Ukraine Crisis – UK Sanctions Update

Mayer Brown


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).


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/)


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)


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).


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).


June 22, 2022


June 21, 2022


June 20, 2022


June 19, 2022


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).


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).


June 15, 2022


June 14, 2022


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).


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).


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)


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).


June 7, 2022


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/).



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)


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)


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/).



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).


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).


May 30, 2022


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).


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).


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)


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).


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).


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).


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).


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).


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).


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).


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).


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).


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).


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).

Share this article: