Russia Sanctions Tracker - UK (2024-25)

OFSI Guidance: Threat Assessment - Property and Related Services

OFSI has published the third in a series of sector specific threat assessment reports addressing threats to UK financial sanctions compliance. The report outlines OFSI’s assessment of threats to sanctions compliance involving UK property and related services firms since February 2022.

The report provides information on suspected sanctions breaches and is intended to assist stakeholders with prioritisation as part of a risk-based approach to compliance.

Director disqualification sanctions – updated designations

Regulation 19B

UK Government Director Disqualification Guidance

The UK Government has varied the designations of 2,996 individuals and 818 entities across 28 UK autonomous and mixed sanctions regimes (including the Russia regime). These persons are now subject to director disqualification sanctions.

The power to designate persons for the purpose of disqualifying those persons from being a director of a company was introduced on 16 May 2024 (see entry below). Any persons so designated will be prohibited from acting as a director of a UK company or directly or indirectly take part in the management, formation or promotion of a UK company (Regulation 19B).

Enforcement: first criminal convictions for breach of UK sanctions

NCA press release

Two individuals have been convicted of breaches of Russian sanctions for the first time in the UK:

• Dmitrii Ovsiannikov, the former Russia appointed Governor of Sevastopol, was found guilty of circumventing sanctions regulations and money laundering after receiving £76,000 from his wife and a new Mercedes from his brother.
• His brother, Alexei Owsjanikow, was also found guilty of circumventing sanctions regulations, having made economic resources available to Dmitrii.

OFSI has published the second in a series of sector-specific threat assessment reports addressing threats to UK financial sanctions compliance. The report outlines OFSI’s assessment of threats to sanctions compliance involving UK legal services providers since February 2022.

The report provides information on suspected sanctions breaches and is intended to assist stakeholders with prioritisation as part of a risk-based approach to compliance.

General Licence: bond amendments and restructurings - amendment

INT/2023/2824812

 The General Licence has been extended until 27 March 2026.

General Licence: legal services - amendment

INT/2024/5334756

The General Licence was amended to clarify:

• That legal advice and/or representation in dispute resolution is included in the definition of "Legal Services"; and
• The reference to 'owned and controlled' applies only to companies and not individuals under the definition of "DP".

General Licence: Arbitration Costs

INT/2025/5787748

Publication Notice

This General Licence permits:

• payments to Arbitration Associations and Arbitrators to cover fees and expenses for their arbitration services;
• payments to representatives of DPs, including legal representatives, to cover Arbitration Costs;
• funds deposited with Arbitration Associations and Arbitrators by DPs prior to their designation to be used for Arbitration Costs; and
• Relevant Institutions to process the payments outlined above.

"Arbitrators" means individuals who are appointed to make a decision to determine a dispute.

"Arbitration Associations" means associations or registered bodies offering arbitration services to persons who wish to resolve a dispute out of court.

“Arbitration Costs” means Fees and expenses for services provided by Arbitrators and Arbitration Associations in relation to arbitrations.
Payments made under this Licence must not exceed £500,000 (including VAT where applicable) in total per arbitration.

The Licence is subject to notification and record-keeping requirements.

The licence takes effect from 28 March 2025. There is no stated expiry date.

General Licence: LCIA arbitration costs – revoked

INT/2022/1552576

The General Licence was revoked following the issuance of the Arbitration Costs General Licence (INT/2025/5787748) – see above.

General Licence: Lithuania rail - amendment

INT/2023/2883496

General Licence: regulatory authorities - amendment

INT/2022/1280976

The General Licence was amended so that it:

• applies to all persons designated under the UK's autonomous sanctions regimes listed in Annex 1 of the General Licence; and
• is extended indefinitely.

OFSI financial sanctions FAQs: new

OFSI has added 1 Frequently Asked Questions to its FAQs page:

• FAQ 145 was added which addresses the internal movement of funds regarding regulation 11.

Designation procedure: urgent procedure

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2025

In force: 18 April 2025

The Russia (Sanctions) (EU Exit) Regulations 2019 have been amended to include the "urgent procedure" for designations. In summary:

• The Secretary of State may choose whether to designate a person under the standard procedure or the urgent procedure.
• Under the standard procedure, the Secretary of State can designate a person if they have reasonable grounds to suspect that that person is an "involved person" (Condition A).
• Under the urgent procedure, the Secretary of State can designate a person where they do not have reasonable grounds to suspect that that person is an "involved person", but (i) they are designated by the US, the EU, Australia or Canada; and (ii) the Secretary of State considers that it is in the public interest (Conditions B and C).
• A person designated under the urgent procedure ceases to be so designated after 56 days unless the Secretary of State certifies that Condition A is met, or Conditions B and C continue to be met.

The urgent procedure was added to the Sanctions and Anti-Money Laundering Act to in March 2022 by the Economic Crime (Transparency and Enforcement) Act 2022. The procedure has now been added to 26 of the UK's sanctions regulations.

General licence: humanitarian activity - amendment

INT/2022/1947936

The General Licence was amended:

• Rosbank PJSC and Tinkoff Bank were removed from the list of "Designated Financial Institutions" in Annex I; and
• TBank was added to Annex I.

General Licence: Mongolia energy payments - amendment

INT/2022/2085212

 The Mongolia energy payments General Licence was amended:

• Rosbank PJSC has been removed from the definition of Sanctioned Banks; and
• TBank has been added to the definition of Sanctioned Banks.

Enforcement: OFSI monetary penalty

Penalty Notice

Press release

OFSI has issued a monetary penalty against the Russian branch of a law firm for breaches of UK financial sanctions imposed on Russia.

The monetary penalty relates to six payments made by the Russian branch with a collective value of £3,932,392.10 to designated persons, namely Alfa-Bank JSC, PJSC Sovcombank and PJSC Sberbank. The payments were made in connection with the firm's closure of its Russian branch.

As a result of these breaches, OFSI has imposed a penalty of £465,000.

 Asset freeze – removal

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Farkhad Akhmedov

General Licence: Petrol station payments for UK nationals in Kyrgyzstan and Tajikistan

INT/2025/5886860

Publication notice

This General Licence allows a UK national to purchase petrol from Gazprom Neft or any subsidiary (the DP) at any petrol station in Kyrgyzstan and Tajikistan that is either owned by the DP or sells the DP’s petrol, provided that the petrol is for that UK national's Personal Vehicle.

"Personal Vehicle" means any vehicle owned or rented by a UK national for the purpose of their personal travel and/or commuting.

The licence takes effect from 14 March 2025 and expires at 23:59 on 15 March 2027.

OFSI Guidance: High Value Dealers and Art Market Participants - factsheet, FAQs and webinar

 OFSI has released additional information and guidance for High Value Dealers (HVD) and Art Market Participants (AMP) to support them in navigating UK financial sanctions and new reporting requirements which apply from 14 May 2025. This includes:

• Online webinar which can be viewed at any time, providing an overview of sanctions guidance for the sector- accessible here
• Factsheet summarising key points of OFSI's guidance: accessible here
• FAQ's 132 to 144, in response to questions from industry, including letting agents and insolvency practitioners: accessible here
• Minor amendment to section 2.1 of OFSI's HVD and AMP guidance, providing additional clarification: accessible here

This guidance is of general application and is not limited to the Russia sanctions regime.

Asset freeze – removal

Two entities have been removed from the Russia financial sanctions regime and are no longer subject to an asset freeze or trust services sanctions:

• RosBank PJSC
• Active Denizcilik Ve Gemi Isletmeciligi Anonim Sirketi

Asset freeze – removal

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Francois Edouard Mauron

25 February 2025

OTSI guidance: Russian circumvention and evasion guidance – update

[Notice NTE 2025/03]

OTSI and the Department for Business and Trade have updated the guidance for UK exporters on countering Russian sanctions evasion and circumvention published on 7 January 2025 (Notice to exporters 2025/01).

The updated guidance provides additional information on the level of risk the government is willing to accept when assessing export licence applications for Common High Priority List items subject to export controls, where there is a lack of certainty regarding the end-use or end user (such as items destined for stock), and where there is assessed to be a risk of diversion to Russia.

24 February 2025

Asset freeze – additions

Press release

66 individuals and entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions. Those designated include:

• Actors linked to the Russian defence sector - 1 individual and 4 Russian state-owned entities
• Russia-based importers of dual-use goods and suppliers to the Russian defence sector - 3 individuals and 5 entities
• International enablers and suppliers to the Russian defence sector, based in a range of third countries including Central Asian states, Turkey, Thailand, India and China - 6 individuals and 16 entities
• DPRK officials involved in supporting Russian military action against Ukraine, including the North Korean Defence Minister – 5 individuals
• Russian Government officials – 2 individuals
• Actors involved in key Russian industries – 17 individuals and 7 entities

Asset freeze and correspondent banking and clearing

An entity been added to the consolidated list and is now subject to an asset freeze, trust services sanctions and a prohibition on correspondent banking and clearing:

• OJSC Keremet Bank

This is the first designation of a foreign financial institution linked to Russia.

Shipping specifications – additions

40 vessels have been specified under the Russia sanctions regime for their involvement in transporting Russian oil.

General Licence: Membership fees for International Organisations

INT/2025/5855272

Publication notice

This General Licence allows "International Organisations" to receive membership and other fees from Russia (Permitted Payments) transferred from an account held with Gazprombank (the DP). UK financial institutions are permitted to process such payments.

"International Organisations" means those international trade organisations based in the UK with recognised diplomatic status under international law, as listed in Annex 1 of the GL.

"Permitted Payments" means subscription fees and any other payments required from the Government of Russia to retain membership of the International Organisations.

The General Licence is subject to reporting and record-keeping requirements for International Organisations.

The licence expires at 11:59 pm on 20 February 2030.

G7 & EU Statement

 The G7 Foreign Ministers from Canada, France, Germany, Italy, Japan, the UK, the USA, and the EU convened at the Munich Security Conference and issued a joint statement.

In relation to future sanctions on Russia, they declared that "Any new, additional sanctions after February should be linked to whether the Russian Federation enters into real, good-faith efforts to bring an enduring end to the war against Ukraine that provides Ukraine with long-term security and stability as a sovereign, independent country."

Enforcement – HMRC sanctions enforcement information

HMRC has written to the Chair of the Treasury Select Committee in response to a request for information on HMRC sanctions enforcement-related issues arising from the oral evidence session the Committee held with the Office for Financial Sanctions Implementation (OFSI) on 26 November 2024.

