https://www.theyworkforyou.com/wrans/?id=2022-07-06.31711.h&p=10594).

UPDATE:

July 14, 2022

  • FCA Publishes Letter Regarding its Sanctions Responsibilities: On July 11, 2022, there was published a letter by the Financial Conduct Authority (FCA) to the House of Commons’ Treasury Committee regarding the regulator’s financial sanctions responsibilities. In the letter, the FCA addressed its responsibilities for financial sanctions and covers the following topics: the current level of awareness and compliance at authorised firms of their obligations; how the FCA feeds into the design, implementation and enforcement of financial sanctions; and, how the FCA shares intelligence with OFSI. (https://committees.parliament.uk/publications/23023/documents/168751/default/).

  • UK Trade Remedies Authority (TRA) Warns of Fall in Rebar Supplies: The Trade Remedies Authority, a non-departmental public body of the Department for International Trade, warns there will be a fall in Reinforcement Bar supplies due to the war in Ukraine and sanctions against Russia and Belarus. It has therefore proposed that existing anti-dumping measures on imports of High Fatigue Performance Steel Concrete Reinforcement Bars (HFP Rebar) from China be revoked. (https://www.gov.uk/government/news/uk-tra-proposes-anti-dumping-measures-on-hfp-rebar-from-china-be-removed).

  • UK Announces Support Package For War Crime Investigations: In a speech at the Ukraine Accountability Conference in The Hague, Minister of State at the Foreign Office Lord Ahmad of Wimbledon will on July 14, 2022 announce a new £2.5 million support package to assist the Office of the Prosecutor General of Ukraine (OPG) with investigating war crimes committed in Ukraine, including conflict-related sexual violence. (https://www.gov.uk/government/news/lord-ahmad-announces-uk-support-package-for-war-crimes-investigations).

UPDATE:

July 12, 2022

  • UK Warns Against Ransomware Payments Following Russian Sanctions: In a letter addressed to UK lawyers the UK’s National Cyber Security Center (“NCSC”) and the Information Commissioner’s Office (“ICO”), have advised against paying a ransom, explaining that Russian sanctions could make such payments to Russian hackers technically illegal. Ignorance of the attackers’ nationality would be a dangerous tactic, since the NCSC specifically states that it would know. (https://www.ncsc.gov.uk/files/Joint-ICO-and-NCSC-letter-to-The-Law-Society-and-The-Bar-Council.pdf)

  • UK Government Updates Travel Advice for Russia: On July 12, 2022, the UK Government updated its foreign travel advice relating to Russia to include new information on the security checks required in Russia on foreign nationals, including Britons. (https://www.gov.uk/foreign-travel-advice/russia).

  • Petropavolvsk Plans to File for Administration: Petropavolvsk, which was once the biggest gold miner listed on the London Stock exchange, plans to file for administration this week as it struggles to refinance its borrowings and seeks a buyer for its mines in Russia’s far east. On Tuesday, the company asked for trading in its shares to be suspended in London and said it would seek a hearing at the High Court in the “coming days”. (https://www.ft.com/content/e4371df1-30bb-48a7-b5c6-fdc47cdfdd84)

UPDATE:

July 11, 2022

  • FCA Issues Policy Statement for Investors Following Invasion of Ukraine:The UK’s Financial Conduct Authority (FCA) have issued a policy statement (PS22/8) on “Protecting investors in authorised funds following the Russian invasion of Ukraine”. The statement sets out final rules and guidance which allow authorised fund managers to create separate unit classes (side pockets) for retail investment funds affected by the invasion of Ukraine. (https://www.fca.org.uk/publication/policy/ps22-8.pdf)

  • Trade Secretary Launches UK-Ukraine Infrastructure Taskforce:  On July 11, 2022, the British International Trade Secretary, Anne-Marie Trevelyan, launched the UK-Ukraine Infrastructure Taskforce alongside Ukrainian Minister for Infrastructure Oleksandr Kubrakov. Longer term, the task force will provide expertise on the delivery of sustainable infrastructure through UK-based businesses and £3.5 billion of financial capacity for UK exporters and Ukrainian buyers. (https://www.gov.uk/government/news/trade-secretary-launches-uk-ukraine-infrastructure-taskforce).

UPDATE:

July 09, 2022

UPDATE:

July 08, 2022

  • UK MP Asked If Secondary Sanctions Would Be Imposed on China: In a question on the TheyWorkForYou website, British Member of Parliament Vicky Ford was asked if secondary sanctions would be imposed on China. While Ford did not answer the question directly, she explained “The UK continues to engage with China at all levels in Beijing, London and at the UN to make it clear that the world is watching what China chooses to say and do”. (https://www.theyworkforyou.com/wrans/?id=2022-06-29.27667.h&s=russia).

UPDATE:

June 29, 2022

  • UK Working to Prevent Russia Accessing UK Trusts Services: In a statement on Wednesday, the UK government announced it is acting alongside international allies to introduce new measures that will prevent Russia from accessing UK trusts services. These services, which allow a person or business to manage the assets of another, are another major element of the UK’s world-class financial services sector that Russia will no longer be able to use. (https://www.gov.uk/government/news/uk-sanctions-russias-second-richest-man).

UPDATE:

June 28, 2022

  • Russia-Ukraine War Exposes AML Loopholes, According to Survey: According to a survey conducted in May 2022 indicates, 34 percent of firms in the finance and banking sector and 47 percent of those in the legal sector have not updated their approach to new customers since the sanctions against Russia were imposed.  The survey reveals “continuing shortfalls in the way some regulated firms check on new and continuing customers and continue to rely on hard-copy documents rather than digital checks to identify them”. (https://www.mortgagestrategy.co.uk/news/russia-ukraine-war-exposes-aml-loopholes-smartsearch/)

UPDATE:

June 27, 2022

  • UK To Introduce New Sanctions This Week: On June 27, 2022, UK Foreign Secretary Liz Truss and Ukrainian Foreign Minister Dmytro Kuleba wrote a joint article in The Telegraph announcing the UK will introduce further sanctions this week “to cut Russia off from its key sources of foreign income: energy and other exports such as gold.” The article confirmed the UK is increasing its sanctions, with further legislation this week on a range of trade bans, and more to come over the next month. (https://www.gov.uk/government/speeches/joint-article-by-british-and-ukrainian-foreign-ministers)

  • Prime Minister to Urge G7 Into Action Over Food Shortages: British Prime Minister Boris Johnson will call on world leaders to take urgent action to get essential food supplies out of Ukraine at the G7 Summit. The Prime Minister will say on Monday that “global leaders need to come together and apply their combined economic and political heft to help Ukraine and make life easier for households across the world. Nothing should be off the table.” (https://www.gov.uk/government/news/pm-to-tell-g7-leaders-we-must-end-putins-stranglehold-on-food-prices)

  • UK Joins Canada, US and Japan in Banning Imports of Russian Gold: In a press release on June 26, 2022, the UK announced new exports of Russian gold will no longer be allowed to enter the UK, Canada, US and Japan thanks to tough new measures to be announced at the G7 Summit. Due to London’s role as a major global gold trading hub, the new sanctions are expected to have a huge impact on Putin’s ability to raise funds. The ban will come into force “shortly”. (https://www.gov.uk/government/news/uk-sanctions-russian-gold-exports).

  • UK to Provide Additional $525 Million In Guarantees for Ukraine: In response to the Ukrainian Government’s fears that it could run out of funding by the autumn, the UK announced it stands ready to provide another $525 million (or £429 million) in guarantees for World Bank lending later this year. The new support announced today brings the total amount of fiscal support including UK loan guarantees to £1.3 billion ($1.5 billion) and the combined UK economic and humanitarian support to Ukraine to £1.5 billion ($1.8 billion) this year. (https://www.gov.uk/government/news/pm-to-say-to-g7-leaders-we-must-keep-up-our-resolve-on-ukraine)

UPDATE:

June 24, 2022

  • OFSI Aims to Upscale Operations and Introduce New Functions: In a discussion with the Treasury Committee this week, the director of OFSI, Giles Thomson, said the agency plans to up its in-house expertise, improve guidance for businesses and put in place a formal whistle-blowing function to assist with increasing levels of reporting. (https://parliamentlive.tv/event/index/d7a380f5-e4a7-47b0-b873-29fc33ad35be).

