Russia Sanctions Tracker - UK
07 November 2024
In the current circumstances, the status of these measures are subject to change on a daily basis. Certain measures were in place prior to February 2022 and these are not included in this tracker. Whilst every effort has been made to ensure the accuracy and completeness of this summary at the date of publication, no reliance should be placed on its content and it does not constitute legal advice. Please refer to the primary sources of the restrictions for their full content.
Selected UK guidance and consolidated lists can be found under "useful links" at the bottom of the page.
This tracker was last updated on 7 November 2024.
Export Enforcement Five: joint statement
Date of imposition | Sanction imposed | Summary |
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7 November 2024 |
General Licence: Correspondent Banking Payments (new) [INT/2024/5394840] |
OFSI has issued a General Licence which allows regulated financial institutions to process a "Relevant Payment" made in the year 2022 from or via a designated credit or financial institution", provided that the original sender and original intended recipient are not Designated Persons. "Relevant Payment" means a payment;
The licence is subject to reporting and record-keeping requirements. This licence took effect from 07 November 2024 and expires at 23:59 on 6 November 2025. |
Asset freeze – addition |
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. |
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4 November 2024 |
Enforcement – HMRC compound settlement |
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. |
29 October 2024 |
General Licence: Legal Services – (new |
The previous licence in legal services (INT/2024/4671884) has expired and OFSI has issued a new licence on legal services which permits:
The main changes from previous licences on legal services include the following:
The licence took effect from 00:001 on 29 October 2024 and expires at 23:59 on 28 April 2025. |
General licence: Payments to Utility Companies for Gas and Electricity – amendment |
On 29 October 2024, General Licence INT/2022/2300292 was amended to:
This General Licence applies to all UK Autonomous Sanctions Regulations. |
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28 October 2024 |
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:
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. |
21 October 2024 | 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. |
17 October 2024 |
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:
The guidance is to help prevent the diversion of controlled items to Russia, including through third countries. |
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:
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Shipping specifications – additions Asset freeze - addition |
The following ships have been specified under the Russia sanctions regime:
The following entity has been added to the consolidated list and is now subject to an asset freeze:
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. |
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14 October 2024 |
General Licence: Government Debt Payments - new |
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. |
10 October 2024 |
The Office of Trade Sanctions Implementation (OTSI) – legislation now in force |
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. |
8 October 2024 |
Asset freeze – additions |
1 individual and 3 entities have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:
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 |
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 |
The General Licence has been updated as follows:
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OFSI financial sanctions FAQs: new |
OFSI has added 2 Frequently Asked Questions to its FAQs page:
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30 September 2024 Applies from 31 October 2024 |
Removal of licencing considerations: intra-corporate services |
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:
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Shipping specifications - additions |
The following ships have been specified under the Russia sanctions regime:
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. |
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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 |
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:
This legislation applies to all UK trade sanctions. |
OTSI: Guidance |
OTSI has issued a number of policy papers/guidance:
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11 September 2024 |
Shipping specifications - additions |
The following ships have been specified under the Russia sanctions regime:
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:
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:
Those specified are key ships involved in Iran’s military support to Russia, including those involved in ballistic missile and drone supply chains. |
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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). |
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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
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:
"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— "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 |
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:
This General Trade Licence took effect from 1 March 2024 and has no expiry date. |
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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. |
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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. |
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9 August 2024 |
General Licence – East-West United Bank – Insolvency related payments and activities – new [INT/2024/5028385] |
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:
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 |
General Licence – Payments to Local Authorities – amendment |
The General Licence has been amended to add a permission to the list of Permitted Payments:
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2 August 2024 |
General Licence – National Settlement Depository - amendment |
The General Licence has been amended to extend its expiry. The licence will now expire at 23:59 on 12 October 2024. |
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:
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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:
between Russia, a third country and/or non-government controlled Ukrainian territory. |
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24 July 2024 |
General Licence - Continuation of Business of Evraz Plc’s North American Subsidiaries – amendment |
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 |
The General Licence has been amended to change Permission 5.2, specifically the Insolvency Proceedings that apply to OWE SE, the EU subsidiary. Please consult paragraph 5.2 of the licence for full details of the amended provision. |
18 July 2024 |
UK Financial Sanctions FAQs – additions |
OFSI has added 7 Frequently Asked Questions (FAQs) to its FAQs page:
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Shipping sanctions – new specifications |
The following ships have been specified under the Russia Sanctions regime:
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. |
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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 |
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. 3 July 2024 and will expire at 11:59 on 13 August 2024. |
3 July 2024 |
General Licence – Payments for Visa Application Services - new |
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 |
1 July 2024 |
General Licence – Payments to Revenue Authorities - new [INT/2024/4881897] |
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] |
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 |
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:
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20 June 2024 |
General Licence – FCA Payments - new [INT/2024/4836676] |
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:
The licence took effect from 00:01 on 20 June 2024. |
13 June 2024 |
Asset freeze – additions |
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:
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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] |
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 |
28 May 2024 |
General Licence – Funds of non-designated third parties involving designated credit or financial institutions ("Personal Remittances") - new [INT/2024/4761108] |
OFSI have issued a new General Licence which permits:
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] |
(amendment to Regulation 6) |
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24 May 2024 | OFSI Guidance: UK Maritime Services Ban and Oil price Cap - update |
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] |
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. |
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21 May 2024 | UK Government Guidance: third country processed Russian diamonds measures - update | The Department for Business and Trade has updated its guidance on relevant Russian diamonds processed in third countries only, and the evidence traders need to provide to demonstrate compliance. It adds a verification certificate, issued by the Federal Public Service Economy at the Diamond Office in Belgium, as an example of documentation demonstrating supply chain history. |
UK Government Guidance: Russia sanctions: sales of oil tankers to third countries
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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 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. |
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17 May 2024 |
Asset freeze – addition |
One entity has been added to the Russia financial sanctions regime and is now subject to an asset freeze and trust services sanctions:
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:
"Aluminium" means anything which falls within commodity code 76 (Schedule 2B). |
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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.
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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). |
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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:
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16 May 2024 |
OFSI/UK Government Guidance: updates Financial sanctions enforcement and monetary penalties guidance |
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. |
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13 May 2024 | Financial sanctions: Licencing – update to general guidance (section 6) |
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." |
7 May 2024 |
Asset freeze – addition The Cyber (Sanctions)(EU Exit) Regulations 2020 |
1 individual has been added to the consolidated list and is now subject to an asset freeze:
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. |
2 May 2024 | OFSI Guidance: UK financial sanctions enforcement and monetary penalties guidance – new format and additions |
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. |
1 May 2024 | UK Financial Sanctions FAQs – new format and additions |
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. |
30 April 2024 | UK Government guidance: Third country processed Russian diamonds measures |
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. |
UK Government guidance: Third country processed iron and steel measures |
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. |
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UK Government guidance: Russia import sanctions | The Department for Business & Trade has updated its guidance providing an overview of the import prohibitions in force on certain goods imported into the UK including Northern Ireland, that originated in or have been consigned from the territory covered by what is now the Russian Federation and non-government controlled Ukrainian territory. It also sets out the licensing process for traders looking to import good subject to prohibitions. | |
29 April 2024 |
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THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/5334756 (29 OCTOBER 2024)
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12 April 2024 |
General Trade Licence: Acquisition of Russian Metals - amendment 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:
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. |
10 April 2024 |
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THIS GENERAL LICENCE HAS NOW EXPIRED
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2 April 2024 |
General licence: Payments to Companies House – amendment [INT/2023/3626884] |
The General Licence has been amended to add the following permissions to the list of Permitted Payments:
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28 March 2024 |
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THIS GENERAL LICENCE HAS NOW EXPIRED
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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) |
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5 March 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:
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1 March 2024 | General Trade Licence – Russian diamonds processed in third countries |
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:
This General Trade Licence took effect from 1 March 2024 and has no expiry date. |
UK Government guidance: Third country processed Russian diamonds measures | The Department for Business & Trade has published 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) | |
29 February 2024 |
General Licence: Payment to Energy Companies for Gas and/or Electricity – amendment [INT/2022/2300292] |
This General Licence has been amended to add permission for payments for gas and electricity meter installation, certification, validation, monitoring, replacement, removal and other payments in relation to these activities. |
General Licence: Court Funds Office payments [INT/2024/4398024] |
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. |
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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:
Includes a prohibition of the provision of associated technical assistance, financial services and funds and brokering services. The prohibition takes effect on:
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27 February 2024 | OFSI Guidance: Licensing principles and delegation frameworks |
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 |
26 February 2024 | General Trade Licence: Iron and steel products – amendment | The General Trade Licence has been varied to extend the date of production/manufacture for iron and steel products to fall within the authorisation – this now applies to a relevant processed iron or steel product which was manufactured or produced before 23 June 2023 (previously this was 21 April 2023). |
23 February 2024 |
General Licence: payments to Companies House [INT/2023/3626884] |
OFSI has amended the General Licence to permit the payment of fees for the administrative restoration of an entity previously incorporated in the UK which was struck off and dissolved by the Registrar of Companies at Companies House, and any related filing fees and penalties. |
22 February 2024 |
UK Government Sanctions Strategy: Deter, disrupt and demonstrate – UK sanctions in a contested world: UK sanctions strategy | The UK Government published its first sanctions strategy . The paper provides a helpful summary of the UK's present and future sanctions policy. A notable theme is the UK's continued focus on Russia alongside its further 36 live sanctions regimes. |
Asset freeze – additions |
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:
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Belarus: Asset freeze – additions |
2 entities have been added to the consolidated list and are now subject to an asset freeze:
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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. |
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21 February 2024 |
Asset freeze – additions The Global Human Rights Sanctions Regulations 2020 |
6 individuals have been added to the consolidated list and are now subject to an asset freeze:
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. |
20 February 2024 | Russia Guidance FAQ: reporting obligations - updated |
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).