The letter provides information about Russia-related investigations and enforcement by HMRC, as follows:

• The number of investigations opened by HMRC criminal investigators into potential sanctions offences from 2021-2024 is: 2021 – 0; 2022 – 14 (all of which relate to Russia sanctions); 2023 - 22 (20 of which relate to Russia sanctions); 2024 - 29 (27 of which relate to Russia sanctions).
• In the period 2021-2024, six companies have received compound settlements for breaches of Russia sanctions following HMRC investigations (details of which are set out in the letter). All the transactions involved the trade of nonmilitary industrial goods. The settlements were calculated in relation to the value of the goods that breached sanctions.
• HMRC currently has 30 live criminal investigations into breaches of sanctions, 27 of which relate to Russia sanctions. None of these investigations has yet reached the point of prosecution. In October 2024, one of the live investigations into a breach of Russia sanctions was referred to the CPS and is awaiting a charging decision.

14 February 2025

Asset freeze – additions

Three individuals and two entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions.

The individuals are:

• Artem Yuryevich Chaika
• Pavel Mikhailovich Fradkov
• Vladimir Viktorovich Selin

The entities are:

• Joint Stock Company Kirov Energomash Plant
• Limited Liability Company Rosatom Additive Technologies 

13 February 2025

OFSI Guidance: Threat Assessment - Financial Services

OFSI has published the first in a series of sector-specific threat assessment report addressing threats to UK financial sanctions compliance. The report outlines OFSI’s assessment of threats to sanctions compliance involving UK financial services firms since February 2022

The report provides information on suspected sanctions breaches and is intended to assist stakeholders with prioritisation as part of a risk-based approach to compliance.

General Licence: oil price cap - amendment

[INT/2024/4423849]

Publication notice

OFSI Guidance: UK Maritime Services Ban and Oil Price Cap

The Oil Price Cap General Licence has been amended to add the Combined Nomenclature (CN) / Harmonized System (HS) commodity code, 2710 19 44, which sits alongside 2710 19 42 under “Premium to Crude”.

OFSI has updated its industry guidance regarding the UK Maritime Services ban and oil price cap accordingly.

11 February 2025

Asset freeze – additions

The Cyber (Sanctions)(EU Exit) Regulations 2020

Press release 

6 individuals and 2 entities have been added to the consolidated list and are now subject to an asset freeze.

The individuals are:

• Aleksandr Sergeyevich Bolshakov
• Aleksandr Igorevich Mishin
• Ilya Vladimirovich Sidorov
• Dmitry Konstantinovich Bolshakov
• Igor Vladimirovich Odintsov
• Vladimir Vladimirovich Ananev

The entities are:

• ZSERVERS
• XHOST Internet Solutions LP

These designations have been made under the UK's cyber sanctions regime but relate to Russian individuals and entities linked to a cybercrime supply chain.

10 February 2025

Asset freeze – removal

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze:

• Irina Vladimirovna Chubarova 

30 January 2025

Asset freeze – removal

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Nikolay Ivanovich BORTSOV 

29 January 2025

General Licence: oil price cap - amendment

[INT/2024/4423849]

Publication notice

On 29 January, the Oil Price Cap General Licence was amended to update the Combined Nomenclature / Harmonized System commodity code for “Premium to Crude”, 2710 19 43, which now falls under 2710 19 42.

This change does not alter UK providers use of the General Licence in relation to the supply or delivery of this oil product, prior to or following the update.

27 January 2025

Belarus: Asset freeze – additions

Press release

3 entities and 6 individuals have been added to the consolidated list and are now subject to an asset freeze.

The entities are

• ALEVKURP OJSC
• KB Unmanned Helicopters
• Legmash Plant JSC

The individuals are:

• Andrei Valerievich ANANENKO
• Andrey Mikhailovich TSEDRIK
• Igor Vasilyevich KARPENKO
• Mikhail Petrovitch BEDUNKEVICH
• Pavel Ivanovich KAZAKOV
• Viktor Alexandrovich DUBROVKA

This list includes leaders of institutions responsible for human rights violations and companies in the Belarusian defence sector supporting Russia's war in Ukraine.

23 January 2025 

OFSI investigations: response to parliamentary question 

On 17 January 2025, Mark Garnier (Conservative MP) tabled the following parliamentary question to the Chancellor of the Exchequer:

"…how many investigations by the Office of Financial Sanctions Implementation into breaches of Russian sanctions (a) are open and (b) have been undertaken since February 2022."

On 23 January 2025, Emma Reynolds (Economic Secretary to the Treasury) responded:

"The Office of Financial Sanctions Implementation (“OFSI”) currently has 318 investigations open regarding potential breaches of The Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”).

Since February 2022, OFSI has investigated and closed 388 cases relating to potential breaches of the Russia Regulations." 

17 January 2025 

UK-Ukraine 100 Year Partnership - Declarations

Press release 

On 16 January 2025, the UK and Ukraine signed a 100 Year Partnership to deepen security ties and strengthen partnership for future generations.

The parties made the following declaration in respect of sanctions cooperation:

"We recognise the importance of sanctions in the context of limiting Russia’s access to finance, goods, technology and services that it uses in its aggression and ongoing violations of international law, including the UN charter and other international obligations, to reduce Russia’s revenues and deter future attacks. The UK commits to apply significant pressure on Russian revenues from energy and other commodities and take decisive action to combat sanctions circumvention. The UK commits to maintaining pressure until Ukraine prevails, Russia stops its violations of Ukraine’s sovereignty and territorial integrity, peace is secured, and Russia compensates Ukraine and victims for the damage it has caused. The UK will continue to work with its allies to pursue all lawful ways to use sanctioned Russian assets to support Ukraine and ensure Russia is made to meet its obligation to pay for the damage it has caused, in line with international law. We will also continue to work closely with our international partners to apply further economic pressure to Russia, recognising differences in our legislative frameworks." 

14 January 2025 

13 January 2025

OFAC-OFSI Memorandum of Understanding

OFSI has published the information-sharing Memorandum of Understanding (MOU) with the Office for Foreign Assets Control (OFAC) dated 9 October 2024. The MOU is said to enhance OFSI's and OFAC's collective ability to collaborate and share information, further fortifying their coordinated efforts in implementing and enforcing sanctions.

The MOU is not specific to Russian sanctions.

10 January 2025

Asset freeze – additions

Press release

Two entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• PJSC SURGUTNEFTEGAS
• GAZPROM NEFT

General Licence: Russian Oil Exempt Projects (Gazpromneft-Sakhalin LLC)
INT/2025/5635700

Publication notice

This General Licence allows for the continuation of business operations with Gazpromneft-Sakhalin LLC to the extent they are in relation to the 'Exempt Projects' (as defined in the licence – currently only the Sakhalin-2 project), including but not limited to:

• Payments to or from Gazpromneft-Sakhalin LLC or any third party under any new or existing obligations or contracts provided the payments are in relation to the Exempt Projects; and
• The processing made of payments in accordance with the above.

The permitted business operations are only permissible for the period from (and including) the 'Date of Application' to (and including) the 'Date of Expiration' for the relevant Exempt Project. For the Sakhalin-2 project, this period is 10 January 2025 28 June 2025.

The General Licence is subject to record-keeping requirements.

The General Licence takes effect from 10 January 2025 and has no expiration date.

General Licence: Russian Oil Majors Wind Down
INT/2025/5635701
Publication notice

[EXPIRED]

[THIS GENERAL LICENCE HAS NOW EXPIRED]

This General Licence permits a Person to wind down or divest from any transactions involving:

• Gazprom Neft;
• PJSC Surgutneftegas;or
• a 'Subsidiary' of either of the above (each a DP),

including the closing out of any positions, and a Person, a Relevant UK Institution, or a DP can carry out any activity reasonably necessary to effect this.

A 'Subsidiary' means any entity incorporated anywhere in the world owned or controlled, directly or indirectly, by Gazprom Neft and/or PJSC Surgutneftegas within the meaning of regulation 7 of the Russia Regulations.

The General Licence is subject to record-keeping requirements.

The General Licence takes effect from 10 January 2025 and expires at 05:01 on 27 February 2025.

8 January 2025

General Licence: Russian Banks (subsidiaries) – amendment
INT/2022/1280876

The General Licence has been amended to add Permission 5.3A which states that no distributions on VTB Bank PJSC’s claim should be made without first deducting from the distributions the value of any VTB Capital plc assets which have been or are subject to VTB Bank PJSC enforcement action, and the VTB Group Receivables; and statutory interest should not be paid for any time over which distributions are not paid because of these deductions.

7 January 2025

OTSI guidance: Russian sanctions circumvention

OTSI has published two guidance documents to support UK industry counter and combat current and emerging trends relating to Russian sanctions circumvention.

• Countering Russian Sanctions Evasion: this supports exporters to further understand circumvention practices, and develop strategies to reduce the risk of their goods being diverted to Russia.
• No-Russia Clause: this guidance is published to support businesses that seek to incorporate a ‘no re-export to Russia’ clause into export contracts.

17 December 2024

Asset freeze – addition

Shipping specifications – additions

Press release

Two entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• 2RIVERS DMCC
• 2RIVERS PTE LTD

In addition, 20 ships have been specified under the Russia sanctions regime. These specifications target Russia's shadow fleet, responsible for transporting oil and oil products.

9 December 2024

 Asset freeze - addition

1 individual has been added to the consolidated list and is now subject to an asset freeze and trust services sanctions:

• Anto JOSEPH

This designation was one of a number of designations targeting the illicit gold trade. The UK has also made related designations under its Global Anti-Corruption and DRC regimes. See the full list here.

5 December 2024

OFSI General Licences: various – revoked

The following General Licences have been revoked:

• FCA Payments - INT/2024/4836676 (publication notice)
• Payments to Companies House - INT/2023/3626884 (publication notice)
• Local Authorities Payments – INT/2023/3781228 (publication notice)
• Payments to Revenue Authorities - INT/2024/4881897 (publication notice)

These General Licences have been revoked because the new Required Payments Exception allows for certain payments to be made from, or on behalf of, non-UN designated persons to the authorities covered by these general licences, without the need for an OFSI licence.

25 November 2024

Asset freeze - addition

Shipping specifications – additions

Press release

Two entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• ALFASTRAKHOVANIE PLC
• VSK

In addition, 30 ships have been specified under the Russia sanctions regime. These specifications target Russia's shadow fleet, responsible for transporting oil and oil products.

OFSI Guidance: Oil Price Cap (OPC) Advisory

OFSI has issued an advisory regarding evasion linked to product origin manipulation through fabricated and falsified certificates of origin.

OFSI has identified instances where shipments of Russian origin oil and oil products have been manipulated to appear as non-Russian through the use of fabricated or falsified certificates of origin.

The advisory includes an overview of red flags to identify such activity and potential mitigation measures which may help UK entities protect themselves against this.

Asset freeze - additions
Press release

8 individuals and 2 entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• Serafim Vikentevich Ivanov
• Igor Kazarezov
• Valentina Vasilyevna Lavrik
• Nikita Vladimirovich Nagorny
• Andrey Sabinov
• Olena Oleksandrivna Shapurova
• Vitaliy Aleksandrovich Suk
• Tetiana Zavalska
• All-Russian Young Army Military Patriotic Social Movement (Yunarmia)
• Avangard

These designations target those involved in the Russian state’s forcible deportation and attempted indoctrination of Ukrainian children.

Shipping specifications – additions

Asset freeze – additions (Iran regime)

 The following ship has been specified under the Russia sanctions regime:

• PORT OLYA-3 (Unique ID:RUS2311)

2 entities have been added to the consolidated list under the UK's Iran regime and are now subject to an asset freeze:

• Islamic Republic of Iran Airlines
• The Islamic Republic of Iran Shipping Lines (IRISL)

Those specified/designated are involved in Iran’s military support to Russia, including the transfer of ballistic missiles and drones.

 Asset freeze – removal

One individual has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions:

• Didier Casimiro

14 November 2024

The Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024, part 15

In force from 3 December 2024 (for all amendments except one – see right)

Amendments to existing sanctions – various
OFSI blog entry

This instrument introduces the following changes to sanctions legislation (including the Russia Regulations):

• An expansion of the definition of relevant firms subject to financial sanctions reporting obligations to cover additional sectors – high value dealers, art market participants, insolvency practitioners and letting agencies. This change will come into force on 14 May 2025.
• Changing the existing requirements on relevant firms and involved persons to report suspected offences to a requirement to report suspected breaches of sanctions regulations.
• A requirement for all UK persons that hold funds or economic resources owned, held, or controlled by a designated person (DP), to provide an annual report to OFSI with the details of these assets.
• An amendment to the notification requirements on HM Treasury, the Department for Business and Trade (DBT), the Department for Transport (DFT), and the Insolvency Service when these persons issue, vary, suspend or revoke a specific sanctions licence.
• Legislative changes to the licensing and exceptions provisions in sanctions legislation. This includes an amendment to the pre-existing judicial decisions licensing purpose, the creation of a new insolvency licensing purpose and a new required payments exception. These changes do not apply in relation to UN regimes.
• New civil monetary penalty powers for breaches in relation to Russia land prohibitions.
• Updating the definition of designated person in Treasury licences schedules and exceptions provisions of sanctions regulations to confirm that this includes persons owned or controlled by named DPs.
• An amendment to certain asset freeze prohibitions to explicitly apply to persons owned or controlled by named DPs.
• An amendment to regulations 18C and 71 of the Russia regulations to clarify that acting as a nominee shareholder, when that involves the use of a trust or similar arrangement, should be considered a prohibited trust service.
• An amendment to the 'Disclosure to the Treasury' provisions in most financial sanctions regulations to clarify the scope of the Treasury’s functions in connection with sanctions.
• A modification to reporting requirements in relation to the assets of prohibited persons listed in regulation 18A of the Russia Regulations.

The majority of these changes have been made across all of the UK's sanctions regimes.

OFSI/UK Government Guidance: updates
Financial sanctions guidance for Russia

OFSI financial sanctions FAQs: new

OFSI has added 1 Frequently Asked Questions to its FAQs Page:

• FAQ 124 can be found under General. It concerns the effect the Russian Decree 840, which has moved equities held at the Russian National Settlement Depository (NSD) to local registrars.

The General Licence permits UK-regulated financial institutions to process payments made in the year 2022 from or via a designated Russian credit or financial institution (a Relevant Payment), provided that the original sender and original intended recipient are not Designated Persons, subject to certain conditions set out in the General Licence.
"Relevant Payment" means a payment;

•  which has been received and blocked by a Relevant Institution which is not a Designated Person or a Designated Credit or Financial Institution; and
• which was first received by any credit or financial institution from the Original Sender, between 1 January 2022 and 31 December 2022 (inclusive); and
• which has, at some point in the chain of payments, been processed by a Designated Credit or Financial Institution acting as an originating, correspondent or intermediary institution; and
• where both the Original Sender, and the Original Intended Recipient of the payment are not Designated Persons.

UK-regulated financial institutions may undertake any activity required in order to process such a payment, including making interest payments.
The General Licence is subject to reporting and record-keeping requirements.
The General Licence takes effect from 7 November 2024 and expires at 23:59 on 6 November 2025.

OFSI financial sanctions FAQs: new

OFSI has added 14 Frequently Asked Questions to its FAQs Page:

• FAQs 49-51 relate to changes to fees and expenses caps in Part A and B of General Licence [INT/2024/5334756] effective from 29 October 2024 and amendments to the definition of Counsel.
• FAQ 55 is in relation to providers of legal advice being UK regulated Counsel, UK regulated law firms or receive payment into a UK bank account.
• FAQ 61 relates to General Licence [INT/2024/5334756] extension to in-house Counsel if they have a bank account in the UK to receive payments.
• FAQs 62-66 relates to General Licence [INT/2024/5334756], £2,000,000 fee cap that applies to all legal professionals, trainee legal professionals and directly instructed Counsel for the duration of the General Licence, however expenses are not included.
• FAQs 72-73 relates to the cap for expenses being up to 10% of the total professional legal fees and Counsel's fees paid or £200,000, whichever is lower, per law firm or directly engaged Counsel instructed and additional expenses requiring a specific licence application to OFSI.
• FAQ 76 relates to where reporting forms can be found.
• FAQ 84 relates to OFSI permitted payments into non-UK bank accounts provided the accounts are in branches of UK-regulated law firms for legal services provided to a Designated Person located in Canada, the EU, EFTA member states, or the US.

Asset freeze – addition

Press release

16 individuals and 31 entities have been added to the consolidated list and are now subject to an asset freeze and trusts services sanctions:

These designations target Russia's military industrial complex, including suppliers involved in the supply and production of goods including machine tools, microelectronics and components for drones, and individuals associated with Russian proxies.

The UK has also made related designations across its Central African Republic, Chemical Weapons, Libya, and Mali regimes, targeting Russian-backed mercenary groups operating in Sub-Saharan Africa and a GRU agent involved in the use of a Novichok nerve agent in Salisbury. See the full list here.

Enforcement – HMRC compound settlement

Notice NTE2024/29

HM Revenue and Customs (HMRC) has issued a compound settlement offer to a UK exporter regarding the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.

In August 2024, £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.

Since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million.

General Licence: Legal Services – (new

[INT/2024/5334756]

Publication notice

The previous licence in legal services (INT/2024/4671884) has expired and OFSI has issued a new licence on legal services which permits:

• A UK legal firm or UK counsel who has provided legal advice to a person designated under either the Russia or Belarus regime to receive payment from that designated person without an OFSI specific licence, provided that the terms of the General Licence are met. The conditions are found in Part A and B of the licence. Part A and B can be used separately or in conjunction.
• Any payments received under general licence must be reported to HM Treasury within 14 days of the payment being received.
• A designated person must keep accurate, complete and readable records, on paper or electronically, of any activity purportedly permitted under this licence for a minimum of 6 years.

The main changes from previous licences on legal services include the following:

• Legal fees are capped at £2,000,000.00 inclusive of VAT and expenses caps have been revised and reset. These caps apply to each law firm instructed by the designated person to cover all matters on which the firm is instructed.

• OFSI has introduced a restricted permission to pay into non-UK bank accounts. The funds will still have to satisfy the other relevant conditions of the general licence.

• Caps apply to all in-house lawyers employed by a designated person and also apply to directly instructed Counsel.

The licence took effect from 00:001 on 29 October 2024 and expires at 23:59 on 28 April 2025.

This General Licence has been amended – please see entry at 28 March 2025.

General licence: Payments to Utility Companies for Gas and Electricity – amendment

[INT/2022/2300292]

Publication Notice

On 29 October 2024, General Licence INT/2022/2300292 was amended to:

• Make clear that the definition of UK DPs includes entities owned or controlled by a designated individual or entity; and excludes those designated for the purpose of compliance with United Nations obligations.
• Add heating and/or hot water powered by gas or electricity from an external source such as through a district heating network; and meters related to district heating networks to the “Permitted Payments” definitions section.
• Update the reference to the Energy Bills Discount Support Scheme (EBDS) in the “Return Payments” definitions section.
• Update the list of the UK Autonomous Sanctions Regulations Schedules contained within Annex 1 so that all the relevant Regulations are included.

This General Licence applies to all UK Autonomous Sanctions Regulations.

Asset freeze – additions

Press release

3 entities and 3 individuals have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• ANO DIALOG
• SOCIAL DESIGN AGENCY
• STRUCTURA NATIONAL TECHNOLOGIES
• Ilya Andreevich GAMBASHIDZE
• Andrey Naumovich PERLA
• Nikolai Aleksandrovich TUPIKIN

These persons have been designated for their involvement in the online network commonly known as Doppelganger, which is responsible for spreading disinformation regarding the war in Ukraine.

Price Cap Coalition – updated maritime advisory

The Price Cap Coalition, which includes G7 countries as well as the European Union, Australia, and New Zealand, has updated its advisory for both government and private sector actors involved in the global maritime industry. The advisory provides recommendations concerning specific best practices and reflects the Coalition’s ongoing commitment to promoting responsible practices in the industry, disrupting sanctioned trade, and enhancing compliance with the price cap.

The Coalition originally published its advisory on 12 October 2023. This update provides stakeholders with new recommendations on meeting international obligations, enhancing due diligence around tanker sales, avoiding interactions with sanctioned counterparties, and raising internal awareness.

G7 Leaders Guidance – Preventing Russian Export Control and Sanctions Evasion

The G7 Sub-Working Group on Export Control Enforcement has published joint guidance on the following:

• A list of items which pose a heightened risk of being diverted to Russia,
• Updated red flag indicators of potential export control and/or sanctions evasion,
• Best practices for industry to address these red flags, and
• Screening tools and resources to assist with due diligence.

The guidance is to help prevent the diversion of controlled items to Russia, including through third countries.