UPDATE:

June 23, 2022

  • UK Extends Existing Import Sanctions Measures: On June 23, 2022, the UK Department for International Trade published a notice to importers (NTI 2953) setting out details of a prohibition on the import of certain “revenue generating goods” as well as the acquisition, supply and delivery, directly or indirectly, of revenue generating goods that originate in or are consigned from Russia. The provision of technical assistance, financial services and funds and brokering services relating to these goods is also now prohibited. (https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/nti-2953-russia-import-sanctions).

UPDATE:

June 22, 2022

UPDATE:

June 21, 2022

UPDATE:

June 20, 2022

UPDATE:

June 19, 2022

UPDATE:

June 17, 2022

  •  UK Trade Minister Discusses Measures In Support of Ukraine at WTO Conference: In a statement following the conclusion of the 12th WTO Ministerial Conference in Geneva, the UK’s International Trade Secretary, Anne-Marie Trevelyan, said she convened Ministers to discuss “trade measures in support of Ukraine.” Trevelyan also clarified that Russia’s presence at the conference did not represent a normalization of trade relations between the UK and Russia. (https://www.gov.uk/government/news/uk-statement-following-the-conclusion-of-the-wto-ministerial-conference).  

  • UK Reports Millions Of Russians Attempting To Leave Country:  In a tweet on June 17, 2022, the UK’s Ministry of Defense stated that around 15,000 millionaires are likely attempting to leave Russia, according to migration applications. The tweet claimed the motivation for these applications is highly likely to be an intent to escape the financial impact of the sanctions imposed on Russia. (https://twitter.com/DefenceHQ/status/1537677492433170433).

UPDATE:

June 16, 2022

  • UK Foreign Secretary Pledges to “Keep Increasing The Pressure” On Russia: In an oral statement to Parliament, Foreign Secretary Liz Truss updated the House of Commons on the Government’s support for Ukraine. Truss repeated that the UK was committed to supporting Ukraine for “the long haul” and said “in the long run there must be consequences for Russia’s actions.” The Foreign Secretary also announced the UK was still committed to ending “Russia’s attack on global food security”.  (https://www.gov.uk/government/speeches/ukraine-foreign-secretarys-statement-16-june-2022).

UPDATE:

June 15, 2022

UPDATE:

June 14, 2022

UPDATE:

June 13, 2022

  • UK to Support Ukrainian Trade and Food Production: In a statement at the WTO’s 12th Ministerial Conference (MC12) Ranil Jayawardena, Minister for International Trade, pledged to facilitate the Ukraine’s exports and “look for ways to help Ukrainian farmers to continue planting and growing cereals and oilseeds”. Jayawardena also pledged to continue providing humanitarian aid and help with the reconstruction of Ukraine. (https://www.gov.uk/government/news/wto-ministerial-conference-joint-statement-in-solidarity-with-ukraine).

UPDATE:

June 11, 2022

  • Charity Commission Appoints Interim Manager to Kantor Foundation and Kantor Charitable Foundation: The UK’s Charity Commission opened statutory inquiries into the Kantor Foundation and Kantor Charitable Foundation in April 2022, following the sanctioning of their current trustee, Dr Viatcheslav Kantor. The regulator has frozen the charities’ bank accounts, but under the General Licence issued by the OFSI, the Interim Manager appointed by the Charity Commission is allowed to act as receiver and manager of the charities’ assets. (https://www.gov.uk/government/news/commission-appoints-interim-manager-to-kantor-foundation-and-kantor-charitable-foundation).