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16 February 2024 | Oil Price Cap: OFSI Guidance - updated |
OFSI has published updated guidance for the Maritime Services Ban and Oil Price Cap, to provide additional clarity and detail on the following:
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General Licence – "new" oil price cap General Licence (INT/2024/4423849) Effective from 19 February 2024 |
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:
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:
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. |
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15 February 2024 |
General Licence – Permitted Payments to UK Insurance Companies – amendment (INT/2022/2009156) |
This General Licence has been amended such that:
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12 February 2024 | OFSI Blog – New reporting requirements |
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:
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THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/4423849
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6 February 2024 |
General Licence – Permitted Payments to UK Insurance Companies – amendment (INT/2022/2009156) |
This General Licence has been amended such that:
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1 February 2024 | Oil Price Cap: Compliance and Enforcement Alert |
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:
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24 January 2024 | NCA Amber Alert: Financial Sanctions Evasion, Money Laundering & Cultural Property Trafficking Through the Art Storage Sector |
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. |
23 January 2024 |
Asset freeze – addition The Cyber (Sanctions) (EU Exit) Regulations 2020 |
1 individual has been added to the consolidated list and is now subject to an asset freeze:
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. |
18 January 2024 | General Trade Licence - Vessels |
Permits the provision of technical assistance, financial services and funds, and brokering services relating to vessels, aircrafts and aero gas turbine engines / their component parts / associated technology, where;
The General Licence also contains a number of conditions relating to insurance/reinsurance in respect of the above. Use is subject to a notification requirement. This replaces the previous licence dated 1 August 2022 (now revoked). |
22 December 2023 | ECJU guidance on complying with professional and business services sanctions |
The Export Control Joint Unit has updated its guidelines on complying with professional and business services sanctions related to Russia by:
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General Licence – Evraz – amendment (INT/2022/1710676) |
The General Licence permitting the continuation of business operations involving the North American subsidiaries of Evraz plc has been extended and will now expire at 23:59 on 30 September 2024. In addition, the definition of North American Subsidiaries under the General Licence was amended on 22 December 2023 to make clear that the definition also covers the subsidiaries of those subsidiaries. See entry at 5 May 2022 for more information on this General Licence. |
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21 December 2023 | OFSI Guidance – various updates |
OFSI updated its General, Russia and Enforcement & Monetary Penalties guidance documents to reflect changes to sanctions legislation introduced through the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 (see entries below for more details). Specifically, the guidance has been updated to reflect the following changes:
The guidance documents have also been updated to reflect the clarifications made by the Economic Crime and Corporate Transparency Act 2023 to OFSI's monetary penalty powers under the Policing and Crime Act 2017. Along with these updates, reporting forms are now available on OFSI's website for the new reporting measures now in place. Following amendments to regulation 17A, a blog has also been issued explaining the new payment processing restrictions. |
20 December 2023 | Oil Price Cap: updated OFSI guidance and two General Licences revoked |
OFSI has published updated guidance for the Maritime Services Ban and Oil Price Cap to provide additional clarity and detail on the following:
Bespoke reporting forms for required reporting, reporting suspected breaches, and specific licence applications are on OFSI's website. Any reporting or queries should be directed to oilpricecap.OFSI@hmtreasury.gov.uk Two General Licences have been revoked: Refined Products Oil Price Cap Wind-down (INT/2023/2660772) and Oil Price Cap Wind-down (INT/2022/2470256). |
18 December 2023 |
General Trade Licence: General Licence webpage |
The iron and steel products General Trade Licence was varied on 18 December 2023 to reflect amendments made by the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023. The changes to the Licence have not affected what is permitted by the Licence. The changes updated the name of the title of Chapter 4CA, and how iron and steel products processed in a third country is defined. The changes take effect at 00:00 on 20 December 2023. See entry at 11 December 2023 below for more information on this General Trade Licence. |
15 December 2023 |
General Trade Licence: Acquisition of metals General Licence webpage |
A General Trade Licence has been granted which authorises 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 such persons:
The description of persons to whom the above applies are:
This General Trade Licence took effect from 15 December 2023 and has no expiry date. |
Correspondent banking relationships etc (Reg 17A) – designations |
The following 26 entities have been designated for the purposes of Regulation 17A and are now subject to the prohibition on correspondent banking relationships etc:
Previously, Sberbank was the only entity designated for the purposes of Regulation 17A. The above entities were already designated for the purposes of the asset freeze measures and the trust services restrictions. |
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General Licence: Payment Processing Wind Down |
The General Licence permits processing payments that would otherwise breach Regulation 17A(2) following amendments to the regulation (see entry for 14 December below). Under this General Licence UK credit or financial institutions may process
For the purposes of this General Licence, "Newly Designated Bank" means any credit or financial institution designated for the purposes of regulation 17A after 13 December 2023, and any UK or non-UK financial institution which is owned or controlled by that institution. (Prior to 15 December 2023, Sberbank was the only person designated for the purposes of regulation 17A.) This General Licence takes effect from 12am (midnight) on 15 December 2023 and expires at 23:59 on 22 December 2023. |
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OFSI General Licences: various amendments (Regulation 17A) |
OFSI has updated the following General Licences to also permit activity that would otherwise breach the prohibitions in Regulation 17A of the Russia Regulations:
General Licence INT/2022/2009156 (Permitted Payments to UK Insurance Companies) also has a number of changes in relation to definitions and use. |
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Asset Freeze - addition |
1 entity has been added to the consolidated list and is now subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions:
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14 December 2023 The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 |
Financial sanctions: Correspondent banking relationships - amendment (amendment to Regulations 17A, 59A) |
The existing prohibition on "processing" payments to/from entities designated for the purpose of Regulation 17A has been amended as follows :
A new exception has also been introduced: the prohibition in regulation 17A(2) is not contravened by a transfer/transfer of funds by C from account A to account B where: (a) neither account A nor account B are held in the name of a customer of C; (b) both account A and account B are held within the UK; and (c) the transfer(s) from account A to account B is/are carried out for the purpose of compliance with regulation 17A(2). |
Trade restrictions: luxury goods – amendment (new Regulations 46BA, 46BB, 46BC; amendments to Regulation 85) |
Introduction of new prohibitions on providing technical assistance, financial services and funds, and brokering services in respect of luxury goods (as specified in Schedule 3A). Consequential amendments have been made to Regulation 85 (application of CEMA). |
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Trade restrictions: Russian metals (new Chapter 4CB, Regulations 46IF – 46II; new Schedule 3BA) |
Introduction of a new prohibition on:
"metals" means anything specified in Schedule 3BA; "third country" means a country that is not the United Kingdom, the Isle of Man or Russia. Schedule 3BA includes: copper, nickel, aluminium, lead, zinc, tin, tungsten, magnesium, cobalt and various other metals |
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Trade restrictions: exceptions – various amendments (various) |
The following exceptions have been amended:
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Trade restrictions: iron and steel products – new exceptions (new regulations 60GAA and 60GAB) |
Introduction of new exceptions to a number of the restrictions on Russian iron and steel products (Chapter 4C, Regulation 46C – 46I) where those goods:
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Reporting obligations: relevant firms (amendment to Regulation 70) |
Introduction of an additional reporting requirement requiring "relevant firms" to inform the Treasury:
"prohibited person" means a person to whom financial services must not be provided by virtue of regulation 18A(1) (Provision of financial services relating to foreign exchange reserve and asset management). |
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Reporting obligations: designated persons (new Regulation 70A; amendments to Regulations 88 and 88C) |
From 26 December 2023, there are new reporting requirements for designated persons, as follows:
The deadline for making any such reports is:
Consequential amendments have been made to Regulations 88 and 88C in respect of the Treasury's ability to impose monetary penalties for breach of the above. |
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Trade restrictions amendments to existing restrictions (various) |
Further amendments to existing trade restrictions:
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Treasury Licences: purposes – amendment (amendment to Schedule 5 – addition of a new Part 1ZA) |
Addition of three new purposes to Schedule 5 for which the Treasury can issue a licence:
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14 December 2023 The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023 |
Trade restrictions: Russian diamonds (new Chapter 4JB, regulations 46Z16J - 46Z16P; new Schedule 3GA) In force from: 1 January 2024 |
Prohibition on the following in respect of "diamonds" and "diamond jewellery" from 1 January 2024:
"diamonds" means anything specified in Part 2 of Schedule 3GA "diamond jewellery" means anything specified in Part 3 of Schedule 3GA "third country" means a country which is not the United Kingdom, the Isle of Man or Russia. Exception for diamonds and diamond jewellery located in the United Kingdom or the Isle of Man having been lawfully imported there (Regulation 60GC). Minor consequential amendments to: regulation 60A (trade: exceptions in relation to personal effects etc.); regulation 85 (trade enforcement: application of CEMA); and Schedule 3DA (revenue generating goods). |
11 December 2023 |
General Trade Licence: Iron and steel products |
A General Trade Licence has been granted which authorises activity in respect of certain iron and steel products which would otherwise be prohibited under Chapter 4C (Regulations 4D to 46I), as follows:
This General Trade Licence took effect from 11 December 2023 and has no expiry date. |
Trade sanctions: Introduction of a new unit to enforce trade sanctions – the Office of Trade Sanctions Implementation |
The UK Government has announced the introduction of a new unit - the Office of Trade Sanctions Implementation (OTSI) - which will be responsible for the civil enforcement of trade sanctions, including those against Russia. OTSI will help businesses comply with sanctions, investigate potential breaches, issuing civil penalties and referring cases to HMRC for criminal enforcement where needed. OTSI will launch in early 2024 once the new legal requirements are in place. |
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9 December 2023 |
General Licence: Local Authorities Payments [INT/2023/3781228] |
The General Licence permits the payment of (i) Council Tax or rates charged on domestic properties; (ii) non-domestic rates, and (iii) any associated late penalties or fees, to Local Authorities in the UK by or on behalf of a Designated Person (Permitted Payments).
For the purposes of this General Licence "DP" does not include persons sanctioned by the United Nations. DPs and persons acting on their behalf must report any payments made under this General Licence within 14 days. DPs must also keep records of the same. This General Licence took effect from 00:01 am on 9 December 2023 and has no expiry date. |
8 December 2023 |
Belarus: Asset freeze – additions |
The UK, US and Canada announced a package of sanctions targeting individuals linked to human rights abuses around the world, ahead of the 75th anniversary of the Universal Declaration of Human Rights on 10 December. The list of those targeted by the UK includes 17 Belarusian individuals including judges, prosecutors and an investigator involved in politically-motivated cases against political activists, independent journalists and human rights defenders. They have been added to the consolidated list and are now subject to an asset freeze:
Designations were also made under a number of the UK's other sanctions regimes but these are outside the scope of this tracker. |
7 December 2023 |
Asset freeze - additions The Cyber (Sanctions) (EU Exit) Regulations 2020 |
2 individuals have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:
The individuals have been sanctioned in connection with their role in cyber operations by the Russian Security Service (FSB) intended to interfere in UK political processes. These designations have been made under the UK's cyber sanctions regime. |
6 December 2023 | Asset freeze – additions Press release |
25 individuals and 20 entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions. These designations include:
The individuals sanctioned are:
The entities sanctioned are:
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Belarus: Asset freeze – additions |
1 entity has been added to the consolidated list and is now subject to an asset freeze: JSC Display Design Bureau |
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NCA Red Alert: Exporting High Risk Goods |
The National Crime Agency has issued a Red Alert to financial institutions and other members of the regulated sector informing UK businesses about common techniques suspected to be in use to evade sanctions on the export of high-risk goods, which Russia is using on the battlefield in Ukraine. The primary audience for this alert is the UK’s financial sector, including banks, credit card operators, foreign exchange dealers and non-bank payment service providers. It may also be relevant to business sectors outside the regulated sector for anti-money laundering, in particular customs brokers, freight forwarders and other transportation and logistics providers. |
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G7 Leaders' Statement: sanctions on Russian diamonds and other future measures |
The G7 leaders published a statement following a (virtual) meeting on 6 December 2023. As part of that statement, they provided further details regarding their intention to introduce sanctions on Russian diamonds, which will comprise:
The G7 leaders repeated their call for third parties to immediately cease providing material support to Russia’s aggression, or face severe cost. In respect of other future sanctions measures, the G& leaders stated that they would:
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1 December 2023 |
Enforcement: HMRC compound settlement – Notice 2023/23 |
On Friday, 1 December, HMRC issued a Notice to Exporters regarding recent fines for unlicensed exports of Dual Use goods. Between August and November 2023, HM Revenue and Customs (HMRC) issued compound settlement offers to three UK exporters totalling in excess of £77,000.00.
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24 November 2023 |
General Licence: Correspondent Banking Payments – amendment [INT/2023/3566356] |
The General Licence permitting a Credit or Financial Institution to return a Relevant Payment to the Credit or Financial Institution which sent the Relevant Payment directly to it, so long as neither the sending or receiving Credit or Financial Institution are a designated person, has been extended and will now expire at 23:59 on 14 December 2023. See entry at 29 September 2023 for more information. |
17 November 2023 | FCDO / OFSI Guidance - Ownership and Control: Public Officials and Control |
The Foreign Commonwealth and Development Office (FCDO) and the Office of Financial Sanctions Implementation (OFSI) have issued joint guidance relating to ownership and control in UK sanctions regimes. This guidance is applicable to all sanctions regimes, including the Russia (Sanctions) (EU Exit) Regulations 2019. In summary, that guidance provides that:
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15 November 2023 | OFSI Blog - One Year On: The OFAC-OFSI Enhanced Partnership | OFSI has published a blog post marking one year since the launch of the OFAC-OFSI Enhanced Partnership, an ongoing commitment from the two sanctions authorities to deepen their collaboration. The post sets out the joint activities which have been undertaken in the past year, including a multi-day technical exchange in London in October 2023. |
13 November 2023 | General Licence: LCIA Arbitration Costs – amendment (INT/2022/1552576) |
OFSI has amended this General Licence to remove the Annex 1 schedule of arbitration costs, and changes the definition of arbitration costs to reflect the relevant Schedule of Costs for LCIA arbitration. See the original entry for this general licence dated 17 October 2022 for further detail. |
10 November 2023 | General Licence: Russian Travel – amendment (INT/2022/1839676) |
OFSI has amended this General Licence to make clear that Paragraph 4.1 only permits the purchase of tickets from a Designated Person or any subsidiary for passenger rail or passenger air journeys originating in, or within, Russia. |
9 November 2023 | 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:
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8 November 2023 |
Asset freeze - additions |
20 individuals and 9 entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions. These entities / individuals are operating in and supporting Russia's gold, oil and strategic sectors, and include both Russian oligarchs and businesses, and third country enablers fuelling Russia's war revenues.