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Semyon Mkrtychovich SIMONYAN (Group ID: 16246)

Shipping specifications – additions

Asset freeze - addition

The following ships have been specified under the Russia sanctions regime:

• ANTAEUS (IMO 9299733)
• ARTEMIS (IMO 9317949)
• ATLAS (IMO 9413573)
• AZURE CELESTE (IMO 9288722)
• CALLISTO (IMO 9299692)
• EASTERN PEARL (IMO 9285859)
• KUDOS STARS (IMO 9288710)
• MOSKOVSKY PROSPECT (IMO 9511521)
• NS ARCTIC (IMO 9413547)
• SAI BABA (IMO 9321691)
• SCF BAIKAL (IMO 9422457)
• SCF SAMOTLOR (IMO 9421972)
• SEA FIDELITY (IMO 9285835)
• STRATOS AURORA (IMO 9288708)
• SUVOROVSKY PROSPECT (IMO 9522324)
• TURBO VOYAGER (IMO 9299898)
• VARUNA (IMO 9332810)
• NS BORA (IMO 9412335)
• EVEREST ENERGY (IMO 9243148)
• MARSHAL VASILEVSKIY (IMO 9778313)
• MULAN (IMO 9864837)
• VELIKIY NOVGOROD (IMO 9630004)

The following entity has been added to the consolidated list and is now subject to an asset freeze:

• RusGazDobycha JSC

Those specified/designated are part of/involved in Putin's shadow fleet of oil tankers which seek to circumvent sanctions on Russian oil and liquid natural gas.

General Licence: Government Debt Payments - new

[INT/2024/5294388]

Publication notice

OFSI have issued a new general licence which applies to all UK Autonomous Sanctions Regulations (see Annex I of the GL), including the Russia regime.

The licence allows Persons to make and facilitate payments in respect of UK Government Debt where either the legal holder or the direct or indirect recipient or beneficiary of that payment is a UK DP or UK Prohibited Person provided the payments are held in Frozen Accounts or UK Prohibited Persons Accounts.

"Relevant Payments" mean payments by the UK Government under or in respect of UK Government Debt to either the legal holder of that UK Government Debt or the direct or indirect beneficiary of that where the recipient of those payments is a UK DP or UK Prohibited Person.

The licence also establishes reporting and record keeping requirements. Please consult paragraphs 7 and 8 of the licence for the full terms.

The licence took effect from 00:01 on 14 October 2024 and has no expiry date.

The Office of Trade Sanctions Implementation (OTSI) – legislation now in force

Press release

Following legislation laid before Parliament on 12 September 2024, OTSI is now is now operational. Various further guidance has been published on OTSI's website.

See entry below on 12 September for more details. This update applies to all UK trade sanctions.

Asset freeze – additions

The Chemical Weapons (Sanctions) (EU Exit) Regulations 2019

Press release

1 individual and 3 entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:

• Igor Anatolyevich Kirillov
• Radiological Chemical and Biological Defence Troops Of The Ministry Of Defence Of The Russian Federation
• 33 Scientific Research And Testing Institute
• Russian Ministry Of Defence 27th Scientific Centre

These designations have been made under the UK's Chemical Weapons Sanctions Regime. These designations target Russia’s Radiological Chemical and Biological Defence (CBR) troops, and their commander for the deployment of chemical weapons in Ukraine. Also sanctioned are two Russian Ministry of Defence laboratories for providing support for the development and deployment of these weapons for use on the frontlines.

1 October 2024

 Asset freeze – additions

The Cyber (Sanctions)(EU Exit) Regulations 2020

Press release

16 individuals have been added to the consolidated list and are now subject to an asset freeze.

These individuals are members of prolific Russian cyber-crime gang Evil Corp. Evil Corp’s malicious cyber activity involved a concerted effort to compromise UK health, government and public sector institutions

This designations have been made under the UK's cyber sanctions regime.

General Licence: Payment to Water Companies for Water & Sewage - updates

[INT/2023/3179120]

 The General Licence has been updated as follows:

• The definition of UK Designated Persons(DPs) was amended to: "Those individuals or entities designated (or owned or controlled by an individual or an entity designated) for the purposes of an asset freeze by the UK under the UK Autonomous Sanctions Regulations, excluding those designated for the purpose of compliance with United Nations obligations."
• The definition of Return Payments was amended to: "A payment payable by a Water Company to a UK DP in connection with water and/or sewerage services to a UK property owned or rented by the DP and arising from: an overpayment by the DP, a credit on the account of the DP, a billing adjustment (whether or not as a result of error) by the Water Company, termination of the services."
• The validity of the General Licence is now indefinite.

OFSI financial sanctions FAQs: new

 OFSI has added 2 Frequently Asked Questions to its FAQs page:

• FAQ 121 can be found under the General licensing section, regarding General licence INT/2024/4919848.

• FAQ 122 can be found under the under Trust services sanctions heading.

30 September 2024

Applies from 31 October 2024

Removal of licencing considerations: intra-corporate services

NTE 2024/26

Following a review of the professional and business services sanctions in place under Regulation 54C of the Russia Sanctions Regulations, the government has decided to remove the licensing consideration which relates to the provision of such services from UK parent companies and their UK subsidiaries to their Russian subsidiaries.

From 31 October 2024, the provision of intra-corporate services will no longer be listed in the Statutory Guidance as a licensing consideration that is likely to be consistent with the aims of the sanctions regime.

The Secretary of State maintains the discretion to grant licences even where no licensing consideration exists, as per Regulation 65 of the Russia Sanctions Regulations. This means that any company that wishes to provide intra-corporate services to their Russian subsidiary must explicitly demonstrate how the provision of any ongoing services aligns with the overarching purposes of the sanctions, as set out in Regulation 4 of the Russia Sanctions Regulations.

Businesses will be able to apply for a licence using the licensing considerations for activities listed in the guidance.

Licensing applications submitted before 31 October 2024 will not be affected by this Notice.

27 September 2024

 Enforcement: OFSI Monetary Penalty

OFSI has issued a monetary penalty to a property management for breaches of the financial sanctions regime imposed on Russia in response to its illegal invasion of Ukraine in 2022.

As a result of these breaches, OFSI imposed a penalty of £15,000. The company did not challenge the penalty and paid in full.

26 September 2024

 Asset freeze: additions

The following entities have been added to the Russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions:

• OCEAN SPEEDSTAR SOLUTIONS OPC PVT LTD

• WHITE FOX SHIP MANAGEMENT FZC

 Shipping specifications - additions

The following ships have been specified under the Russia sanctions regime:

• ASYA ENERGY (IMO 9216298)
• PIONEER (IMO 9256602)
• NORTH SKY (IMO 9953523)
• SCF LA PEROUSE (IMO 9849887)
• NOVA ENERGY (IMO 9324277)

Those specified/designated are involved in the Russian Liquified Natural Gas (LNG) sector. This action builds on efforts alongside allies to bear down on Russia’s attempts to bolster its future energy revenues.

18 September 2024

Export Enforcement Five: joint statement

Representatives from the United States, Australia, Canada, New Zealand, and the United Kingdom, collectively known as the Export Enforcement Five, gathered in Washington, D.C. on September 17 and 18, 2024, and reaffirmed their commitment to combatting Russia’s circumvention of export controls and sanctions in attempts to obtain dual-use items to support its illegal invasion of Ukraine.

12 September 2024

Trade sanctions – new enforcement powers and the Office for Trade Sanctions Implementation (OTSI)

The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024

Statutory guidance

The UK government has laid a new Statutory Instrument in Parliament – The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024. These regulations were made under the Sanctions and Anti-Money Laundering Act 2018.

The legislation confers powers on the Secretary of State for enforcing trade, aircraft and shipping sanctions and related requirements. The Secretary of State for the Department for Business and Trade (DBT) and the Department for Transport (DfT) respectively will be responsible for the exercise of relevant enforcement powers. In practice, DBT, through the Office of Trade Sanctions Implementation (OTSI), will lead on civil enforcement in relation to trade sanctions that fall within its remit. DfT will lead on civil enforcement in relation to aircraft and shipping sanctions.

In summary:

• Timing: The legislation comes into force on 10 October 2024.

• Monetary Penalties: The Secretary of State is empowered to impose monetary penalties on individuals or entities that breach prohibitions or fail to comply with obligations under sanctions regulations. The penalties can be imposed based on the balance of probabilities.

• Calculation of Penalties: The maximum penalty for trade sanctions is the greater of £1,000,000 or 50% of the estimated value of the breach. For aircraft and shipping sanctions, the maximum penalty is the greater of £1,000,000 or 50% of the estimated value of the aircraft or ship involved in the breach

• Strict liability: Where a civil monetary penalty can be imposed for a breach of a prohibition or a failure to comply with an obligation, such breaches or failures to comply will be determined on a ‘strict liability’ basis.

• Liability of Corporate Officers: Corporate officers, including directors and managers, can be held personally liable for breaches committed by their organizations if the breach occurred with their consent, connivance, or due to their neglect

• Reporting Obligations: Relevant persons must report to the Secretary of State if they know or suspect a breach of trade sanctions regulations. Failure to do so can be a criminal offence.

This legislation applies to all UK trade sanctions.

OTSI: Guidance

OTSI has issued a number of policy papers/guidance:

• New civil enforcement powers on trade sanctions
• Trade sanctions: civil enforcement
• Information you must provide in response to a trade sanctions information request
• Mandatory reporting for suspected breaches of trade sanctions
• How suspected breaches of trade sanctions are assessed by the Office of Trade Sanctions Implementation (OTSI)
• Appealing a civil monetary penalty for a breach of trade sanctions
  

11 September 2024

Shipping specifications - additions

The following ships have been specified under the Russia sanctions regime:

• Nikolay Zuyev (IMO 9610781)
• NS Clipper (IMO 9341081)
• NS Corona (IMO 9341079)
• Zaliv Aniva (IMO 9418494)
• Olympiysky Prospect (IMO 9511387)
• Leonid Loza (IMO 9412347)
• NS Asia (IMO 9413561)
• SCF Baltica (IMO 9305568)
• Vladimir Tikhonov (IMO 9311622)
• SCF Vankor (IMO 9316127)

These sanctions target Russia’s 'shadow fleet' which uses illicit practices to avoid UK and G7 sanctions on Russian oil.

10 September 2024

Asset freeze – additions

The following entities have been added to the Russia financial sanctions regime and are now subject to an asset freeze:

• 924th State Centre for Unmanned Aviation;
• Command of the Military Transport Aviation; and
• Russian Aerospace Forces.

Those designated are key organisations involved in Iran’s military support to Russia, including those involved in ballistic missile and drone supply chains.

Shipping specifications - additions

The following ships have been specified under the Russia sanctions regime:

• Baltinskiy (IMO 7612448)
• Begey (IMO 8943210)
• Musa Jalil (IMO 8846814)
• Omskiy-103 (IMO 8889385)
• Skif-V (IMO 8858087)

Those specified are key ships involved in Iran’s military support to Russia, including those involved in ballistic missile and drone supply chains.