UPDATE:

June 9, 2022

  • UK Condemns Death Sentence Handed to UK Nationals for Involvement in Ukraine: On June 9, 2022, UK Foreign Secretary Liz Truss condemned the death sentences handed down by Moscow-backed separatists in the so-called Donetsk People’s Republic.  Truss said the men were prisoners of war and called the judgment a “sham” with “absolutely no legitimacy.” (https://www.rferl.org/a/ukraine-separatists-death-sentence-foreign-fighters/31891033.html)

UPDATE:

June 8, 2022

  • UK Issues New Guidance on Trade Sanctions Relating to Russia: On June 8, 2022, the UK’s Department for International Trade published new guidance setting out what import and export restrictions apply to companies and individuals subject to UK sanctions when trading with Russia. (https://www.gov.uk/guidance/trading-under-sanctions-with-russia).

UPDATE:

June 7, 2022

UPDATE:

June 6, 2022

  • UK to Supply Ukraine with Long-Range Missiles: In a call on June 6, 2022, Prime Minister Boris Johnson spoke to Ukrainian President Volodymyr Zelenskyy and set out the significant new support the Government is providing, including long-range multiple launch rocket systems. He also discussed the ongoing diplomatic negotiations and efforts to end the blockade of Ukraine’s grain exports. (https://www.gov.uk/government/news/pm-call-with-president-zelenskyy-6-june-2022).

  • Barclay’s Raises Brent Crude Forecasts in Response to Russian Invasion: On Monday, Barclays announced that it had revised its Brent Crude forecasts for 2022 and 2023 upward to an average of $111 per barrel this year and next, while it sees U.S. West Texas Intermediate (“WTI”) at $108 for the same period. This revision is an $11 increase for Brent Crude for 2022 and a $23 increase for Brent Crude in 2023. The estimate is the result of anticipated prolonged disruptions in the Russian oil market as a result of the Russian invasion of Ukraine. (https://www.reuters.com/markets/commodities/barclays-raises-brent-forecasts-russia-oil-sanctions-2022-06-06/).

     

UPDATE:

June 4, 2022

  • Russians Struggle to Find UK Lawyers: According to the Financial Times, Russian litigants fighting cases in UK courts are being forced to find new representation as the biggest UK-based law firms are increasingly refusing to act for them, regardless of whether they are sanctioned or not. (https://www.ft.com/content/fd2707b4-f8bb-4b67-95ed-45872884a124)

UPDATE:

June 3, 2022

  • Abramovich-Owned UK Telecoms Group to be Sold For £1: British telecoms group Truphone, owned by sanctioned Russian oligarch Roman Abramovich and his associates, is being bought for £1 by two European tech entrepreneurs, despite being valued at £410 million in 2020. (https://www.ft.com/content/624482dd-0a83-4377-b846-a6bc7dad7cef)

UPDATE:

June 2, 2022

  • UK Members of Parliament (MPs) Call for Transparency on Arms Export Fines: Members of Parliament from across the political divide are piling pressure on the UK government over the secretive punishment regime for British firms that breach weapons export rules. Concerns were raised after it was revealed that an unknown exporter was fined £2.7 million in February, which suggests a severe breach was committed. (https://www.politico.eu/article/pressure-over-secretive-uk-arms-export-fines/).

     

UPDATE:

June 1, 2022

  • UK Member of Parliament Says Royal Navy May Be Used Against Russia: Alec Shelbrooke, a Tory MP who leads the UK’s parliamentary delegation to NATO, has suggested Royal Navy ships could have to use “lethal defensive force” against Russia’s forces as part of a mission to escort vital grain supplies out of Ukrainian ports, at the “high risk” of deaths of UK personnel and the escalation of war in Europe. (https://www.independent.co.uk/news/world/europe/ukraine-russia-war-putin-oil-weapons-latest-b2091419.html).