The entities sanctioned are:
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NCA Red Alert: Gold-based Financial and Trade Sanctions Circumvention |
The National Crime Agency has issued a Red Alert to financial institutions and other members of the regulated sector warning that Russia is using gold as a means to undermine the impact of the UK sanctions regime. The purpose of the Alert is to provide information on common techniques sanctioned individuals and entities, and their enablers, are suspected to be using to evade sanctions related to gold. The London Over the Counter (OTC) market has historically been the centre of the gold trade and attracts participants from all around the world. They are responsible for setting the twice daily global reference benchmark for gold. Traders, financial institutions and other market participants should ensure that, as part of their due diligence, they are aware of the common circumvention techniques set out in the alert, and the risks and obligations in relation to Russia sanctions and gold. |
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27 October 2023 |
General Licence: Continuation of Business and Basic Needs for Telecommunications Services and News Media Services – amendment [INT/2022/1875276] |
OFSI has amended this General Licence to clarify that:
The Licence has also been extended to 30 May 2026. See entries at 30 May 2022, 26 June 2023 and 23 August 2023 for more information on this General Licence. |
25 October 2023 |
[EXPIRED] |
THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/4671884 (29 April 2024)
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19 October 2023 |
General Licence: Payments to Companies House – amendment. [INT/2023/3626884] |
OFSI has amended the "Payments to Companies House" General Licence to:
the payment of fees owed by or due from UK DPs to Companies House for filing a confirmation statement (previously known as an annual return) in respect of the payment of late filing penalty fees owed by or due from UK DPs to Companies House incurred as a result of late filing of
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17 October 2023 | UK guidance on the interception and monitoring prohibitions in UK sanctions on Russia and Belarus |
The Export Control Joint Unit (ECJU) has released a technical guidance on the interception and monitoring prohibitions in UK sanctions on Russia and Belarus. This guidance provides further information on the meaning of the following 14 specific terms used in the schedules to these regulations. The schedules in the legislation cover goods and software which can perform the following functions:
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16 October 2023 | UK Government statement following the Court of Appeal judgment in Mints & Others v PJSC National Bank Trust & another |
The UK Foreign, Commonwealth and Development Office (FCDO) has released a statement following the Court of Appeal judgment in Mints & others v PJSC National Bank Trust & another: "The Government is carefully considering the impact of the Court of Appeal’s judgment in Mints & others v PJSC National Bank Trust & another, in particular the Court's views that PJSC National Bank Trust is 'controlled' by Designated Persons by virtue of their political office, noting that the case was not decided on this point. In response to that statement, OFSI stated that it "has consulted with the FCDO in its considerations following the judgement and supports this statement. OFSI will continue to work with our stakeholders to understand the impacts, particularly in respect of financial sanctions". |
13 October 2023 |
General Licence: Payment to Energy Companies for Gas and/or Electricity - amendment [INT/2022/2300292] |
OFSI has amended the "Payment to Energy Companies for Gas and/or Electricity" General Licence to:
This GL allows for payment to utility companies for gas and electricity by UK designated persons who own or rent properties in the UK. For further details, see the entries at 17 November 2022 and 24 February 2023 below. |
12 October 2023 | Oil Price Cap: Price Cap Coalition statement and maritime safety advisory |
The Oil Price Cap Coalition (Australia, Canada, the European Union, France, Germany, Italy, Japan, the United Kingdom, and the United States) have issued the following documents in respect of the price caps on seaborne Russian oil:
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10 October 2023 |
General Licence: Prior Obligations - amendment [INT/2023/3024200] |
OFSI has made a number of amendments to the "Prior Obligations" General Licence, including:
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6 October 2023 | General Licence: Payments to Companies House [INT/2023/3626884] Publication notice |
OFSI has issued a General Licence permitting Designated Persons (DPs) / persons acting on their to make Permitted Payments to Companies House. "Permitted Payment" means:
Persons acting on behalf of UK DPs for this purpose, and financial institutions, are permitted to receive and process the above payments. The General Licence does not permit payment by any person designated by the United Nations. Subject to reporting and record-keeping requirements. The licence does not have an expiry date. |
2 October 2023 |
Trade restrictions: licencing grounds – divestment from Russia |
The UK has updated its Russia Guidance to add additional licencing grounds for trade activities that would otherwise be prohibited. A licence may be granted for the activities below if the activity is necessary for the purposes of divestment from Russia, subject to certain conditions:
The Export Control Joint Unit (ECJU) is responsible for administering the trade licensing provisions on behalf of the Department for Business and Trade. |
30 September 2023 |
Trade restrictions: third country processed iron and steel measures – measure in force |
The restrictions relating to Russian iron and steel processed in third countries are in force as of 30 September 2023. The measures were introduced on 20 April 2023 – for further detail see the original entry for 20 April below. |
29 September 2023 |
Asset Freeze - additions |
10 individuals and 1 entity have been added to the consolidated list and are now subject to asset freeze and trust services sanctions. The individuals sanctioned are:
The entity sanctioned is the Russian Central Election Commission. |
General Licence: Correspondent Banking Payments (Russia and Belarus) [INT/2023/3566356] |
OFSI has issued a General Licence permitting a Credit or Financial Institution to return a Relevant Payment to the Credit or Financial Institution which sent the Relevant Payment directly to it, so long as neither the sending or receiving Credit or Financial Institution are a designated person (DP). "Relevant Payment" means a payment;
This licence is issued for the purpose of providing certainty and does not reflect a view that UK financial sanctions are engaged by the actions referred to in this licence. Any act which would otherwise breach the prohibitions in Regulations 11 to 15 of the Russia Regulations or the Belarus Regulations is exempt from those prohibitions to the extent required to give effect to the permissions in this licence. This licence took effect from 29 September 2023 and expires at 23:59 on 1 December 2023. |
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27 September 2023 |
Guidance: Exporting Commercial Goods - Russia Sanctions – Common High Priority Items List See also: US press release |
Australia, Canada, New Zealand, the UK, and the US (collectively referred to as "the Export Enforcement Five" or "E5") have issued joint guidance to industry and academia identifying high priority items critical to Russian weapons systems and urging specific actions to prevent diversion of these items to Russia through third countries. The Guidance contains a list of 45 prioritized Harmonized System (HS) codes containing items Russia needs for its weapons systems, of which nine codes are the highest priority. The list will be updated when required. The Guidance also contains information on diversion concerns as well as due diligence tips for screening such parties, and red flag indicators. |
21 September 2023 |
General Licence: Payment to water companies for water and sewage [INT/2023/3179120] |
OFSI has issued a General Licence which permits payment to water companies for water and sewage services by UK designated persons (DPs) who own or rent properties in the UK. The General Licence permits:
This licence takes effect from 21 September 2023 and expires at 23:59 on 20 September 2025. |
14 September 2023 |
General Licence: Oil Price Cap – exempt projects and countries – amendment (Sakhalin-2 Project) [INT/2022/2470156] |
The General Licence has been amended to extend the expiration date of the exemption for the Sakhalin-2 Project to 28 June 2024 (see: Schedule 1 - Exempt Projects). See also: publication notice |
12 September 2023 | Guidance – third country processed iron and steel measures |
The Department for Business & Trade and the Department for International Trade have published a notice explaining the scope of the measures relating to Russian iron and steel processed in third countries, including:
The measures were introduced on 20 April 2023 (see below) are due to come into effect on 30 September 2023. |
7 September 2023 |
Asset freeze – additions Cyber Sanctions – Russian cybercrime group designated (Notice) The Cyber (Sanctions) (EU Exit) Regulations 2020 (S.I. 2020/597) |
11 members of a Russian cybercrime group have been designated and are now subject to an asset freeze. This was the cyber criminal gang behind the Trickbot/Conti ransomware attacks, which included the hacking of crucial infrastructure and hospitals during the COVID-19 pandemic. The individuals designated are:
This was a joint action by the UK FCDO and the US OFAC. |
31 August 2023 |
Enforcement: OFSI disclosure of sanctions breach (Notice) Guidance: OFSI enforcement and monetary penalty guidance - update |
OFSI has used its disclosure powers for the first time, by disclosing that a UK fintech firm had breached financial sanctions after a cash withdrawal of £250 was made from a business account held by a company owned or controlled by a Designated Person. In particular, OFSI found that the firm's systems and controls in response to the sanctions designation were inappropriate. Where OFSI decides it is necessary and proportionate, OFSI will publish details of a breach on its website in the form of a notice. The intention is to use the power in response to moderately severe breaches, when a warning letter would be too lenient but a monetary penalty would be disproportionately punitive. OFSI has also updated Section 10 of its Enforcement and Monetary Penalty Guidance to provide further detail on how it assesses the severity of breaches. |
23 August 2023 |
General Licence – Amendment Telecommunications Services and News Media Services |
OFSI has made an amendment to this General Licence to clarify that:
See entries at 30 May 2022 and 26 June 2023 for more information on this General Licence. |
General Licence – Amendment GTLK Companies and their Subsidiaries – Insolvency related payments and activities - INT/2023/3263556 |
OFSI has made an amendment to this General Licence to make clear that STLC Europe Nine Leasing Limited is covered by the General Licence. Annex 1, which provides a list of non-exhaustive subsidiaries, has been amended to reflect this. See entry at 1 August 2023 for more information on this General Licence. |
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22 August 2023 | Enforcement – HMRC compound settlement (Notice NTE 2023/17) | In August 2023, a UK company was fined £1 million by HM Revenue & Customs (HMRC) in relation to the unlicensed trade of goods in breach of The Russian (Sanctions) (EU Exit) Regulations 2019. The Notice provides no further details. |
11 August 2023 |
General Trade Licence: Russia sanctions: Legal Advisory Services See Notice to Exporters NTE 2023/16 [NOW REVOKED] |
THIS GENERAL TRADE LICENCE WAS REVOKED ON 6 SEPTEMBER 2024 – SEE ENTRY ABOVE
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8 August 2023 |
Asset Freeze additions |
10 individuals and 9 entities have been added to the consolidated list and are now subject to asset freeze and trust services sanctions. The individuals sanctioned include:
The entities sanctioned include:
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Belarus: Asset Freeze – additions |
6 entities have been added to the consolidated list and are now subject to an asset freeze:
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4 August 2023 | Oil Price Cap and Maritime Services Ban: updates to Reporting Forms |
OFSI has updated its reporting forms for the Oil Price Cap (OPC) and Maritime Services Ban General Licences. The updates provide additional information on the following:
OFSI strongly encourages use of the new forms immediately, however previous versions will still be accepted after 4 August 2023. |
1 August 2023 |
General Licence: GTLK Companies and their Subsidiaries – Insolvency related payments and activities INT/2023/3263556 |
This General Licence permits:
This licence is subject to a condition that 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 the GTLK Companies and any of their Subsidiaries. The licence has notification and record-keeping requirements and takes effect from 1 August 2023 and expires at 23:59 on 31 July 2025. This General Licence has been amended – please see entry at 23 August 2023. |
31 July 2023 | Asset Freeze – additions |
6 individuals have been added to the consolidated list and are now subject to asset freeze and trust services sanctions:
The individuals have been designated for their involvement in the politically motivated conviction of Vladimir Kara-Murza, after Mr Kara-Murza lost his appeal in Moscow on 31 July 2023 and faces 25 years in prison. For more information, see this Press Release. |
27 July 2023 |
General Licence: Mongolia Energy Payments amendment INT/2022/2085212 |
The General Licence permitting payments to a Sanctioned Bank or a Subsidiary for the purpose of making energy available for use in Mongolia has been extended and will now expire at 23:59 on 14 August 2025. See entry at 16 August 2022 for more information. |
26 July 2023 | OFSI General Guidance: rejected licence applications - amendment |
OFSI has updated its general guidance relating to options available following a rejected licence application. The amendment removes the option to request from OFSI a review of its decision. Paragraph 6.12 of the General Guidance now provides that if you have had an application for a licence refused, you have the following options:
A challenge to a decision in the courts will require application to the High Court or Court of Session in Scotland. |
20 July 2023 |
Overseas territories: Order in Council extending UK sanctions The Russia (Sanctions) (Overseas Territories) (Amendment) (No.2) Order 2023 |
This order makes the necessary amendments to give effect in the relevant British overseas territories to the following changes made to the Russia sanctions regime pursuant to the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 (S.I. 2023/440); the Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2023 (S.I. 2023/665) and the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 (S.I. 2023/713):