6 September 2024

General Trade Licence: Russia sanctions: Legal Advisory Services – revoked

See also Notice to exporters 2024/21

The general trade licence has been revoked following a change to the Russia Sanctions Regulations, which meant it was no longer required (see the entry below regarding The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2024).

UK Government guidance: Providing professional and business services to a person connected with Russia – update

The guidance on providing professional and business services to a person connected with Russia has been updated to reflect the legislative changes to Regulation 54D (see entry below).

5 September 2024

The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2024

In force from 6 September 2024

Legal Services - amendment

(amendment to Regulation 54D, 60DB and Schedule 3J)

The definition of "legal advisory services" in Schedule 3J has been amended to extend the exclusions to the definition. The exclusions now include

• legal representation, advice, preparation of documents or verification of documents in relation to contentious proceedings in any jurisdiction; and
• the provision of legal advice or other services in connection with the management of claims under a contract of insurance or reinsurance.

The restriction on providing legal services under regulation 54D has been amended so that legal services cannot be provided to a non-UK person where the object or effect of those services is to enable or facilitate certain financial or trade activity which would be prohibited under the UK sanctions regime if the activity was done by a UK person or taking place within the UK. The amendment also removes the defence for those who contravene the prohibitions on providing legal services.

The exceptions relating to legal advisory services in regulation 60DB have been expanded so that more activities are permitted. Notably, the restrictions on legal services do not apply to acts which provide legal advisory services in relation to:

• the discharge of or compliance with UK statutory or regulatory obligations; or

• compliance with, or the consequences of non-compliance with, any relevant law; the discharge of obligations under any relevant law; or the potential or actual application of punitive measures.

"punitive measures" mean any sanction which may be applied by a country in relation to a person (“P”) in retaliation for P engaging, or proposing to engage, in conduct which would render P liable to penalties under the law of that country if P were subject to its jurisdiction.

"relevant law" means—
(a) any sanction, imposed by any jurisdiction;
(b) any law of Russia that has as its primary object or effect the frustration of any sanctions referred to in paragraph (a), or
(c) any criminal law imposed by any jurisdiction;

"sanction" includes any export or import control or other restrictive measure.

1 September 2024

Russian diamonds processed in third countries – restriction comes into effect

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2024

Chapter 4JC

The second element of the restrictions on Russian diamonds processed in third countries introduced in March 2024 comes into effect from 1 September.

From this date, the existing restrictions now apply to any Russian diamonds processed in a third country which are equal to or larger than 0.5 carats (see Regulation 46Z16Q).

For further details, see the entry below for 1 March 2024 (The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2024) came into effect on 1 March 2024 and inserted provisions into Chapter 4JC of the Russia (Sanctions) (EU Exit) Regulations 2019.

General Trade Licence – Russian diamonds processed in third countries - amendment

To reflect the change outlined above, the Department for Business and Trade has updated the General Trade Licence which provides authorisation for diamonds originating in Russia to be processed in a third country ("relevant processed diamonds"). The licence makes it a condition that:

• the relevant processed diamond is equal to or larger than 1 carat; (ii) any diamond processed to produce the relevant processed diamond has not been located in Russia at any time beginning with 1 March 2024; and (iii) the relevant processed diamond has not been located in Russia at any time beginning with 1 March 2024.; or
• the relevant processed diamond is equal to or larger than 0.5 carats and smaller than 1 carat; (ii) any diamond processed to produce the relevant processed diamond has not been located in Russia at any time beginning with 1 September 2024; and (iii) the relevant processed diamond has not been located in Russia at any time beginning with 1 September 2024.

This General Trade Licence took effect from 1 March 2024 and has no expiry date.

UK Government guidance: Russia sanctions guidance - update

The Russia sanctions guidance has been updated to reflect the above legislative changes and resulting changes to the General Trade Licence – Russian diamonds processed in third countries.

UK Government Guidance: third country processed Russian diamonds measures - update

The guidance on third country processed Russian diamonds has been updated to reflect the above changes.

9 August 2024

General Licence – East-West United Bank – Insolvency related payments and activities – new

[INT/2024/5028385]

Publication notice

OFSI have issued a new general licence which permits any Person to make, receive or progress any payments or other action, in connection with the insolvency proceedings of East-West United Bank ("EUWB").

The General Licence provides that:

• any Person (including EWUB and an Insolvency Practitioner) may make, receive or process any payments, or take any other action, in connection with the insolvency proceedings; and
• except for the payment distributions to DP Creditors or Shareholders into Frozen Accounts, no funds or economic resources shall be made available to or for the benefit of a person designated under the Russia Regulations including any entity owned or controlled by such a person, except for EWUB.
• a Relevant Institution may process payments made in accordance with the above.

There are notification and record keeping requirements associated with this licence. Please consult paragraphs 6 and 7 of the licence for details on this.

The licence took effect from 9 August 2024 and expires at 23:59 on 8 August 2029.

5 August 2024 

THIS GENERAL LICENCE WAS REVOKED ON 05 DECEMBER 2024

The General Licence has been amended to add a permission to the list of Permitted Payments:

• The payment of fees owed by or due from UK DPs to Local Authorities or Business Improvement of District levies

2 August 2024 

General Licence – National Settlement Depository - amendment

[INT/2024/4919848]

Publication notice

29 July 2024

The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2024

In force from 31 July 2024

[These amendments replicate amendments made by The Russia (Sanctions) (EU Exit) (Amendment) (No 2) Regulations 2024. The No.2 Regulations were not approved by Parliament within the required period and have therefore been revoked and replaced by these regulations.]

Asset freeze designation criteria - additions

(amendment to Regulation 6)

The criteria for designation under the UK's Russia regime have been extended as follows:

• The categories of persons who can be designated as the subject of an asset freeze have been expanded to include persons who own or control; or are working as a director/manager/trustee or equivalent of; or have the right to nominate/appoint at least one director to, persons in the existing categories of persons.
• The definition of being “involved in obtaining a benefit from or supporting the Government of Russia” has been expanded to include providing financial services, or making available funds, economic resources, goods or technology, to a person who falls within the existing definition.
• The definition of a person who is involved in “destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine” or “obtaining a benefit from or supporting the Government of Russia” has been expanded to include a person providing financial services, or making available funds, economic resources, goods or technology, to a person who falls within the existing definition.

Ships: specification of ships

(amendment to Regulation 57F)

The criteria for the specification of ships for the purpose of the existing prohibitions on ships has been expanded to include ships carrying:

• dual-use goods or military goods;
• oil and oil products that originated in Russia; or
• any other goods or technology that could contribute to destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine,

between Russia, a third country and/or non-government controlled Ukrainian territory.

24 July 2024 

General Licence - Continuation of Business of Evraz Plc’s North American Subsidiaries – amendment

[INT/2022/1710676]

Publication notice

The General Licence has been amended to extend its expiry. The licence will now expire at 23:59 on 31 March 2025.

23 July 2024 

General Licence - Russian Banks – UK / Guernsey / EU subsidiaries - Basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments – amendment

[INT/2022/1280876]

Publication notice

18 July 2024

UK Financial Sanctions FAQs – additions

OFSI has added 7 Frequently Asked Questions (FAQs) to its FAQs page:

• FAQs 92-97 relate to the Russia trust services sanctions and can be found under the Russia section)
• FAQ 98 relates to General Licence INT/2024/4919848 and can be found under the General Licensing section.

Shipping sanctions – new specifications

The following ships have been specified under the Russia Sanctions regime:

• Rocky Runner (IMO 9288899);
• Dynamik Trader (IMO 9286657);
• Fighter Two (IMO 9296391);
• SCF Amur (IMO 9333436);
• SCF Pechora (IMO 9333424);
• Zaliv Amurskiy (IMO 9354313);
• NS Lotus (IMO 9339337);
• NS Commander (IMO 9306794);
• Adygeya (IMO 9292204);
• Korolev Prospect (IMO 9826902); and
• Primorsky Prospect (IMO 9511533)

The ships have been specified for their involvement in activity whose object or effect is to destabilise Ukraine or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine or to obtain a benefit from or support the Government of Russia. Notably, the ships were involved in carrying oil or oil-related products that originated in Russia from Russia to a third country.

A specified ship is prohibited from being provided with access to or having its master or pilot cause it to enter a port in the UK, may have its registration on the UK Ship Register terminated, and a master or pilot of a specified ship may be given a port barring direction, a detention direction, and a port entry direction or a movement direction.

3 July 2024 

General Licence - Sale, divestment and transfer of financial instruments held by the National Settlement Depository and payment of safe keeping fees to the National Settlement Depository - new

[INT/2024/4919848]

Publication notice

OFSI have issued a new general licence which permits activities which are reasonably necessary for the sale, divestment or transfer of financial instruments held at the National Settlement Depository (NSD) and the payment of Safe Keeping Fees.

"Safe Keeping Fees" are fees paid to the DP to hold the DP Held Financial Instruments

"DP Held Financial Instruments" means debt and equity securities (private and government issued) and financial instruments including global depository receipts issued in respect of those securities which the DP holds as the Russian Central Securities Depository or are registered at the DP.

The licence took effect on

3 July 2024 and will expire at 11:59 on 13 August 2024.

3 July 2024 

General Licence – Payments for Visa Application Services - new

[INT/2024/4907888]

Publication notice

OFSI have issued a new general licence which applies to all UK autonomous sanctions regimes (see Annex I of the GL), including the Russia regime

The licence permits certain payments to Visa Application Services Providers from a Designated Person (DP), or on behalf of a DP, including for courier services, appointments and photo, ID, and biometric scanning fees.

"Visa Application Services Providers" are companies authorised and contracted by the Home Office to provide visa application services around the world on behalf of UK Visas and Immigration division.

The licence also establishes reporting and record keeping requirements. Please consult paragraphs 7 and 8 of the licence for the full terms.

The licence took effect from 3 July 2024 and has no expiry date.

1 July 2024 

[THIS GENERAL LICENCE WAS REVOKED ON 05 DECEMBER 2024]

OFSI have issued a new general licence which applies to all UK autonomous sanctions regimes (see Annex I of the GL), including the Russia regime.

The licence permits certain payments to be made to the Revenue Authorities by a UK Designated Person (DP), or on behalf of a DP.

"Permitted Payments" are any payments owed by or due from UK DPs to the Revenue Authorities, either at the point of, or after, their designation, including tax, duty, national insurance contributions, penalties or interest.