  • UK Updates Guidance on Imports From Russia and Belarus: On June 1, 2022, the UK officially implemented the additional duties of 35% to a package of goods originating in Russia and Belarus, which had been initially announced on April 21, 2022. The UK has since announced that a further package of Russian and Belarusian goods is planned to be affected by additional duties. (https://www.gov.uk/guidance/additional-duties-on-goods-originating-in-russia-and-belarus).

UPDATE:

May 31, 2022

  • UK Minister of State Promises Further Sanctions on Russia: In response to an FCDO written question, Lord Ahmad of Wimbledon, Minister of State for the Foreign, Commonwealth and Development Office said the sanctions on Russia were having “deep and damaging consequences” and promised the UK would “continue to put more pressure on Putin’s regime, including through further sanctions”. (https://www.theyworkforyou.com/wrans/?id=2022-05-18.HL334.h&p=13103).

  • UK and EU Hit Russian Oil Cargoes with Insurance Ban: The UK and EU have agreed a coordinated ban on insuring ships carrying Russian oil, shutting Moscow out of the Lloyd’s of London insurance market and sharply curbing its ability to export crude, according to the Financial Times. (https://www.ft.com/content/10372dd3-be3c-42b9-982b-241a38efcc88).

UPDATE:

May 30, 2022

UPDATE:

May 29, 2022

  • UK Prime Minister Agrees to Shore up Energy Security on Call with Hungarian Premier: On May 27, 2022, on a call with Hungary’s Prime Minister Viktor Orban, UK Prime Minister Boris Johnson set out his strong condemnation of Russia’s continued attack on Ukraine and said the international community had to continue to apply maximum economic pressure to cripple Putin’s war machine. Both leaders agreed that shoring up energy security and domestic resilience in Europe was crucial.(https://www.gov.uk/government/news/pm-call-with-prime-minister-of-hungary-27-may-2022).

  • £4.25 billion sale of Chelsea Football Club to Todd Boehly to Complete on Monday: The sale of Chelsea football club to a consortium led by US magnate Todd Boehly has been agreed and is expected to be complete on Monday. The sale has required UK Government, European Union and Portuguese Government approval due to the sanctions imposed on Roman Abramovich. The proceeds of Chelsea’s sale – expected to be £2.5bn – will be frozen in a UK bank account on completion of the sale.(https://inews.co.uk/news/chelsea-confirm-4-25billion-sale-todd-boehly-will-be-complete-on-monday-1656754).

UPDATE:

May 27, 2022

  • Holland & Barrett Lenders Appoint Advisers to Oversee Debt Talks: The lenders to Holland & Barrett have appointed investment bank Perella Weinberg to advise on the impact of sanctions on the ultimate owners of the business. Holland & Barrett is owned by LetterOne, the London-headquartered investment group that was funded by Russian oligarchs including Mikhail Fridman and Petr Aven. Both individuals are under sanctions from the UK and EU, although LetterOne itself is not. (https://www.ft.com/content/fca700b7-faa5-4273-85ba-00e7972e7b24).

UPDATE:

May 26, 2022

  • Liz Truss Outline UK’s Increased Support to Counter Russia’s Malign Influence in Bosnia and Herzegovina: During a visit to Sarajevo on May 26, 2022, Foreign Secretary Liz Truss warned against appeasement of Vladimir Putin, and said “We must be relentless in ensuring Ukraine prevails through military aid and sanctions. We can’t take our foot off the accelerator now… I urge Bosnia and Herzegovina to join us in imposing sanctions on Russia – cutting off funding for Putin’s war machine” (https://www.gov.uk/government/news/foreign-secretary-says-west-needs-to-ensure-putin-loses-in-ukraine-26-may-2022)