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20 July 2023 |
Asset Freeze - removal |
The following individual has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions:
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17 July 2023 |
14 entries have been added to the consolidated list and are now subject to asset freeze and trust services sanctions:
The designations are said to be in response to Russia's attempts to destroy Ukrainian national identity, including 11 against those involved in the forced deportation of Ukrainian children. |
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12 July 2023 |
OFSI Guidance: update to licensing process - Returning incomplete applications – OFSI Blog Updated General Guidance |
OFSI has issued an update to its General Guidance and published a blog post on updates to the licensing process in relation to incomplete applications for a specific licence, or an amendment to an existing specific licence. To help mitigate the impact on applicants, OFSI has until now been returning incomplete applications to the applicant, and engaging until sufficient details and evidence have been received. The blog post explains that OFSI will be ending this temporary measure and will return applications which are not complete at the time of receipt. Applicants will be able to reapply, but this will be treated as a new application. The blog suggests that to ensure an application is complete, an applicant may wish to:
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6 July 2023 |
Asset Freeze - removal |
The following individual has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions:
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29 June 2023 (in force 30 June 2023) |
Trade restrictions– access to UK legal expertise: A new prohibition on the provision of legal advisory services (amendment to Chapter 6B of Part 5) The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2023 |
The UK Government has imposed prohibitions on the provision of legal advisory services – Regulation 54D. A person must not directly or indirectly provide legal advisory services to any person who is not a UK person in relation to, or in connection with, specified activity which would be prohibited under the UK sanctions regime if the activity was done by a UK person or was taking place in the UK. The specified activities which would contravene the UK sanctions regime are certain financial or trade activity (under Regulations 11 to 18C of Part 3 (asset-freeze and other financial and investment restrictions), and Chapters 2 to 6 or Chapter 6B of Part 5 (trade restrictions)). "Legal advisory services" is defined to mean the provision of legal advice to a client in certain non-contentious matters. It does not include any representation, advice, preparation of documents or verification of documents undertaken as part of legal representation services provided in, or in anticipation of (i) any proceedings before administrative agencies, courts or other duly constituted official tribunals; or (ii) arbitral or mediation proceedings. This is subject to exceptions and licences. A government Press Release has stated that the new law will "prevent UK lawyers from advising Russian companies in certain business deals – thwarting the nation from benefitting economically from the UK's world-leading legal expertise". |
Trade restrictions– access to UK legal expertise: Exceptions (amendment to Part 7) |
Exceptions are introduced to the new prohibition on legal advisory services – Regulation 60DB. These include providing legal advisory services:
An amendment is also made to Regulation 61 to ensure an exception for emergencies in certain cases. |
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Trade restrictions–: (amendment to Regulation 60DA) |
New exceptions are introduced to the prohibition on the provision of professional and business services to a person connected with Russia for:
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28 June 2023
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OFSI/OFAC Fact Sheet – Humanitarian Assistance and Food Security |
OFSI have published a joint fact sheet with OFAC to provide clarity on US and UK Russia sanctions. The statement provides guidance for use by humanitarian actors, NGOs, financial institutions, and companies engaged in agricultural trade or the provision of medical supplies and assistance, when engaging in transactions impacted by sanctions. The statement answers FAQs from both a US and UK perspective. This include questions on:
The joint statement also sets out a summary of key authorisations for certain activities both within the UK and US jurisdictions, and key humanitarian guidance. |
26 June 2023 |
General Licence - Telecommunications Services and News Media Services (Continuation of Business and Basic Needs) - amendment (INT/2022/1875276) |
OFSI have published amendments to the 'Telecommunications Services and News Media Services (Continuation of Business and Basic Needs)' General Licence as follows:
See entry at 30 May 2022 for more information on this General Licence. See entry at 23 August 2023 for information on an amendment to this General Licence, with PJSC MegaFon included as Civilian Telecommunications and News Media Services DPs. |
General Licence – Evraz – amendment (INT/2022/1710676) |
The General Licence permitting the continuation of business operations involving the North American subsidiaries of Evraz plc has been extended and will now expire at 23:59 on 31 March 2024. In addition, the definition of North American Subsidiaries under the General Licence was amended on 4 May 2023 to make clear that the subsidiaries of Evraz Inc. NA and Evraz Inc. NA – Canada are covered by the General Licence. See entry at 5 May 2022 for more information on this General Licence. |
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20 June 2023 |
General Licence: Humanitarian activity – amendment
(INT/2022/1947936) |
OFSI have published amendments to the "Humanitarian Activity" General Licence, as follows:
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19 June 2023 (in force 20 June 2023) The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2023 |
Russia (Sanctions) (EU Exit) Regulations 2019: updated purpose (amendment to Regulation 4) |
Amendment to introduce a new purpose to the 2019 Regulations to state that, in addition to the current purposes in regulation 4, the regulations are for the purposes of:
The Explanatory Memorandum states that this change "reflects the UK position that Russia bears full responsibility or the war and the damage it has caused, including to Ukraine’s critical infrastructure, The UK considers that sanctions measures can contribute to the objective to make sure Russia pays compensation for the damage it has caused". |
Trade sanctions: amendment to extend existing restrictions to include the Kherson and Zaporizhzhia Oblasts (various) |
Amendment to the existing definition of "non-government controlled Ukrainian territory" to include the non-government controlled areas of the Kherson and Zaporizhzhia oblasts. A number of consequential amendments to extend existing sanctions and relevant exceptions to these non-government controlled areas:
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19 June 2023 |
Designated individuals - voluntary donation of assets (announced but not yet implemented) |
The UK Government has stated that it intends to introduce a route for sanctioned individuals who support Ukraine to voluntarily donate their frozen funds for Ukrainian reconstruction. The precise mechanics of the fund which will disburse these donations will be announced in due course. The Government has stated that there will be no coercion of individuals to encourage them to transfer funds, nor any offer of sanctions relief in return for making a donation. More information will be included on this tracker once available. |
Increased reporting obligations (announced but not yet implemented) |
The UK Government has stated that it intends to pass new legislation imposing additional reporting obligations, as follows:
More information will be included on this tracker once available. |
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14 June 2023 |
Oil Price Cap: updated OFSI guidance |
OSFI has published updated guidance for the Maritime Services Ban and Oil Price Cap, to provide additional clarity and detail on the following:
Bespoke reporting forms for required reporting, reporting suspected breaches, and specific licence applications are on OFSI's website. Any reporting or queries should be directed to oilpricecap.OFSI@hmtreasury.gov.uk |
General licence: Oil Price Cap - Trading in Derivatives and Futures (INT/2023/3074680) |
This General Licence permits:
"Derivative" means a financial instrument whose value is based on the change in value of an underlying asset. "Derivatives Broker" means a person who buys and sells assets for others. "Futures" means a type of derivative contract to buy or sell a specific commodity asset or security at a set future date for a set future price. This licence takes effect from 14 June 2023 and is of indefinite duration. |
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General licence: Securing Energy for Europe General Licence – revoked (INT/2022/2305324)
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OFSI has revoked the "Securing Energy for Europe" General Licence. The nationalisation of Gazprom Germania (renamed Securing Energy for Europe) means that Gazprom's UK subsidiaries are no longer in scope of the credit restrictions introduced by The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022, which this General Licence was designed to lift. OFSI therefore no longer considers there to be a need for this General Licence. |
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8 June 2023
Belarus: new sanctions package The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023 UK Government press release |
Belarus: amendments to designation criteria (amendment to Regulation 6) |
Additions to / further explanation of the criteria for designation by expanding the definition of "involved person" to include:
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Belarus: amendments to restrictions on dealing with securities/money-market instruments (amendments to Regulation 15A) |
Expanding the existing restrictions to include securities/money-market instruments issued by persons acting on behalf or upon the direction of Belarus, a Belarusian authority, or an entity wholly owned by Belarus or a Belarusian authority. |
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Belarus: trade restrictions – export of goods /technology to Belarus (amendments to Regulations 21-26) |
Expanding the existing restrictions on exports (including the supply from a third country) to or for use in Belarus to include:
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Belarus: trade restrictions – import of goods/ technology from Belarus (amendments to Regulations 27I-27M) |
Expanding the existing restrictions on imports from Belarus (including the supply to countries outside the UK) to include:
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Belarus: prohibition on providing certain internet services (new Regulations 27P, 45A, 56A and B) |
New restrictions requiring providers of:
"designated person" means a person who is designated under regulation 5 for the purposes of this new regulation 27P (i.e. not a person designated for the purposes of an asset freeze). OFCOM has the power to request a person to provide certain information for the purpose of monitoring compliance with or detecting evasion of regulation 27P. OFCOM has the power to impose a monetary penalty up to £1 million for breach of regulation 27P or 45A. |
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Belarus: new exceptions to prohibitions (various) |
Introduction of certain exceptions for the new prohibitions, including:
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6 June 2023 | General Licence - Transactions related to agricultural commodities – amendment (INT/2022/2349952) |
The General Licence was amended to allow the Grain and Feed Trade Association (GAFTA) to receive Funds and Economic Resources from any person in connection with the direct and indirect provision of services related to contracts for the trade in agricultural commodities, by or on behalf of GAFTA. See the original entry for this general licence dated 4 November 2022 for further detail. |
5 June 2023 | General Licence – LCIA costs – amendment (INT/2022/1552576) |
The General Licence INT/2022/1552576 was amended to allow:
See the original entry for this general licence dated 17 October 2022 for further detail. |
30 May 2023 | Trade sanctions: Common High Priority Items List - Foreign, Commonwealth & Development Office update |
The FCDO has issued a communication identifying a "Common High Priority Items List" composed of Western items critical to Russian weapons systems and its military development. The communication states that businesses should undertake due diligence to ensure that the end destination of these items is not Russia. Together with its international partners, the UK has identified items that Russia is using in its weapons system. Many of these have been found on the battlefield in Ukraine. They include electronic components such as integrated circuits and radio frequency (RF) transceiver modules. The list, which will be updated when required, also includes items that are essential for the manufacturing and testing of the electronic components and circuits retrieved from the battlefield. The list is divided into four Tiers:
The UK is working with international partners to tackle sanctions avoidance and evasion including closing routes that Russia is potentially using to circumvent sanctions. |
Trust Services Sanctions: OFSI blog post – 5 months on |
OFSI has published a blog post 5 months on from Trust Services sanctions coming into effect on 16 December 2022. The blog aims to provide further clarity on themes arising from questions OFSI has received. The blog covers when Trust Services sanctions apply, where the sanctions apply, key exceptions, OFSI's enforcement powers and licensing. See also: OFSI's homepage on trust services sanctions. |
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22 May 2023 | General Licence – Prior Obligations (Russia and Belarus) |
OFSI has issued a General Licence which permits a Designated Person to transfer funds or economic resources to UK persons in satisfaction of a contractual obligation, provided that:
A bank or financial institution, which is itself a Designated Person and required to process payments made in accordance with this licence, may process such payments. |
Notice to Exporters – Trade sanctions circumvention |
The UK Department for Business & Trade has published a guidance note for companies to help them understand what they need to do to ensure they are complying with the Russia sanctions. The aim of the notice is to prevent the undermining of trade sanctions, export controls and other restrictive measures designed in response to Russia's invasion of Ukraine. The guidance covers:
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19 May 2023 |
G7 Leaders' Statement on Ukraine |
The G7 leaders published a statement of continued commitment against Russia's war against Ukraine, following the G7 meeting in Hiroshima on 19 May.