The licence also establishes reporting and record keeping requirements. Please consult paragraphs 7 and 8 of the licence for the full terms.

The licence took effect from 00:01 on 1 July 2024 and has no expiry date..

28 June 2024

General Licence – Oil Price Cap: Exempt Projects and Countries -amendment

[INT/2022/2470156]

Publication notice

The General Licence has been amended to extend the expiration date of the Schedule 1 Exempt Projects (the Sakhalin-2 Project) to 28 June 2025.

;27 June 2024 

General Licence – Payments for Statutory Audits – new

[INT/2024/4888228]

Publication notice

OFSI have issued a new general licence which applies to all UK autonomous sanctions regimes (see Annex I of the GL), including the Russia regime.

The licence permits payments to Statutory Auditors for a Statutory Audit from a Designated Person (DP), or on behalf of a DP. It also establishes reporting and record keeping requirements. Please consult paragraphs 7 and 8 of the licence for the full terms.

"Permitted Payments" include any remuneration receivable by Statutory Auditors for the Statutory Audit of accounts following the Statutory Auditor's appointment.

The licence took effect from 00:01 on 27 June 2024.

25 June 2024

Asset freeze - removal

 One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Aleksei Nikolaevich Filippovskii

20 June 2024

Publication notice

[REVOKED]

[THIS GENERAL LICENCE WAS REVOKED ON 05 DECEMBER 2024]

OFSI have issued a new general licence which applies to all UK autonomous sanctions regimes (see Annex I of the GL), including the Russia regime.

The licence permits payments to the Financial Conduct Authority (FCA) from a designated person or on behalf of a designated person.

"permitted payments" include:

• payments a UK designated person is required to make to the FCA under or by virtue of any enactment;
• a payment of a levy by the scheme manager of the Financial Services Compensation Scheme under section 213 of the Financial Services and Markets Act 2000; and
• a payment collected by the FCA on behalf of the Financial Reporting Council

The licence took effect from 00:01 on 20 June 2024.

13 June 2024

Asset freeze – additions

Press release

7 individuals and 35 entities have been added to the Russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions, including:

• PJSC Moscow Exchange Group (i.e. the Moscow Stock Exchange)
• PJSC SPB Exchange (i.e. the Saint Petersburg Stock Exchange)
• JSC National Settlement Depository
• Central Counterparty National Clearing Centre
• suppliers of munitions, machine tools, microelectronics, and logistics to Russia’s military, including entities based in China, Israel, Kyrgyzstan and Türkiye
• ships which transport military goods from North Korea to Russia
• vessels used by Russia to circumvent UK and G7 sanctions in respect of Russian oil

31 May 2024

General Licence - Russian Banks UK/EU/Guernsey subsidiaries - Basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments - amendment

[INT/2022/1280876]

Publication notice

The General Licence has been amended to permit a scheme of arrangement prepared by the Joint Administrators of VTB Capital plc.

Please consult paragraphs 5.3(a) to 5.7 of the licence for full details of the new definitions and permissions associated with this amendment.

The expiry date of the General Licence has also been extended to 23:59 on 03 April 2030

General Licence – Funds of non-designated third parties involving designated credit or financial institutions ("Personal Remittances") - new

[INT/2024/4761108]

Publication notice

OFSI have issued a new General Licence which permits:

• a Person to make use of the retail banking services of a designated Credit or Financial Institution provided that the payments made or received are intended for the personal use of
• a Person and do not exceed a total value of £50,000 in the period from the date of issue of the licence to its expiry (inclusive); and
• a Relevant Institution to process payments made by the Person provided that the total value of such payments from the date of issue to the expiry of the licence (inclusive) do not exceed £50,000.

A "Person" is an individual other than an individual designated under Regulation 5 of the Russia.

The General Licence also establishes reporting and record keeping requirements for the Relevant Institutions. Please consult the General Licence for the full terms.

The licence took effect from 28 May 2024 and expires at 23:59 on 27 May 2026.

 24 May 2024

The Russia (Sanctions) (EU Exit) (Amendment) (No 2) Regulations 2024

In force from: 28 May 2024

[NOW REVOKED]

This statutory instrument has now been revoked by The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2024 – see entry dated 29 July 2024

The designation criteria have been extended, as follows:

• The categories of persons who can be designated have been expanded to include persons who own or control; or are working as a director/manager/trustee or equivalent of; or have the right to nominate/appoint at least one director to, persons in the existing categories of persons.
• The definition of being “involved in obtaining a benefit from or supporting the Government of Russia” has been expanded to include providing financial services, or making available funds, economic resources, goods or technology, to a person who falls within the existing definition.
• The definition of a person who is involved in “destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine” or “obtaining a benefit from or supporting the Government of Russia” has been expanded to include a person providing financial services, or making available funds, economic resources, goods or technology, to a person who falls within the existing definition.

Ships: specification of ships – amendments

(amendment to Regulation 57F)

The criteria for the specification of ships for the purpose of the existing prohibitions on ships has been expanded to include ships carrying:

• dual-use goods or military goods;
• oil and oil products that originated in Russia; or
• any other goods or technology that could contribute to destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine,
  between Russia, a third country and/or non-government controlled Ukrainian territory.

OFSI has updated its industry guidance regarding the UK Maritime Services ban and oil price cap. Chapter 4 has been amended to specify that the price cap exception is not applicable to services for the benefit of designated persons or to services in relation to specified ships, nor to the supply or delivery of Russian oil or oil products in specified ships or to a designated person.

General licence: Oil Price Cap amendment

[INT/2024/4423849]

Publication notice

The General Licence has been amended to exclude the supply or delivery of Russian oil in, or provision of relevant services in relation to, a "Specified Ship", being a ship specified by the government under Regulation 57F of the Russia Sanctions Regulations 2019. 

UK Government Guidance: Russia sanctions: sales of oil tankers to third countries

The Department for Business and Trade has published new guidance for those involved in the sale and brokering of second hand vessels to third countries. 

The guidance highlights the UK sanctions prohibitions which capture brokering and other ancillary services related to the sale of oil tankers and other vessels to Russia, notably:

• the prohibition on directly or indirectly supplying or delivering "restricted goods" from a third country to a place in Russia; and 
• the prohibition on directly or indirectly making restricted goods available in a third country for direct or indirect supply or delivery to a person connected with Russia or to a place in Russia. (regulation 29 of the Russia Regulations).
  • "restricted goods" include certain vessels listed in Part 7 of Schedule 2A of the Russia Regulations.

The guidance also sets out a suggested due diligence process as well as some key risk indicators to help identify those attempting to circumvent trade sanctions. 

Asset freeze – addition

Press release

One entity has been added to the Russia financial sanctions regime and is now subject to an asset freeze and trust services sanctions:

• Vostochnaya Stevedore Limited Liability Company (Group ID: 16498)

The entity has been sanctioned as part of the UK's strategy to target the Russia North Korea (DPRK) "arms for oil" trade. 

 16 May 2024

The Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024

Director disqualification sanctions

(amendment to Regulation 5 and new Regulations 19B, 64A and 67A).

Introduction of a new power to designate persons for the purpose of disqualifying those persons from being a director of a company or directly or indirectly taking part in or being concerned in the promotion, formation or management of a company (Regulation 5).

Any persons so designated will be prohibited from acting as a director of a UK company. A designated person subject to this new measure will commit an offence if they act as a director of a company or directly or indirectly take part in the management, formation or promotion of a UK company (Regulation 19B).

Persons will be able to apply for a licence to allow them to undertake activity that is otherwise prohibited (Regulations 64A and 67A).

Belarus: the same director disqualification sanctions have been added to the Belarus Regime (amendment to Regulation 5 and new Regulations 16A, 32A and 35A)

Belarus: Trade restrictions - aluminium 

(amendments to Regulations 20(3), 27I, 27J, 27K, 27L, 27M and Schedule 2B)

 The existing trade sanctions have been extended to include:

• the import of aluminium originating in/consigned from Belarus (Regulation 27I);
• the acquisition of aluminium which is located or originates in Belarus (Regulation 27J);
• the supply and delivery of aluminium from Belarus to a third country (Regulation 27K); and
• the ancillary services related to the import, acquisition, or supply and delivery of aluminium (Regulation 27L and Regulation 27M).

"Aluminium" means anything which falls within commodity code 76 (Schedule 2B).

Belarus: Reporting obligations

(new Regulation 38A and amendments to Regulations 46, 48 and 56)

Designated people must inform the Treasury of the nature and value of any funds or economic resources which that person owns, holds or control, and the location of those funds or economic resources.

• For UK designated persons this reporting obligation applies to entities owned, held or controlled in any jurisdiction. For non-UK designated persons, this applies to entities owned, held or controlled in the UK.
• Those designated immediately before 16 May 2024, must give this information by 25 July 2024. Those not designated on or after 16 May 2024, must give this information by the end of the period 10 weeks from the day they are designated. 
• The designated person must inform the Treasury as soon as practicable of any change to the nature, value or location of the funds or economic resources.
• Failure to fulfil this obligation constitutes an offence. 

Belarus: Enforcement - monetary penalties

(new Regulations 56C and 56D)

The Treasury can impose monetary penalties on a person if it is satisfied, on the balance of probabilities, that the person has committed an offence by failing to comply with Regulation 38A (Regulation 56C).

The permitted maximum is the greater of £1,000,000 and 50% of the value of the funds or economic resources the Treasury was not informed of (where it is possible to estimate the value of these economic resources or funds).

Otherwise the permitted maximum is £1,000,000.

The Treasury must fulfil certain procedural steps before it imposes a monetary penalty under Regulation 56C (Regulation 56D). 

Belarus: trade restrictions – additions (various)

(amendment to Schedules 2C, 2H, and 2I)

New items have been added to the lists of goods/technology which are subject to existing trade restrictions, including: 

• Critical-industry goods and technology (Schedule 2B) - Electronics (Part 2), navigation and avionics (Part 6), and aerospace and propulsion (Part 8);
• Chemical and biological weapons-related goods and technology (Part 2, Schedule 2H); and 
• Machinery-related goods and machinery-related technology (Schedule 2I).

OFSI/UK Government Guidance: updates

Financial sanctions enforcement and monetary penalties guidance

Republic of Belarus sanctions: guidance

Financial sanctions guidance for Russia

Existing guidance has been updated to include the new reporting requirements and associated monetary penalties introduced via Regulations 38A and 56C of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019. 

General licence: Russian Travel amendment

[INT/2022/1839676]

The General Licence has been amended to extend its expiry. The licence will now expire on 23 May 2026.