  • UK Government Says Legal Services Are Essential and Cannot Be Banned: Following the announcement of a ban (not yet in force) on the export of certain professional services to Russia, the UK’s Ministry of Justice has said “Legal services are distinct from other services in the role they play in supporting a flourishing democracy and upholding the rule of law.” The Government has therefore not included legal services within the scope of the ban. However, the Solicitors Regulation Authority has reportedly stepped up spot checks and investigations to monitor and enforce compliance with the sanctions regime. (https://questions-statements.parliament.uk/written-questions/detail/2022-05-16/2441)

  • Abramovich to Donate Proceeds of Chelsea FC Sale to Ukraine Victims: Nadine Dorries, the Secretary of State for Digital, Culture, Media and Sport, made a statement to the UK Parliament on May 26, 2022, re-confirming that the government has issued a licence to Chelsea Football Club to allow the sale of Chelsea FC PLC. In the statement, Dorries stated that “the Club will be free from previous operating restrictions imposed by sanctions from the point the new ownership takes effect, and we expect this to take place in a matter of days.” (https://questions-statements.parliament.uk/written-statements/detail/2022-05-26/hcws71)

UPDATE:

May 25, 2022

  • Treasury Department Extends Russia General License 13A: On Wednesday, the Treasury Department issued General License 13A, which permits US persons to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications, regardless of whether these transactions violate restrictions on payments with the Russian Central Bank, National Wealth Fund, and Ministry of Finance. The new license is valid until 12:01am on September 30, 2022. (https://home.treasury.gov/system/files/126/russia_gl13a.pdf).

  • Treasury Official Outlines Russia Sanctions Program at Anti-Money Laundering Conference:Speaking on Wednesday at SIFMA’s Anti-Money Laundering and Financial Crimes Conference, Under Secretary of the Treasury for Terrorism and Financial Intelligence of the United States Brian Nelson discussed the Treasury Department’s efforts to sanction Russia. He stated that the measures to date are intended to hinder the Russian economy, notably the defense sector, and to improve enforcement. He thanked the private sector for their partnership in this effort, highlighting the Department’s guidance, outreach, and enforcement measures as ways to inform the public. (https://home.treasury.gov/news/press-releases/jy0800).

  • Nike Leaving Russian Market: On Wednesday, Nike announced that it would not extend its franchise agreement with Russia’s Inventive Retail Group (“IRG”) the largest retailer of Nike products in the country. The stores will close once all goods are sold. Nike previously suspended online sales in Russia and closed all of its shops, including ones operating under franchise agreements, in the country. (https://www.rferl.org/a/nike-marks-spencer-leave-russia-ukraine-war/31867200.html).

UPDATE:

May 24, 2022

  • UK Professional Services Firms Seek Exemptions to Ban on Russia Work: Auditors and tax advisers in the UK are lobbying the government for exemptions from a ban on working for businesses in Russia, introduced earlier this month. Lobbyists include the Institute of Chartered Accountants in England and Wales. According to the Financial Times, Ministers are currently considering “very limited exceptions”, such as services needed to wind down operations or contracts for UK firms that are already pulling out of Russia. (https://www.ft.com/content/3f74c9d7-d945-4a77-b0d5-81fdf5b7b23f).

UPDATE:

May 23, 2022

  • UK Prime Minister Refuses to Join Canada in Sanctioning Alexander Lebedev:  Following calls for former KGB officer, Alexander Lebedev, to be sanctioned, the Byline Times reported that a spokesperson on Boris Johnson’s behalf stated “It’s not for me to comment on a different judgement of a different country…we will, and have, taken significant action against Putin’s inner circle.” (https://bylinetimes.com/2022/05/23/alexander-lebedev-boris-johnson-evgeny-sanctions-putin-russia/).

  • Gazprom’s UK Energy Supply Business Considers Rebrand: Gazprom Energy is considering a rebrand, as it seeks to distance itself from its Russian owners after the invasion of Ukraine. Gazprom Energy is the biggest gas supplier to businesses in the UK, supplying more than a fifth of the gas used by British companies. (https://www.ft.com/content/43aef0cc-341d-48ac-b1b4-2402cc4dffeb).