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Asset freeze – additions and removals |
86 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:
The entities include the following banks: DOM.RF, Rosbank PJSC, Tinkoff Bank, Russian Regional Development Bank, and PJSC JSCB Metallinvestbank. These designations target individuals on the Boards of Directors of Sovcomflot, Russian Railways, Gazprom Neft, and Transneft, alongside individuals and entities in the shipping, energy, military and defence sectors. This includes companies connected to the theft of Ukranian grain, the shipment of Russian energy and companies connected to Rosatom, which are producing advances materials and technology in support of Putin's military efforts. Additionally, the following individuals have been removed from the consolidated list and are no longer subject to an asset freeze or trust services sanctions:
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Future trade restrictions announced – but not yet implemented |
Prime Minister Rishi Sunak has announced incoming import bans on Russian diamonds and metals at the G7 in Japan. In further comments made on 22 May 2023, UK Prime Minister Rishi Sunak has also committed to a new package of sanctions. |
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12 May 2023 | OFSI Guidance – Travel expenses/costs |
OFSI has published new guidance to support those applying for a licence to access funds for travel expenses and associated costs. The guidance sets out what information OFSI requires when considering if an application for travel costs is 'reasonable', including consideration of alternatives to travel, pre-planning, necessity and exceptional circumstances. |
28 April 2023 | General Licence – Legal Fees (Russia and Belarus) |
OFSI has issued a General Licence 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 existing Legal Fees General Licence issued on 28 October 2022 expires on 28 April 2023 (see below).
Each has its own set of conditions and there is a separate legal fees and expenses cap for each part. The previous legal fees caps and expenses caps have been reset. Users will be able to make use of the legal fees caps (£500,000 inc. VAT) and the expenses caps (5% of legal fees, up to £25,000) under Parts A and B of the General Licence. The General Licence also contains maximum hourly rates for fee earners. |
21 April 2023 | Asset Freeze |
3 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions for their involvement in a politically motivated case against and arrest of opposition politician Vladimir Kara-Murza:
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20 April 2023 |
Trade restrictions: new category of revenue generating goods – supply to third countries (new Chapter 4GA - Regulations 46XA – 46XG, and Schedule 3DA) |
Prohibition on the following activities in respect of a new category of revenue generating goods (as listed in new Schedule 3DA):
The restrictions in respect of the goods listed in Part 3 of Schedule 3DA will not apply to any goods which are either consigned from Russia or imported into the UK before 21 April 2023. Revenue generating goods that have an important humanitarian or civilian use, such as certain agricultural and energy-related goods (as listed in the amended schedule 3D) are not covered by this new prohibition on supply and delivery from Russia to third countries. The prohibition on the acquisition of these goods, and associated services, do not apply to:
The restrictions are also subject to the existing exceptions, such as humanitarian assistance. The existing Schedule 3D (revenue-generating goods) has been recast in light of these changes. |
Trade Restrictions: amendments to existing restrictions (various) |
Further amendments to existing trade restrictions:
The restrictions in respect of the goods listed in Part 3 of Schedule 3B and Part 3 of Schedule 3D will not apply to any goods which are either consigned from Russia or imported into the UK before 21 April 2023 (Regulation 60G).
A number of these amendments are intended to bring a range of goods found on the battlefield within the scope of existing restrictions. |
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Trade restrictions:–iron and steel products processed in a third country |
Introduction of a new prohibition on the import of specified iron and steel products which have been processed in a third country and which incorporate one or more iron or steel products originating in Russia on/after 30 September 2023. The "iron and steel products" are listed in Schedule 3B. For the purposes of this restriction, "processed" means altered; transformed in any way; or subjected to any other type of operation or process. Includes a prohibition of the provision of associated technical assistance, financial services and funds, and brokering services. |
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18 April 2023 | High Value Dealer Guidance | OFSI has published guidance on financial sanctions implementation for high value dealers, luxury goods markets and art market participants. |
14 April 2023 |
General Licence - Lithuania Rail |
This General Licence permits:
This licence takes effect from 14 April 2023 and expires at 23:59 on 13 April 2025. |
Updated guidance– UK's ban on Russian oil and oil products |
The updated guidance clarifies the position on co-mingling and provides information on what suppliers should do to ensure they comply with sanctions. The update reinforces that the prohibitions apply regardless of the importer's knowledge or suspicions about the origin of the goods, their location or the place from which they were consigned. Breaching the prohibitions can be a criminal offence. |
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12 April 2023 | Asset Freeze |
14 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions:
These designations are said to target those who have knowingly assisted sanctioned Russia oligarchs to hide their assets in complex financial networks. |
6 April 2023 | Updated OFSI Guidance – UK Maritime Services Ban and Oil Price Cap |
OFSI has updated its "UK Maritime Services Ban and Oil Price Cap" industry guidance. This document provides guidance regarding the UK ban on the provision of maritime transportation of certain Russian oil and oil product, and associated services. See entry dated 3 November 2022 for more information on the introduction of this prohibition. |
28 March 2023 | General Licence – bond amendments and restructurings |
Permits:
These permissions are subject to the condition that no funds or economic resources are to be made available, directly or indirectly, to a Designated Person. Any funds or economic resources that a Designated Person would be entitled to as part of a bond restructuring or amendment must be frozen. |
21 March 2023 | Trust Services - update on Designated Persons | The Foreign, Commonwealth & Development Office confirmed that from 21 March 2023 all persons designated under the UK's Russia financial sanctions regime for the purposes of asset freezes have been designated for the purpose of trust services restrictions (Regulation 18C). The UK's Sanctions List has been updated accordingly. For more information, see the OFSI blog and the OFSI notice. |
General Licence - winding down of trust services provided to Designated Persons |
Permits any activity necessary to terminate an arrangement for the provision of trust services to a Designated Persons which would otherwise be prohibited under Regulation 18C, including:
The General Licence allows for a 90-day period from the date on which a Designated Person becomes designated for the purposes of Regulation 18C to undertake any of the permitted activity. Use of the General Licence requires a reporting form and associated evidence to be submitted to OFSI within 30 days of undertaking an activity under the General Licence. Use of the General Licence is also subject to a 6-year record-keeping requirement. |
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17 March 2023 | Asset freeze- removal |
The following individual has been removed from the consolidated list and is no longer subject to an asset freeze:
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16 March 2023 | Updated guidance- Enforcement and monetary penalties for breaches of financial sanctions |
OFSI has updated its guidance covering enforcement and monetary penalties for breaches of financial sanctions. New sections relating to ownership and control have been included under sections 3.22-3.31. In summary, the updated guidance provides that:
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13 March 2023 | New UK Integrated Security Fund- Press release |
The UK Prime Minister announced the launch of a new fund (UKISF) to support the new Economic Deterrence Initiative (see entry below for more info). The UKSIF will have a budget of approximately £1 billion and will combine several other funds across the government. An additional £50 million in funding has been provided, notably to improve enforcement of the UK’s sanctions regime. The government will also work with the private sector to maximise the reach of sanctions against those who pose a threat to the UK. |
Government priority actions: sanctions evasion (see also: Press Release) |
The UK government published its ‘Integrated Review Refresh 2023: Responding to a More Contested and Volatile World’ (IR23). The IR23 sets out a number of priority actions for the UK government. This includes establishing an "Economic Deterrence Initiative" to improve the UK's sanctions implementation and enforcement by strengthening the UK's diplomatic and economic tools. The IR23 also indicated that the UK government will:
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9 March 2023 |
Overseas territories: The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2023 |
This Order makes the necessary amendments to give effect in the relevant British overseas territories to the following changes made to the Russia sanctions regime pursuant to the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022:
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8 March 2023 | Updated Guidance- UK Maritime Services Prohibition and Oil Price Cap | OFSI has updated its "UK Maritime Services Prohibition and Oil Price Cap" industry guidance following the introduction of the price cap on refined Russian oil products on 5 February 2023 and the associated wind down period (please see entries dated 3 November and 3 February 2022 below for more information). |
24 February 2023 | Potential new legislation - Seizure of Russian State Assets and Support for Ukraine Bill |
The House of Commons has objected to the "Seizure of Russian State Assets and Support for Ukraine Bill" (see entry dated 7 February 2023 for more info). The Bill was introduced under the "Ten Minute Rule" and had its second reading (i.e. this was the first opportunity for MPs to debate the main principles of the Bill). The Bill requires the Secretary of State to lay before Parliament proposals for the seizure of Russian state assets to provide support for Ukraine. Under the Bill, the Secretary of State must consider the following in preparing the proposals:
The next sitting of the House of Commons to consider the Bill will be on 3 March 2023. |
(See also Government press release) |
92 entries have been added to the consolidated list and are now subject to an asset freeze. These include:
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New package of sanctions- Press release (announced but not yet implemented) |
In addition to the new designations (above), the UK has announced a new package of additional sanctions. This includes:
[Note: A more detailed breakdown of new restrictive measures will be included on this page once the relevant legislation has been published.] |
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General Licence- Extensions |
OFSI has extended the expiry dates of the following general licences:
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16 February 2023 | House of Commons Research- "Sanctions against Russia" and "Post-conflict reconstruction assistance to Ukraine" |
The House of Commons Library published two research briefings: "Sanctions against Russia" and "Post-conflict reconstruction assistance to Ukraine". The "Sanctions against Russia" paper provides an overview of the evolution of the UK sanctions regime since Russia's invasion of Ukraine; The "Post-conflict reconstruction assistance to Ukraine" paper addresses the question of whether Russian sanctioned assets could be used for Ukraine's reconstruction and outlines the main legal issues with the proposal. In summary:
Please refer to entries dated 20 January 2023 and 7 February 2023 below for more background information. |
General Licence - Evraz - extension | The General Licence permitting the continuation of business operations involving the North American subsidiaries of Evraz plc has been extended and will now expire on 30 September 2023 (see entries from 5 May 2022 and 18 August 2022 for more information). | |
General Licence – Amendment to Russian flight and railway travel licence |
OFSI has amended the General Licence permitting a UK national/entity to purchase tickets from certain designated Russian travel companies, or any subsidiary, for flights or rail journeys within Russia or originating in Russia (see entry dated 23 May 2022 for more information). The updated General Licence now permits:
This licence took effect from 23 May 2022 and expires on 23 May 2024. |
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9 February 2023 | Asset Freeze (Cyber Sanctions Regime) |
7 Russian individuals have been added to the consolidated list under The Cyber (Sanctions) (EU Exit) Regulations 2020. The sanctioned individuals form part of a Russian cybercrime group, Trickbot, and was one of the first cybercrime groups to back Russia's war in Ukraine according to the NCA. They have been sanctioned for their involvement in cyberactivity intended to undermine the integrity of the UK and other countries, or cause economic loss/prejudice commercial interests. OFSI simultaneously published its Ransomware and Sanctions Guidance. Note: These individuals do not explicitly bear a connection to Russia's invasion of Ukraine under OFSI's notice. |
8 February 2023 | Asset freeze |
15 new entries have been added to the consolidated list and are now subject to an asset freeze. This includes the following individuals:
The new entries also include the following entities:
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7 February 2023 | Upcoming legislation- Seizure of Russian State Assets and Support for Ukraine Bill |
The "Seizure of Russian State Assets and Support for Ukraine Bill" had its first reading in Parliament on 7 February. The Bill would require the British Government to present plans to seize Russian assets frozen in the UK due to sanctions, and allocate them to Ukraine and the Ukrainian people. These powers of seizure would not apply to individuals' assets, but only to Russian state assets, bypassing the concept of sovereign immunity. The EU also introduced the idea of using frozen Russian assets for the reconstruction of Ukraine in November 2022 (Accountability for international crimes- EU Press Release). The next stage for the Bill (second reading) is scheduled to take place on Friday 24 February. This will be the first opportunity for MPs to debate the general principles and themes of the Bill. |
Updated Guidance – Professional and business services | The Department for International Trade has updated its guidance relating to the supply of professional and business services to a person connected with Russia. The document provides guidance in relation to the sanctions covering the provision of services prohibited on 16 December 2022 i.e. advertising services, architectural and engineering services, auditing services and IT consultancy and design services (please see entry dated 15 December 2022 below for more information). |
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5 February 2023 | Trade restrictions - maritime transportation of 2710 oil and oil products |
The prohibition in respect of oil and oil products with CN code 2710 comes into force on 5 February 2023. This measure was introduced on 3 November 2022 in the "The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022" (see 3 November entry below for more details). |
Updated Guidance - UK Maritime Service Prohibition and Oil Price Cap |
OFSI updated its "UK Maritime Service Prohibition and Oil Price Cap" industry guidance. The guidance outlines obligations under the UK Maritime Services Prohibition and Oil Price Cap exception, as well as OFSI’s approach to implementation and enforcement. |
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3 February 2023 |
Refined Oil Products Winddown General Licence - INT/2023/2660772 [NOW REVOKED] |
[THIS GENERAL LICENCE WAS REVOKED ON 20 DECEMBER 2023 – SEE ENTRY ABOVE]
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THIS GENERAL LICENCE HAS NOW EXPIRED – SEE REPLACEMENT LICENCE INT/2024/4423849
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UK Press Release - Price Cap on |
Following, the implementation of a $60 price cap on Russian crude oil in December 2022, the Price Cap Coalition of the G7, the European Union and Australia have set caps on the price of seaborne Russian oil products, effective from 05 February 2023. High-value Russian exports such as diesel and gasoline, will be capped at USD 100 per barrel while lower-value products such as fuel oil will be capped at USD 45 per barrel. These prices will be kept under review. This measure was legislated for in the “The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022” laid on 3 November 2022 (see entry below). |
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24 January 2023 | Truphone Limited - Secretary of State Order |
Telecoms company, Truphone Limited, has been sold to TP Global Operations pursuant to a licence granted by OFSI. The transaction follows the UK's imposition of sanctions on three of Truphone's owners in 2022, namely, Roman Abramovich, Alexander Frolov and Alexander Abramov (see entries dated 10 March 2022 and 2 November 2022 for more information).