OFSI has amended section 6 of its general guidance on its approach to licensing grounds for UK regimes, including updating the definitions for Extraordinary Expenses and Extraordinary Situations.

In particular, in respect of the "Extraordinary Situations" licencing grounds, the guidance now states that: "There is a high threshold for a situation to meet the standard of being extraordinary, and even where a situation may seem extraordinary to the parties concerned (i.e. outside their normal day to day business) it does not necessarily mean it will meet the threshold for this licensing ground."

Asset freeze – addition

The Cyber (Sanctions)(EU Exit) Regulations 2020

Press release

1 individual has been added to the consolidated list and is now subject to an asset freeze:

• Dmitry Yuryevich Khoroshev

The individual has been sanctioned for his role as a senior leader in the LockBit ransomware group. LockBit are responsible for ransomware attacks on over 200 UK businesses and major public service providers. This designation has been made under the UK's cyber sanctions regime but relates to a Russian individual.

OFSI has restyled and moved into a digital format its guidance on enforcement and monetary penalties. (Access the previous guidance.)

The update communicates a change in policy in how OFSI applies its guidance to cases: OFSI will now apply the most recent iteration of its Enforcement guidance to cases. Chapter 3 of the guidance, which covers case assessment, gives some more details on the change.

Other updates are also primarily to Chapter 3. The guidance now better explains how OFSI applies and splits the 'case factors' that it uses to assess suspected breaches of financial sanctions. It introduces two new distinct case factors, "Knowledge, intention and reasonable cause to suspect" and "Cooperation" that were previously included more generally in the guidance. 

Chapter 6 also includes a small edit to the delegation of ministerial reviews of monetary penalties.

OFSI has launched a government web-page containing FAQs, a form of additional guidance providing technical support to industry partners and the public. The FAQs should be considered supplementary to, and not a replacement for, OFSI's primary guidance. 

The FAQs address a number of topics not specific to Russia, but also contains specific sections on Russian sanctions (see FAQ 4 to 34) and the Russian Oil Services Ban (see FAQ 35 to 47). A number of the FAQs on Russian sanctions replicate the FAQs contained in OFSI's previous Russia Guidance. The FAQs relating to the Oil Services Ban are largely new.

The Department for Business & Trade has updated its guidance explaining the scope of the measures related to relevant Russian diamonds processed in third countries, and the evidence traders need to provide to demonstrate compliance. It does not cover other prohibitions (including other measures related to Russian diamonds).

The update recognises Norway has substantially equivalent sanctions on iron and steel, adding it as a partner country for iron and steel import sanctions alongside the EU and Switzerland.

The Department for Business & Trade has updated its guidance explaining the scope of the measures related to relevant iron and Steel processed in third countries, and the evidence traders need to provide to demonstrate compliance. It does not discuss other prohibitions (including other measures related to Russian iron and steel, except for the section on reusable packaging under the General Trade Licence).

The update recognises Norway has substantially equivalent sanctions on iron and steel, adding it as a partner country for iron and steel import sanctions alongside the EU and Switzerland.

General licence – Legal services (new)

[INT/2024/4671884]

Publication notice

THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/5334756 (29 OCTOBER 2024)

The previous licence on legal services (INT/2023/3744968) has expired and OFSI has issued a new licence on legal services which permits:

• A UK legal firm or counsel who has provided legal advice to a person designated under either the Russia or Belarus regime to receive payment form the designated person, provided the conditions of the general licence are met. The conditions are found in Part A and B of the licence. Part A and B can be used separately or in conjunction.
• Any payments received under the general licence must be reported to HM Treasury within 14 days of the payment being received.
• A designated person must keep accurate, complete and readable records of any activity purportedly permitted under this licence for a minimum period of 6 years.

The main changes from previous licences on legal services include the following:

• Legal fees are capped at £500,000 inclusive of VAT and expenses are capped at 10% of the legal fees (maximum of £50,000 inclusive of VAT). These caps apply to each law firm instructed by the designated person to cover all matters on which that firm is instructed.
• Brief fees and refresher fees can be paid to counsel, provided they are fixed fees not subject to hourly rates. These fees are included in the overall cap for professional legal fees including counsel’s fees.
• The definition of counsel has been extended to include barristers regulated by the Bar Council of Northern Ireland and advocates regulated by the Faculty of Advocated (in Scotland).

The licence took effect from 29 April 2024 and expires at 23:59 on 28 October 2024.

General Trade Licence: Acquisition of Russian Metals - amendment

Press release

The LME has issued updated guidance and a new guidance note

The General Licence has been amended to reflect changes to the circumstances where metals, and warrants for metals, may be acquired in relation to their trade on global metals exchanges, and to the relevant reporting requirements and definitions.

The General Licence now permits the direct or indirect acquisition of a warrant on a global metal exchange by the persons described below, so far as otherwise prohibited by regulation 46IH(1)(a) of the Russia Regulations, provided that:

a) such persons do not cancel or withdraw (or request or order the cancellation or withdrawal of) such a warrant from a global metal exchange in order to take physical delivery of metal for their own account;

b) such persons do not change the location of the metal to which the warrant relates; and

c) the metal to which the warrant relates was produced before 23:59 on 12 April 2024.

The conditions in paragraph a) and b) do not apply where a person acquires a warrant in relation to metal which was under warrant on a global metal exchange as at 23:59 on 12 April 2024.

Where a person acquired a warrant which was issued before 23:59 on 12 April 2024, such a person is authorised to:

• cancel or withdraw (or request the cancellation or withdrawal of) that warrant from a global metal exchange in order to take physical delivery of the metal; and
• change the location of the metal to which the warrant relates.

The description of persons to whom the above applies remains unchanged: LME Clear Limited; the London Metal Exchange; global metal exchange members; and clients of global metal exchange members.

The amendments also introduce new record-keeping and reporting requirements.

The General Licence remains of indefinite duration.

General licence: Active Denizcilik and Beks Ships Transit to Port and Wind Down – amendment

[INT/2024/4576632]

THIS GENERAL LICENCE HAS NOW EXPIRED

The General Licence has been amended to remove the language prohibiting funds or economic resources from being made available for the benefit of any designated person.

General licence: Payments to Companies House – amendment

[INT/2023/3626884]

[REVOKED]

[THIS GENERAL LICENCE WAS REVOKED ON 05 DECEMBER 2024]

The General Licence has been amended to add the following permissions to the list of Permitted Payments:

• The payment of fees owed by or due from UK designated persons to Companies House for filing an Overseas Entity Update Statement in respect of entities on the Register of Overseas Entities.
• The payment of penalties owed by or due from UK designated persons to Companies House incurred as a result of failure to register as an entity on the Register of Overseas Entities or failure to provide an Overseas Entity Update Statement in respect of entities on the Register of Overseas Entities.

General licence: Active Denizcilik and Beks Ships Transit to Port and Wind Down

[INT/2024/4576632]

Publication Notice

THIS GENERAL LICENCE HAS NOW EXPIRED

OFSI has issued a new General Licence which permits:

• insurers and other service providers to provide insurance and certain other services to Active Denizcilik for the purpose of allowing certain vessels managed by Active Denizcilik to reach their port of discharge or other safe port to discharge their cargo, and for payments to be made to insurers / service providers up to a certain amount in respect of the same; and
• the wind-down of any transactions involving Active Denizcilik (and relevant vessels) or Beks Ships Transit, provided that no funds or economic resources are made available to or for the benefit of any Designated Person.

"Active Denizcilik" means Active Denizcilik ve Gemi Isletmeciligi Anonim Sirketi (consolidated list group ID: 16428) (DP)
"Beks" means Beks Gemi Isletmeciligi Ve Ticaret Anonim Sirketi OR Beks Ship Management And Trading Joint Stock Company (consolidated list group ID: 16411) (DP)

Certain permissions in the General Licence are subject to reporting requirements. Please consult the General Licence for its full terms.

The licence took effect from 14:30 on 28 March and expires at 23:59 on 11 June 2024.

Financial sanctions: enforcement - anticipated monetary penalties in 2024

Letter from Anne-Marie Trevelyan MP to the Chair of the Foreign Affairs Committee

The FCDO has indicated that the first monetary penalties from breaches of financial sanctions on Russia are expected in 2024. In a letter to the Chair of the Foreign Affairs Committee, Anne-Marie Trevelyan MP stated:

"OFSI cannot pre-determine case outcomes but does expect to see the first Monetary Penalties resulting from 2022 Russia designations come to fruition in 2024. This is in line with other jurisdictions, including the US, given the time it takes to properly investigate cases." (emphasis added).

In response, Chair of the Foreign Affairs Committee, Alicia Kearns MP, stated:

"Since Russia’s full-scale invasion of Ukraine in February 2022, the number of asset freezes under UK sanctions has grown significantly. If this is not soon reflected in the number of enforcement actions, we will have to ask difficult questions about the efficacy of OFSI’s enforcement capacity. Investigations into non-compliance are complex but must be prioritised and undertaken at pace; we need to send a clear message that illicit finance has no home in the UK." (emphasis added)

One individual has been removed from the Russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions:

• Igor Viktorovich Makarov

A General Trade Licence has been granted which provides authorisation for Russian diamonds processed in a third country ("relevant processed diamonds") outside of Russia since before 1 March 2024, subject to the following conditions:

• the relevant processed diamond is equal to or larger than 1 carat;
• any diamond processed to produce the relevant processed diamond has not been located in Russia at any time beginning with 1 March 2024; and
• the relevant processed diamond has not been located in Russia at any time beginning with 1 March 2024.

This General Trade Licence took effect from 1 March 2024 and has no expiry date.

General Licence: Court Funds Office payments

[INT/2024/4398024]

Publication Notice

OFSI has issued a new General Licence which permits Persons who owe monies to a designated person as a result of a Court Order to pay these to the Court Funds Office and for the Court Funds Office to receive these payments.

This General Licence took effect from 29 February 2024 and has no expiry date.

 28 February 2024

(in force on 1 March 2024)

Trade restrictions – diamonds processed in a third country

(new Chapter 4JC, Regulations 46Z16Q – 46Z16U)

Introduction of a new prohibition on the import of "relevant processed diamonds", being diamonds which originate in Russia and have been processed in a third country. 

For the purposes of this restriction, "diamonds" means anything falling within:

• The following commodity codes:
  • 7102 10 (unsorted diamonds);
  • 7102 39 (non-industrial diamonds, other than unworked or simply sawn, cleaved or bruted); and 
• Both commodity code ex 7102 31 and the description "non-industrial diamonds, simply sawn, cleaved or bruted".

Includes a prohibition of the provision of associated technical assistance, financial services and funds and brokering services.