UPDATE:

May 22, 2022

  •  Labour Party Calls for Sanctions on Media Magnate, Alexander Lebedev: Following Canada’s decision to sanction Russian billionaire Alexander Lebedev, the Labour party’s deputy leader, Angela Rayner, has said the case for the British government to follow Canada’s lead is “extremely strong”. The British Prime Minister’s Boris Johnson’s, links to Lebedev are well documented. (https://www.ft.com/content/c9fe610a-f4ec-413c-8f0d-fd9a86eca9dd)

  • Sainsbury’s Bans Russian Fuel At All Its 315 UK Petrol Stations: The UK’s second largest supermarket, Sainsbury’s, announced it will no longer sell Russian diesel at its petrol stations by the end of the year. The ban would affect 315 of its forecourts across the country. The supermarket has already stopped selling products that are solely from Russia. (https://www.mirror.co.uk/news/uk-news/sainsburys-announces-russian-ban-affect-27025353)

  • UK Says Sanctions Are Causing “Shortages” of Russian Reconnaissance Equipment Used in Syria: Sanctions on the Russian economy are helping to cause “shortages” of vital reconnaissance equipment, the UK’s Ministry of Defense has said. Russia has used the equipment, which allows unmanned aerial vehicles to identify enemy targets to be hit by jets or artillery fire, in Syria. (https://www.euronews.com/2022/05/21/uk-ukraine-crisis-britain-intelligence)

  • Fresh Calls for UK Sanctions Against Russia State-Linked Bank Pursuing Billions in Russian Claims Abroad: The National Bank Trust is pursuing former bank executive, Ilya Yurov, who is originally from Moscow, with two former colleagues for $900 million (£720 million) in Russia, after Yurov lost a high court case. The National Bank Trust is not included on the UK Sanctions List. Yurov is calling for them to be added, over concerns the proceeds from the disposal of his estate risk being used to fund Vladimir Putin’s war machine. (https://www.theguardian.com/world/2022/may/22/if-my-65m-kent-mansion-is-sold-now-it-could-help-fund-putins-war).

UPDATE:

May 20, 2022

  • UK Financial Conduct Authority (“FCA”) Calls For Reports on Sanctions Evasion: The FCA has requested that regulated firms produce reports of sanctions evasion issues or weaknesses in sanctions controls where they relate to regulated firms or UK listed securities. Reports should include information on: firms having poor sanctions controls; suspected breaches of the sanctions regime; actual breaches of the sanctions regime; and any method believed to be used by firms or individuals to breach the sanctions regime. (https://www.fca.org.uk/firms/financial-crime/reporting-sanctions-evasions).

UPDATE:

May 19, 2022

  • UK Prime Minister Pledges UK’s “Steadfast Solidarity” in Call With President Zelenskyy: UK Prime Minister Boris Johnson spoke to Ukrainian President Volodymyr Zelenskyy on May 19, 2022 and looked at options to open up critical sea and land supply routes for Ukrainian grain stocks. The Prime Minister reiterated the UK’s steadfast solidarity with Ukraine. (https://www.gov.uk/government/news/pm-call-with-president-zelenskyy-19-may-2022).

  • UK Government Sets Out Options for International Law on Cyberspace: The Attorney General, Suella Braverman QC MP, set out in more detail the UK’s position on applying international law to cyberspace. She clarified that one of the response options available, to impose a cost on States carrying out irresponsible or hostile cyber activity, could include economic sanctions, restrictions on freedom of movement, exclusion from international groupings and wider diplomatic measures. (https://www.gov.uk/government/speeches/international-law-in-future-frontiers).

UPDATE:

May 18, 2022

  • UK Chancellor of the Exchequer Promises Further Sanctions: Answering a written question on an online platform on the effectiveness of sanctions, the UK’s Chancellor of the Exchequer wrote “We will go broader, we will go deeper, and we will close loopholes.” (https://www.theyworkforyou.com/wrans/?id=2022-05-10.204.h&s=finance).