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20 January 2023 | Press release - UK joins core group dedicated to achieving accountability for Russia’s aggression against Ukraine | The UK has joined a coalition of international partners to shape thinking on how to achieve accountability for Russia's aggression against Ukraine. This includes potentially setting up a "hybrid" tribunal (i.e. a specialised court integrated into Ukraine's national justice system with international elements). For context, the International Criminal Court does not have jurisdiction over the crime of aggression allegedly committed by Russia against Ukraine. A new special tribunal on the crime of aggression could help ensure that Russian civilian and military leadership are held accountable for the decision to illegally invade Ukraine. |
19 January 2023 | International Trade Committee - Enquiry into UK trade sanctions on Russia |
The International Trade Committee will launch a new enquiry into the UK's trade sanctions on Russia focusing on the following points:
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19 December 2022 | Trade sanctions - Export Control Joint Unit guidance |
The Export Control Joint Unit (ECJU) published the following:
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16 December 2022 | General Licence - Wind down period (certain new financial sanctions) |
Allows for a 7 day wind down period with respect to certain financial prohibitions introduced by The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022, meaning that:
Please see the entries below for more information regarding each prohibition above. The licence takes effect from 00:01 on 16 December 2022 and expires at 23:59 on 22 December 2022. |
15 December 2022 The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (comes into force on 16 December 2022) |
Disapplication of Banking Act 2009 requirement The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 |
Suspends the Bank of England’s duty under the Banking Act 2009 to make a decision in respect of a notification of third-country resolution action in respect of designated persons or persons owned or controlled by designated persons. Resolution is the process by which regulatory authorities manage the orderly failure of financial institutions. |
Trust services prohibition The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 |
Introduces a new prohibition on providing trust services:
"trust services" means—
Trust services are provided for the benefit of a person (“B”) where—
The prohibition is also subject to a number of specific exceptions - all listed under the new regulation 60ZZB. |
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Financial restrictions - dealing with transferable securities or money-market instruments – new category The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 |
Addition of a new category of transferable security or money-market instrument to the existing prohibitions: It is prohibited to deal, directly or indirectly, with a transferable security or money-market instrument issued:
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Financial and investment restrictions – investments in relation to Russia – amendment to definition of "relevant entity" The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 |
Amendment of the definition of a "relevant entity" for the purposes of the investment restrictions to clarify that a "relevant entity" is "means a person, other than an individual, which (see further detail regarding the investment restrictions below – 19 July 2022) The exceptions to the investment restrictions have also been amended – Regulation 60ZZA. |
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Financial restrictions - Loans and credit arrangements The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 |
Introduces a new prohibition to existing restrictions:
"relevant entity" – see entry immediately above. Also adds a new category of loan to those which are subject to existing restrictions on the granting of loans/credit (see 1 March 2022 and 28 October 2022 entries below). A "Category 6 loan" is a loan or credit:
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Trade restrictions - amendments to existing restrictions (amendments to Schedule 2A and 3C) The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 |
Amendments to existing trade restrictions:
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Trade restrictions - Professional and business services – additional services added [(amendment of regulation 54C)-] The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 |
Introduces a prohibition on the direct and indirect provision of the following additional professional and business services to a person connected with Russia:
Each of these services are defined in more detail under the new Schedule 3J to the Russia (Sanctions) (EU Exit) Regulations 2019. |
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Overseas territories: The Russia (Sanctions) (Overseas Territories) (Amendment) (No. 4) Order 2022 (made on 14 December 2022) |
This Order makes the necessary amendments to give effect in the relevant British overseas territories to the following changes made to the Russia sanctions regime pursuant to the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 and the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022:
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13 December 2022 | Asset Freeze |
15 individuals and 1 entity have been added to the consolidated list and are now subject to an asset freeze. This includes Russian members of the armed forces and Iranian businessmen involved in providing Unmanned Aerial Vehicles (UAVs) for use by the Russian military. The newly added entity is Oje Parvaz Mado Nafar Company which has provided to the Russian military components and engines for UAVs that could contribute to destabilising Ukraine. |
9 December 2022 |
Asset freeze |
1 individual has been added to the consolidated list and is now subject to an asset freeze:
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5 December 2022 | Updated legislation- Immigration (Persons Designated under Sanctions Regulations) (EU Exit) (Amendment) Regulations 2022 |
The UK Parliament debated the Immigration (Persons Designated under Sanctions Regulations) (EU Exit) (Amendment) Regulations 2022. The new regulations seek to clarify that:
A travel ban has an effect on a person’s immigration status; they cannot enter or remain in the UK. The current legislation allows for a person who is lawfully in the UK to make a human rights claim before a travel ban made under the Sanctions Act impacts their immigration status. They are then exempt from the effect of the travel ban while the claim is considered. By contrast, non-designated persons making a human rights claim under the immigration rules also benefit from the same protections, but cannot leave the UK and return simply on the basis of a claim lodged before their departure. The updated regulations aim to protect the UK sanctions regimes from abuse and provide consistency with the wider immigration system. |
OFSI Guidance- UK Maritime Services Prohibition and Oil Price Cap |
OFSI published guidance regarding the UK ban on the provision of maritime transportation of certain Russian oil and oil products and associated services. The guidance covers the following topics:
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General Licence- Oil Price Cap: Exempt Projects and Countries |
Permits:
This licence takes effect from 5 December 2022 and is of indefinite duration (subject to the expiration dates above). |
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General Licence- Correspondent banking and payment processing | Permits financial institutions to process, clear or send payments to any person or entity in connection with activities that would otherwise contravene the ban on the provision of financial services and funds and brokering in relation to the maritime transportation of certain oil and oil products (regulation 46Z9C to 46Z9D of The Russia (Sanctions) (EU Exit) Regulations 2019). | |
General Licence- Oil Price Cap winddown [INT/2022/2470256] [NOW REVOKED] |
[THIS GENERAL LICENCE WAS REVOKED ON 20 DECEMBER 2023 – SEE ENTRY ABOVE]
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General licence – Oil Price Cap |
This general licence permits:
The general licence differentiates between Tier 1, Tier 2 and Tier 3 providers, each of which is subject to different requirements. (Tier provider status is determined by the extent to which a service provider can access the unit price agreed per barrel of Russian oil) . The licence is also subject to strict record-keeping requirements lasting 4 years from the end of the calendar year in which the record was created. Additional record-keeping requirements apply to Tier 1, Tier 2 and Tier 3 providers. This licence takes effect from 5 December 2022 and is of indefinite duration. |
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G7 Statement- Oil Cap |
The G7, EU and Australia have agreed to set the maximum price of USD 60 per barrel for seaborne Russian-origin crude oil. The price cap on Russian-origin crude oil entered into force across the relevant jurisdictions on 5 December 2022 (please see the UK general licence above). The statement reiterated that the price cap on Russian-origin petroleum products will enter into force on 5 February 2023. |
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1 December 2022 | Updated Guidance- Department for International Trade |
The Department for International Trade has published guidance on applying for licences with respect to the provision of accounting, business and management consulting, and public relations services to a ‘person connected with Russia’. The guidance notably includes information on the contents of the cover letter for a licence application. Please see the entry dated 21 July 2022 for more information regarding the prohibition of accounting, business and management consulting, and public relations services. |
30 November 2022 | Asset Freeze |
22 individuals have been added to the consolidated list and are now subject to an asset freeze. These include a number of Russian officials such as:
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28 November 2022 | SRA Guidance - Complying with the UK Sanctions Regime |
The Solicitors Regulation Authority (SRA) published guidance setting out its expectations regarding the UK sanctions regime and providing practical advice on avoiding breaches. This guidance will be relevant to SRA-regulated firms, solicitors, registered European lawyers and registered foreign lawyers. Separately, the SRA expressed concern in a warning notice around the misuse of litigation to discourage public criticism, a type of abusive litigation known as strategic lawsuits against public participation (SLAPPs). The SRA has specifically referred to that warning notice on its page dealing with 'Impacts of Russia sanctions' . The SRA warned that failure to have proper regard to this warning notice is likely to lead to disciplinary action. |
24 November 2022 |
British overseas territories: Russia (Sanctions) (Overseas Territories) (Amendment) (No. 3) Order 2022 |
A new Order has been introduced by the UK government to give effect in the relevant British overseas territories to the changes made to the Russia sanctions regime by the regulations below:
The list of British overseas territories is available under the Schedule to the regulation. |
21 November 2022 | Updated guidance- UK ban on Russian oil and oil products |
21 November 2022 Updated guidance- UK ban on Russian oil and oil products The UK government published guidance explaining the ban on Russian oil, oil products and associated services. The guidance covers:
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17 November 2022 | General licence- Payment to Energy Companies for Gas and/or Electricity |
The general licence permits:
This licence is subject to record-keeping requirements (available here). It will take effect from 17 November 2022 and [Note: This general licence was extended on 24 February 2023 - see entry above for more information]. |
14 November 2022 | OFSI blog post- Upcoming general licences |
OFSI announced that by 5 December 2022 (date by which the crude oil ban will come into effect):
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OFSI Guidance- Oil Price Cap |
OFSI published its "UK Maritime Services Prohibition and Oil Price Cap Guidance". This document provides guidance regarding the UK ban on the provision of maritime transportation of certain Russian oil and oil product and associated services (as introduced by The Russia (Sanctions) (EU Exit) (Amendments) (No.16) Regulations 2022). Please see the entry dated 3 November 2022 below for more information regarding the Russian oil and oil product ban. |
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11 November 2022 | Frozen Asset Reporting 2022- Notice | As part of its annual review of frozen assets, OFSI requests that all persons holding or controlling funds or economic resources belonging to, owned, held or controlled by a designated person to provide a report to OFSI with details of such assets by 11 November. Further information is available here. |