The prohibition takes effect on:

• 1 March 2024 in relation to any diamonds which are equal to or larger than 1 carat;
• 1 September 2024 in relation to any diamonds which are equal to or larger than 0.5 carats

OFSI has published guidance on the principles its licensing caseworkers follow to assess licence applications and refer to for a licensing decision to be made. Alongside this, it has published the frameworks that govern who makes a decision in regard to that licence application.

OFSI has also published a blog to explain in more detail the licensing process and principles. 

This guidance applies to all UK financial sanctions – it is not Russia-specific

General Licence: payments to Companies House

[INT/2023/3626884]

Asset freeze – additions

Press release

50 individuals and entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions. The list of those sanctioned includes:

• 14 individuals and entities linked to manufacturing munitions
• A number of foreign entities and individuals including a Turkish company and three Chinese companies
• Oil trader Niels Troost and his company Paramount Energy & Commodities SA
• Fractal Marine DMCC, Beks Ship Management, and Active Shipping, which carry on business in the Russian energy sector
• Arctic LNG 2 and associated individuals
• Two Russian diamond companies, OJSC Almazny Mir and JSC AGD Diamonds, and a number of individuals linked to Alrosa, Russia’s state-owned diamond company
• A number of Russian metals companies (Ural Mining and Metallurgical (UMMC), Samara Metallurgical Company and Kamensk-Uralskiy Metallurgicheskiy Zavod) and associated individuals

Belarus: Asset freeze – additions

Press release

2 entities have been added to the consolidated list and are now subject to an asset freeze:

• JSC Planar
• Precise Electro-Mechanics Plant

Guidance: Common High Priority Items List (Russia Regime) – update

Access the Common High Priority List

The UK's list has been now been expanded to include 5 new codes related to Computer Numerical Control (CNC) machines which are crucial to the manufacture and maintenance of vital military equipment.  

The Common High Priority List contains items that Russia is using in its weapons systems. It is composed of Western items critical to Russian weapons systems and its military development. They include electronic components such as integrated circuits and radio frequency (RF) transceiver modules and items that are essential for the manufacturing and testing of the electronic components and circuits retrieved from the battlefield.

Asset freeze – additions

Press release 

The Global Human Rights Sanctions Regulations 2020

6 individuals have been added to the consolidated list and are now subject to an asset freeze:

• Colonel Vadim Konstantinovich Kalinin
• Lieutenant Colonel Sergey Nikolaevich Korzhov
• Lieutenant Colonel Vasily Alexandrovich Vydrin
• Lieutenant Colonel Vladimir Ivanovich Pilipchik
• Lieutenant Colonel Aleksandr Vladimirovich Golyakov
• Colonel Aleksandr Valerievich Obraztsov

These individuals are responsible for the custody of Alexei Navalny in their positions as Head or Deputy Head of Arctic Penal Colony IK-3. They have been designated under the UK's Global Human Rights sanctions regime.

OFSI has updated its Russia Guidance FAQ by adding FAQ number 56, explaining when a designated person is required to report to OFSI under regulation 70A(5). 
A designated person must report to OFSI:

• when the value of their funds or economic resources, when taken together, has changed by an amount exceeding £10,000 compared with the previous report filed with OFSI. 
• if there has been a change to the nature or location of funds or economic resources where those funds or economic resources exceeds the value of £10,000. This also applies where multiple funds or economic resources of the same type taken together exceed £10,000.

OFSI has published updated guidance for the Maritime Services Ban and Oil Price Cap, to provide additional clarity and detail on the following:

• Attestations: The changes to the attestation model announced on 20 December 2023 will come into effect on 19 February 2024. The updated model requires 1) attestation forms to be provided on a per-voyage basis and 2) itemised ancillary costs to be recorded by Tier 1 entities and provided to Tier 2 and Tier 3A contractual counterparties upon request. The tier system has been amended and Tier 3 has been split into Tier 3A and Tier 3B.
• Attestation and cost information deadlines: The deadline for providing additional attestations or itemised ancillary costs has been reduced from 30 days to 28 days.
• Ceasing doing business: The requirement to cease doing business with actors who refuse or fail to provide information has been clarified as being contract-specific and only applying to policies relating to the seaborne transportation of Russian oil and oil products.

General Licence – "new" oil price cap General Licence

(INT/2024/4423849)

Effective from 19 February 2024

Publication notice

This new General Licence replaces the previous General Licence Oil Price Cap INT/2022/2469656 which expires on 18 February 2024.

This new General Licence permits the supply or delivery by ship of Russian crude oil and oil products, as well as provision of associated services, so long as the price paid for Russian oil or oil products is at or below the price cap. This General Licence sets the price at USD $60 per barrel for crude oil, USD $100 for “premium to crude”, and USD $45 for “discount to crude”.

Subject to the stated exclusions and conditions and provided that no supply or delivery by ship of Russian oil or Relevant Services are provided to a Designated Person:

1. A person may supply or deliver Russian oil by ship from a place in Russia to a third country or from one third country to another third country provided that the Unit Price of the Russian oil concerned is at or below the Price Cap.
2. A service provider may provide relevant services to any person provided that the unit price of the Russian oil being supplied or delivered by ship from a place in Russia to a third country or from one third country to another third country is at or below the Price Cap. 
3. A Relevant Institution may process payments in relation to the activities authorised by paragraphs 1 and 2.

This new General Licence utilises an attestation process – on a per-voyage basis – which is designed to put different levels of requirement onto different actors in the oil supply chain, depending on whether they routinely know the price paid in their ordinary course of business and how often they transact. An attestation means a document:

• demonstrating that the Price Information of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
• demonstrating that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
• attesting that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
• attesting that the Russian oil was purchased pursuant to a Licence issued under Part 4 of Schedule 5 of the Russia Regulations for example to enable anything to be done to deal with an extraordinary situation
• which, for Tier 3A and Tier 3B Providers, contains a clause within contractual terms and conditions that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap.

Tier 1 Providers (and Tier 2 Providers with access to the information) are required to record itemised ancillary costs information – on a per-voyage basis – and provide them to other Tier 1, Tier 2 and Tier 3A contractual counterparties upon request.

General Licence – Permitted Payments to UK Insurance Companies – amendment

(INT/2022/2009156)

Publication notice

This General Licence has been amended such that: 

• Reference to frozen UK bank accounts has been removed from paragraphs 4.1, 4.3.1, and 6.1 to make clear that payments by DPs are not restricted to those made from frozen funds; and
• The language in paragraphs 5.1 and 6.6 has been clarified.

OFSI has published a blog post explaining the two new reporting requirements that came into force in December 2023 through the Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023:

• the immobilised assets reporting measure; and
• the Designated Persons asset reporting measure.

General Licence – Oil Price Cap – amendment

(INT/2022/2469656)

Publication notice

THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/4423849

This General Licence has been amended to include an expiration date of 18 February 2024. 

General Licence – Permitted Payments to UK Insurance Companies – amendment

(INT/2022/2009156)

Publication notice 

 This General Licence has been amended such that:

• Permitted Payments can only be made for UK properties and UK vehicles;
• Insurance Brokers may make all types of Return Payments to a DP’s frozen bank account including payments due from successful claims;
• The language in 5.2 and 6.5 has been clarified;
• The definition of Return Payments was expanded to include other types of refunds;
• The reporting and record-keeping requirements also apply to Insurance Brokers; and
• Those reporting must now report to HM Treasury within 10 working days.

The Oil Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) have issued an enforcement alert to support governments and strengthen oil price cap (OPC) compliance.

The coalition has two key objectives: 1) constraining Russian revenues that could otherwise be used to fund Russia’s war of aggression against Ukraine; while 2) maintaining global oil flows and protecting energy security.

The alert includes an overview of key OPC evasion methods and recommendations for identifying such methods and mitigating their risks and negative impacts. The alert also includes information on how to report OPC suspected breaches across the Price Cap Coalition.

The OPC evasion methods covered in this alert are related to:

• falsified documentation and attestations;
• opaque shipping and ancillary costs;
• third country supply chain intermediaries and complex and irregular corporate structures;
• flagging;
• the “shadow” fleet; and
• voyage irregularities.

The National Crime Agency has issued an Amber Alert highlighting the sanctions evasion and money laundering risks presented to UK industries linked to the art storage sector, and to serve as a reminder on due diligence checks and reporting obligations.

The Alert includes key indicators and useful questions, as well as case studies.

The Alert is not specific to Russian sanctions, but identifies Russia as a jurisdiction of high risk.

Asset freeze – addition

The Cyber (Sanctions) (EU Exit) Regulations 2020

Press release

1 individual has been added to the consolidated list and is now subject to an asset freeze:

• Aleksandr Gennadievich Ermakov

The individual has been sanctioned for his involvement in the cyber-attack on Medibank Private network that resulted in 9.7 million medical records being stolen. This designation has been made under the UK's cyber sanctions regime.

Permits the provision of technical assistance, financial services and funds, and brokering services relating to vessels, aircrafts and aero gas turbine engines / their component parts / associated technology, where;

• the goods are:

• vessels and their component parts controlled under 8A992f of Schedule 2A to the Regulations and the restricted technology is technology related to such vessels controlled under 8E992 of Schedule 2A to the Regulations,
• aircraft and their component parts controlled under Schedule 2C to the Regulations and the restricted technology is technology related to such aircraft controlled under Schedule 2C to the Regulations, but in each case not including anything defined under Part 5 of the Regulations as military goods or military technology, or
• aero gas turbine engines and specially designed components therefor controlled under 9A991c of Schedule 2A of the Regulations and the restricted technology is technology related to such engines and components controlled under 9E991 of Schedule 2A to the Regulations,

• the aircraft or vessel is moving from a third country to Russia, or to the UK or a third country from Russia, or transiting Russian territorial waters or airspace or moving between two third countries,
• in the case of an aircraft, it is carrying goods or passengers when removed or is removed in order to undertake a journey carrying goods or passengers,
• the aircraft or vessel is moving under its own power, and
• the movement of the aircraft or vessel is not for the purpose of: (i) transfer of ownership of the aircraft or vessel or any of its component parts or (ii) a change of the operator of the aircraft or vessel.
• an aero gas turbine engine and specially designed components form part of an aircraft specified above which is undertaking an activity in accordance with the above.,
• technical assistance and brokering services are not being provided to a person connected with Russia; and
• in the case of insurance and reinsurance services under Article 29A, they are not being provided to a person connected with Russia.

The General Licence also contains a number of conditions relating to insurance/reinsurance in respect of the above.

Use is subject to a notification requirement.

This replaces the previous licence dated 1 August 2022 (now revoked).