UPDATE:

May 17, 2022

  • UK Officials Demand “Watertight” Legal Guarantees from Abramovich Over Chelsea Funds: UK government officials are demanding a “legally watertight” guarantee that Roman Abramovich will not lay claim to a roughly £1.5bn chunk of the proceeds from the sale of Chelsea Football Club, funds that have become a key source of tension that could scupper the planned deal. (https://www.ft.com/content/d24ef7cb-da0d-497d-b14e-d8fbcc88af24).

UPDATE:

May 16, 2022

  • Questions Raised About UK Arts Donations of Leonard Blavatnik: A UK freedom of information request shows that the links of Ukrainian-born benefactor Leonard Blavatnik, who was listed by the Sunday Times as the UK’s richest man, with sanctioned Russian oligarchs have been the subject of discussions at major UK cultural institutions, including the National Library of Scotland, particularly around sensitivities over Blavatnik’s donations to such institutions. (https://www.theguardian.com/culture/2022/may/16/questions-raised-about-uk-arts-donations-of-leonard-blavatnik).

UPDATE:

May 15, 2022

  • UK Considering Sanctions on National Bank Trust: On Saturday, The Guardian reported that the UK is considering sanctions on National Bank Trust, which is owned by the Russian Central Bank. In calling for an investigation, Christine Jardine, the Liberal Democrat Treasury spokesperson, said, “There are too many question marks around the National Bank Trust and whether it is, in fact, able to channel funds to the Putin regime… If it is, it must be sanctioned straight away.” (https://www.theguardian.com/world/2022/may/14/the-russian-bank-the-bruce-willis-ad-and-the-900m-sanctions-battle).

  • UK Supermarkets Still Selling Russian Whitefish: The Guardian reported on Saturday that UK supermarket chains like Sainsbury’s, Tesco, Morrisons and Asda are still selling Russian whitefish products, though Tesco and Asda are no longer buying from Russian suppliers. Russia accounts for 45 percent of the world’s whitefish supply, and the supermarkets reported difficulty in finding alternative sources for their products. The UK previously attempted to impose a 35 percent tariff on all Russian imports, including imported whitefish, but industry groups successfully blocked the proposal. (https://www.theguardian.com/business/2022/may/14/fish-fingers-containing-russian-whitefish-still-on-sale-across-uk).

UPDATE:

May 13, 2022

  • 12 Individuals Added to the UK Sanction List: In an attempt to hit Putin’s financial network and tighten the vice on the President and his inner circle, 12 individuals were added to the UK’s sanctions list on May 13, 2022. The individuals include Putin’s confidants and loyal supporters Alexander Plekhov, Mikhail Klishin and Vladimir Kolbin, as well as Alina Kabaeva, the Chair of the Board of the National Media Group who is rumoured to be Putin’s girlfriend. (https://www.gov.uk/government/news/uk-sanctions-the-shady-network-funding-putins-lavish-lifestyle).

View the Ukraine Crisis - UK Sanctions Archive

Share this article:

Facebook-square Linkedin-in Twitter Youtube
To stay up to date, subscribe here:
Subscribe to our email newsletter
Subscribe
Subscribe
Visit Mayer Brown:
www.mayerbrown.com

© 2022 Mayer Brown. All rights reserved.

Mayer Brown is a global service provider comprising associated legal practice that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) (collectively the “Mayer Brown Practices”) and non-legal service providers, which provide consultancy services (the “Mayer Brown Consultancies”). The Mayer Brown Practices and Mayer Brown Consultancies are established in various jurisdictions and may be a legal person or a partnership. Details of the individual Mayer Brown Practices and Mayer Brown Consultancies can be found in the Legal Notices section of our website.

“Mayer Brown” and the Mayer Brown logo are trademarks of Mayer Brown.

Attorney Advertising. Prior results do not guarantee a similar outcome.

“Mayer Brown” and the Mayer Brown logo are trademarks of Mayer Brown.

Attorney Advertising. Prior results do not guarantee a similar outcome.