10 November 2022 | General licence amendment- Truphone Limited |
The general licence granted in relation to Truphone Limited on 2 November 2022 has been amended to incorporate the following changes:
Additional clarifications regarding the scope of the licence have been included (notably regarding incremental orders and loan funding by directors). |
General licence amendment- use of retail banking services of a designated credit/financial entity |
The general licence allowing non-designated persons to make use of retail banking services of a sanctioned credit or financial institution has been renewed from 10 November 2022 until 10 November 2023. The licence was granted for personal use only and for a total value not exceeding £50,000. The original licence was originally granted on 10 June 2022 and expired on 10 September 2022. Please see the entry dated 16 June 2022 below for more information regarding the scope of the licence. |
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9 November 2022 | Updated OFSI Guidance | OFSI's statutory guidance has been updated to clarify the application of the prohibition on providing financial services and funds relating to restricted goods and G7 dependency and further goods. |
General licence- specified fertiliser goods |
The Export Control Joint Unit published a general licence authorising the direct or indirect provision of financial services or making funds available to a person connected with Russia in connection with:
provided the fertilisers are for agricultural use only. "Specified fertiliser goods" is defined under the licence. This licence shall come into force on 9 November 2022. Any person seeking to rely on the licence must register online via SPIRE within 30 days of their first use of the licence. |
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4 November 2022 | General Licence-Agricultural commodities transactions |
For the purposes of this licence, "Agricultural Commodities" means "Food; Fertiliser; Seed; Feed; and Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food for animals". Relevant Exporters (i.e. non-designated exporters, producers, sellers or transporters of Agricultural Commodities); or DIT Licence Holders may continue to:
Relevant Institutions, Insurance Providers, UK Corporates or Relevant UK Nationals may carry out the activities necessary to effect the above permissions. This includes the provision of insurance, reinsurance and underwriting services and any other Financial Service (as defined as defined in section 61(1) of the Sanctions and Anti-Money Laundering Act 2018) to a Relevant Exporter, DIT Licence Holder or Designated Person in connection with a transaction relating to Agricultural Commodities. Designated Persons may also carry out the following activities:
This licence takes effect from 4 November 2022 and has no expiry date. |
3 November 2022 The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022: |
Trade restrictions -maritime transportation of certain oil and oil products The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (New Chapter 4IA) |
Introduces a prohibition on direct or indirect supply or delivery by ship of certain oil and oil products which originate in or are consigned from Russia (i) from a place in Russia to a third country; or (ii) from one third country to another third country. The prohibition comes into effect:
Includes a prohibition on associated financial services, funds and brokering services. Provides for exceptions where such products:
According to the explanatory memorandum:
Existing reporting obligations (under Regulation 70) are expanded to include a requirement to report breaches or suspected breaches of these prohibitions, and associated information, to Treasury. |
Trade restrictions – maritime transport of oil products - civil penalties for breach The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (New Regulations 88C and 88D) |
Confers on OFSI the power to impose civil monetary penalties on a person who fails to comply with the trade sanctions relating to maritime transportation of certain oil and oil products. Any defence that the person did not know and had no reasonable cause to suspect that such an offence had been committed is to be ignored Existing criminal penalties for breaches of trade sanctions also apply. The amount of the penalty may not exceed the permitted maximum which is:
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Trade restrictions – oil and oil products – amendment to implementation date The Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 (Amendments to regulation 46Z3) |
The implementation of prohibitions relating to the import of all Russian oil and oil products into the UK (introduced by Amendment No. 14 – see entry dated 21 July 2022 below) will be brought forward to 5 December 2022 (instead of 31 December 2022 as previously announced). | |
2 November 2022 | Asset freeze |
Four individuals have been added to the consolidated list and are now subject to an asset freeze.
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General licence – Truphone Limited |
The general licence permits:
Relevant institutions may process payments in accordance with the above. Any payments received by Truphone must be paid into a UK bank account, whereupon they must be frozen. The general licence does not permit the repayment of any loans or any other debt facilities extended to the Truphone, directly or indirectly, by Alexander Abramov, Alexander Frolov or any person, including any shareholders. Payments/activity over £5,000 must be reported to OFSI within 14 days. The general licence terminates on 23:59 on 31 January 2023 |
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28 October 2022 | General Licence- Legal Fees |
The UK government issued a general licence allowing payments to be made by a person designated under the Russia or Belarus regime for legal professional fees and expenses associated with the provision of legal services. The licence differentiates between legal services provided ‘pre-designation’ (Part A) and ‘post-designation’ (Part B):
Both caps may be combined (i.e. up to a £1 million limit), and a specific licence should be sought for any fees above this cap. Any activity conducted under this general licence must be reported to HM Treasury within 7 days, with details and supporting evidence. More information on reporting requirements are available on OFSI's website here. This licence takes effect from 28 October 2022 and expires on 28 April 2023. |
General Licence - category 5 loans (Gazprom Germania / Securing Energy for Europe) |
The UK government issued a general licence permitting the continued granting of category 5 loans or entering into arrangements to grant category 5 loans to Saving Energy For Europe GmBH, also known as Gazprom Germania and/or its subsidiaries, including SEFE Marketing and Trading and SEFE Energy, for the following purposes:
Relevant Institutions are permitted to process any of the above payments. Please see the entry below for more information regarding "category 5 loans". This Licence takes effect from 28 October 2022 and expires on 29 October 2023 (available here). |
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General licence – category 5 loans – wind-down |
The UK government issued a general licence permitting the continued granting of category 5 loans for the 7 days following the issuing of the Licence (please see the entry below for more information regarding "category 5 loans")subject to record-keeping requirements. This Licence takes effect from 28 October 2022 and expires on 5 November 2022. |
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Financial restrictions – capital markets restrictions (granting new loans) – amendment The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (amended Reg 17(5)) |
Definition of "category 3 loan" amended to add an end-date of 28 October 2022 (effectively phasing out the restrictions on "category 3" loans that have been in place since 1 March 2022). Added a new category of loan to those which are subject to existing restrictions on the granting of loans/credit (see 1 March 2022 entry below). A "category 5 loan" is a loan or credit:
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Trade restrictions – gold jewellery and processed gold The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (new Chapter 4JA) |
Introduces prohibitions on:
"relevant processed gold" means gold which: (a)has been processed in a third country; and (b) incorporates gold that, on or after 21 July 2022 originated in Russia, and has been exported from Russia. |
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Trade restrictions – liquified natural gas (LNG) The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (new Chapter 4L) |
From 1 January 2023, there will be prohibitions on:
"liquefied natural gas" means liquefied natural gas falling within commodity code 2711 11 00 |
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Trade restrictions – Russia's vulnerable goods The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 (new Chapter 4M and Schedule 3I) |
Introduces prohibitions on a new category of goods – Russia's "vulnerable goods" (as listed in Schedule 3I), including:
Russia's "vulnerable goods" are products which are critical to Russia's economy. |
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Trade restrictions –amendments to existing restrictions The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 |
Amendments to existing trade restrictions:
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26 October 2022 |
Government Response- Upcoming Economic Crime Plan | The UK government published its response to the Foreign Affairs Committee's interim report "The cost of complacency: illicit finance and the war in Ukraine" published on 30 June 2022 (available here). As part of its response, the government stated that work is underway to develop a new Anti-Corruption Strategy and the next Economic Crime Plan, which will go further still to tackle the threat from Economic Crime, including a specific focus on kleptocracy and sanctions evasion (Q.14). |
20 October 2022 | Asset Freeze- additions |
3 Iranian individuals and 1 Iranian entity have been added to the consolidated list and are now subject to an asset freeze:
The UK government's press release confirms that these sanctions have been imposed against those Iranian individuals and businesses responsible for supplying Russia with kamikaze drones used in Ukraine. |
Upcoming legislation- Sanctions (Damages Cap) Regulations 2022 |
The UK Parliament debated the draft Sanctions (Damages Cap) Regulations 2022 this week. The purpose of this instrument is to specify the amount of damages which cannot be exceeded where a court is satisfied that a designation was made in bad faith. The proposed cap is set at £10,000. In some cases, designated persons may have an incentive to pursue government through the courts, even though their claims may eventually be found to be without merit. This cap on damages seeks to disincentivise such claims. Please find the explanatory memorandum here, the draft legislation here and the procedure timeline here. |
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18 October 2022 | Press Release - OFSI-OFAC cooperation |
OFSI and OFAC have issued a statement detailing their enhanced cooperation following a multi-day technical exchange in London. This includes:
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17 October 2022 | General Licence - Arbitration payments |
OFSI has issued a new General Licence which permits the following:
This General Licence takes effect from 17 October 2022 and is of indefinite duration. |
11 October 2022 | Press release – G7 meeting |
The UK Prime Minister Liz Truss joined a virtual gathering of G7 leaders and President Zelenskyy on 11 October following Russia's most recent attacks in Kyiv. This meeting was the first gathering of all G7 leaders since Ukraine’s counter-offensive started to take hold in Ukraine.
The G7 leaders' joint statement following the meeting is available here. |
6 October 2022 | General licence – Russian banks UK subsidiaries (basic needs) – amendment |
OFSI amended the VTB basic needs General Licence granted on 1 March 2022 to include payments related to Insolvency Proceedings under the German Banking Act. The General Licence expires on 3 April 2023. See entries on 1 March 2022 and 22 August 2022 below for more details. |
4 October 2022 | Asset Freeze- addition and removal |
1 individual has been added to the consolidated list and is now subject to an asset freeze:
1 individual has been removed from the consolidated list and is no longer subject to an asset freeze:
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30 September 2022 | Upcoming services sanctions and export ban- UK government press release |
The UK Foreign Secretary has announced new services and goods export bans in response to Russia's illegal annexation of the Ukrainian regions of Donetsk, Luhansk, Kherson and Zaporizhzhia following sham referenda.
The UK will also ban the export of nearly 700 goods that are critical for production in Russia’s manufacturing sector. |
Asset Freeze- addition |
1 individual has been added to the consolidated list and is now subject to an asset freeze:
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27 September 2022 | Enforcement - Imposition of monetary penalty |
OFSI has imposed a monetary penalty of £30,000 against UK registered company, Hong Kong International Wine and Spirits Competition Ltd (HKIWSC) for breaches of sanctions which were imposed by the EU (including the UK) in 2014 in response to actions which undermined or threatened the territorial integrity, sovereignty, and independence of Ukraine. The penalty relates to three payments and 78 wine bottles HKIWSC received from a designated entity for entry into competitions between September 2017 and August 2020. OFSI identified five potential breaches:
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26 September 2022 | Asset freeze |
92 entries have been added to the consolidated list in response to the Russian regime imposing "sham referendums" in 4 regions of Ukraine: comprising: 89 individuals: Amongst those individuals designated are:
3 entities:
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22 September 2022 | Upcoming legislation- Economic Crime and Corporate Transparency Bill |
The Economic Crime and Corporate Transparency Bill (the "Bill") passed its first reading in the House of Commons. The Bill is intended to build on the measures contained in the Economic Crime (Transparency and Enforcement) 2022 Act (the "ECTE Act"). It contains an additional suite of reforms to tackle economic crime and improve transparency over corporate entities. In summary, as regards sanctions, the Bill:
The House of Commons has started its second reading of the Bill. Further information regarding the status of the Bill is available here . Further information regarding the contents of the Bill is available here. |
16 September 2022 | Asset freeze - removal |
The following entity has been removed from the consolidated list and is no longer subject to an asset freeze:
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5 September 2022 | G7 statement – crude oil and petroleum price cap |
The G7 Finance Ministers' statement following their meeting on 2 September 2022 contained the following statements about the crude oil and petroleum price cap:
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30 August 2022 | Financial sanctions – expanded reporting obligations | The expanded definition of "relevant firms" to include cryptoasset exchange providers and custodian wallet providers comes into effect as of today (for detail, see entry from 19 July 2022 below). |
22 August 2022 | General licence – Russian banks UK subsidiaries (basic needs) – amendment |
Extended the VTB basic needs General Licence granted on 1 March 2022 to include the following VTB subsidiaries:
The General Licence expires on 3 April 2023. See entry on 1 March 2022 below for more details. |
General Licence – Bank fees |
Permits, subject to record-keeping requirements:
"Bank" means a person or a firm with a Part 4A permission which includes accepting deposits, and which is a credit institution. It does not include a building society, friendly society or a credit union. "Service Fees" means service fees that a Bank would otherwise charge for the routine holding or maintenance of a bank account, including but not limited to premium bank account fees, fees associated with the provision of bank statements, account maintenance fees, late payment charges and overdraft fees. Service fees may also include transaction fees, payment fees or transfer fees, where those fees pertain to a transaction otherwise licensed by OFSI. This General Licence does not permit the payment to banks designated under the Russia Regime. This General Licence is of indefinite duration. |
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18 August 2022 |
General Licence –Permitted payments to UK insurance companies - amendment |
The General Licence permitting certain insurance-related payments (see entry from 22 July 2022) has been extended to include within "Permitted Payments":
This General Licence is of indefinite duration. |
18 August 2022 | General Licence - Evraz - extension | The General Licence permitting the continuation of business operations involving the North American subsidiaries of Evraz plc (see entry from 5 May 2022) has been extended and will now expire on 31 March 2023. [Note: On 16 February 2023, the General Licence was further extended to 30 September 2023 – see above.] |
16 August 2022 | General Licence – Crown servants, contractors and their family members |
Permits, where Crown immunity does not apply:
"Crown Servant" means an individual holding office or employment under the Crown "Contractor" means an individual who is not a Crown Servant, but who has been contracted by the Crown to provide goods or services within or in relation to the Crown’s operations in Russia "Family Member" means a member of the family forming part of the household of a Crown Servant or Contractor, namely:
"Visiting Family Member" means:
This General Licence takes effect from 11:59pm (midnight) on 19 August 2022 and has no expiry date. |
General Licence – Mongolia energy payments |
Permits:
"Person" means an individual, a body of persons corporate or incorporate, any organisation or any association or combination of persons. The "Sanctioned Banks" are:
This General Licence expires on |
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5 August 2022 | General Licence – Companies winding down operations in Russia |
Permits, subject to reporting requirements:
"Person" means a body of persons corporate or unincorporate, any organisation or any association or combination of persons, excluding a designated person Payments permitted under this General Licence include payment of staff salaries, taxes, regulatory fees and other fees to official government bodies, and payment of bills or invoices. Making use of the retail banking services of a designated Credit or Financial Institution does not include selling or transferring a Person's assets to a designated Credit or Financial Institution. |
2 August 2022 | Asset freeze | 2 individuals: Didier Casimiro and Zeljko Runje |
1 August 2022 | General Trade Licence – Vessels [NOW REVOKED] |
[THIS GENERAL TRADE LICENCE WAS REVOKED ON 18 JANUARY 2024]
[A replacement general licence was granted on 18 January 2024 – see above.] |
29 July 2022 | Extension of Rosbank General Licence | The General Licence permitting wind down of positions involving Rosbank (see entry from 30 June 2022) has been extended until 30 September 2022. |
26 July 2022 | Asset freeze | 41 individuals, including Kremlin-imposed "officials" in Luhansk and Donetsk, Russia's Minister and Deputy Minister of Justice, relatives of an oligarch, and Syrian individuals who have been recruiting Syrians to fight with Russia. 1 entity: Al-Sayyad Company for Guarding and Protection Services |
22 July 2022 | General licence – payment to UK insurance companies for building and engineering insurance |
Permits, subject to reporting and record-keeping requirements:
"Permitted Payments" mean insurance premiums, reinsurance premiums and broker commissions relating to the provision of Buildings Insurance and Engineering Insurance provided to UK properties. [Definition extended on 18 August 2022 to also include: Terrorism Insurance; Property Owners' Liability Insurance; and Claims Preparation Insurance.] This licence does not permit the provision of insurance to individuals who are also designated by the United Nations. This General Licence is of indefinite duration. |
21 July 2022 Explanatory Memorandum to The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 |
Aviation technical assistance The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022 |
Amendment of the measures introduced in the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 (see entry from 30 March 2022) to allow necessary technical assistance for temporarily detained aircraft in the ownership of suspected designated persons due to the rapid rate of aircraft degradation. |
Trade restrictions – gold The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022 |
Prohibition on the import/acquisition/supply/delivery, whether from Russia or a third country, of gold that originates in Russia on or after 21 July, as well as ancillary services, such as:
Gold originating from Russia that was exported from Russia before 21 July 2022 is not affected. |
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Trade restrictions – oil and coal The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022 |
Prohibition on the import/acquisition/supply/delivery of:
That originate in or are consigned from Russia, as well as prohibitions on the provision of related services. |
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Trade restrictions -professional and business services The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022 |
Prohibition on the provision, directly or indirectly, to persons connected with Russia, of:
This includes Russian residents who are temporarily located in another country, including the UK. The Regulation contains more detailed definitions of the services covered by the above. "person connected with Russia" – see entry at 1 March 2022 below. Exceptions exist where the services:
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Trade restrictions – energy-related goods and services The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022 |
Expanded existing prohibitions, including:
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Trade restrictions – G7 dependency and further goods list goods The Russia (Sanctions) (EU Exit) (Amendment) (No 14) Regulations 2022 |
Prohibits the export/supply/delivery of items listed on the G7 dependencies and further goods list. (as listed in Schedule 3E) to or for use in Russia or to a person connected with Russia. These goods are significant to the Russian economy and goods for which the Russia particularly depends on the G7 partners and the UK. The list is wide and includes:
Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology. "person connected with Russia" – see entry at 1 March 2022 below. Licences can be sought for humanitarian purposes. |
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20 July 2022 |
Trade restrictions – import tariffs The Customs (Additional Duty) (Russia and Belarus) (Amendment) (No. 2) Regulations 2022 |
Updates the list of products from Russia and Belarus which are subject to the previously announced tariff increases of 35% (see further below at 21 April and 21 May 2022). Access the Belarusian Additional Duties Document (version 1.2, dated 15 July 2022) and the Russian Additional Duties Document (version 1.2, dated 15 July 2022) here. |
Overseas territories: The Russia (Sanctions) (Overseas Territories) (Amendment) (No. 2) Order 2022 |
This Order makes the necessary amendments to give effect in the relevant British overseas territories to the changes made to the Russia sanctions regime pursuant to the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022. | |
19 July 2022 | General licence – investments in relation to Russia | Permits a person to carry out/wind down the prohibited activities in relation to outward investment to Russia detailed below for a period of 7 days. This General Licence expires on 26 July 2022. |
Financial and investment restrictions – investments in relation to Russia The Russia (Sanctions) (EU Exit) (Amendment) (No 12) Regulations 2022 |
Where a person knows or has reasonable cause to suspect that they are carrying on such an activity, there is a prohibition on:
"person connected with Russia" – see entry at 1 March 2022 below. “branch” means, in relation to a person other than an individual, a place of business which forms a legally dependent part of that person and which carries out all or some of the transactions inherent in the business of that person. "relevant entity" means a person, other than an individual, which "directly or indirectly acquiring any ownership interest in or control over a person or entity" means a person directly or indirectly acquiring:
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Exceptions – investments in relation to Russia The Russia (Sanctions) (EU Exit) (Amendment) (No 12) Regulations 2022 |
Exceptions to the prohibitions outlined above include:
"dealing with" includes purchasing/selling the security, providing investment services relating to the security or assisting in the issuance of the security. "relevant security issued by a person connected with Russia" means (1) a security issued by a person connected with Russia or a person owned by, or acting on the behalf of, a person connected with Russia, (2) which is negotiable on the capital market, (3) which is a share, bond or other security and (4) was admitted to trading on a regulated market or multilateral trading facility before 19 July 2022 (full definition included in regulation 60ZZA) "relevant security issued by a relevant entity" means (1) a security issued by a relevant entity, (2) which is negotiable on the capital market, (3) which is a share, bond or other security (full definition included in regulation 60ZZA). |
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Treasury licences – investments in relation to Russia The Russia (Sanctions) (EU Exit) (Amendment) (No 12) Regulations 2022 |
The purpose of treasury licences can relate to:
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Financial sanctions – reporting obligations – amendment of the definition of "relevant firms" The Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2022 |
The definition of "relevant firms" (i.e. those who have financial sanctions reporting obligations) has been extended to include cryptoasset exchange providers and custodian wallet providers. These reporting obligations require "relevant firms" to provide OFSI with particular information when they encounter a designated person when conducting their business "cryptoasset exchange provider" and "custodian wallet provider" are defined in the regulation. This expanded definition will apply as of 30 August 2022. There is a requirement for "relevant firms" to notify OFSI of certain information as soon as practicable when encountering a designated person in the course of their business. This requirement applies to relevant firms in the UK or under UK jurisdiction including people working for them. For more information about the obligations on relevant firms to report information to OFSI, see here. |
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18 July 2022 | Designation criteria The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 |
The definition of being "involved in obtaining a benefit from or supporting the Government of Russia" has been extended to include "other managers", rather than just trustees, of Russian government-controlled entities and those carrying on business of economic or strategic significance to the Russian government. As well as applying to persons involved in "destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine", the designation criteria also captures persons "obtaining a benefit from or supporting the Government of Russia", including but not limited to working as:
The definition of "being associated with" a person has been extended to those who are an "immediate family member" which is defined as:
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Trade: humanitarian exception The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 |
A new exception has been added for humanitarian assistance activity in non-government controlled areas of the Donetsk and Luhansk oblasts. This exception applies when:
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Interpretation: ship and aircraft ownership The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 |
The concept of ownership of a ship and aircraft has been extended to include:
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15 July 2022 |
Trade restrictions – defence and security, and maritime goods The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Prohibition on the export/supply/delivery etc of: (1) defence and security goods; and (2) maritime goods/technology:
Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology. "person connected with Russia" – see entry at 1 March 2022 below. "defence and security goods/technology" means:
"maritime goods/technology" means any goods and technology specified in Chapter 4 (Navigation Equipment) and Chapter 5 (Radio-Communication Equipment) of Annex 1 of the Merchant Shipping Notice 1874, subject to certain exceptions. Introduction of certain new exceptions to the prohibitions for maritime goods/technology. |
Trade restrictions – goods/technology relating to non-government controlled Ukrainian territory The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Prohibition on the export/supply/delivery etc of military goods/technology to or for use in non-government controlled Ukrainian territory. Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology. "non-government controlled Ukrainian territory" means Crimea and non-government controlled areas of the Donetsk and Luhansk oblasts |
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Trade restrictions – iron and steel products – amendment The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Expansion of the existing restrictions on Russian iron and steel products (see 14 April 2022 below) to include new prohibitions on the provision of technical assistance; financial services and funds; and brokering services in respect of:
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Trade restrictions – Interception and monitoring The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Prohibition on the provision/supply/delivery of interception and monitoring services to or for the benefit of the Government of Russia. "interception and monitoring services" means any service that has as its object or effect the interception of a communication in the course of its transmission by means of a telecommunication system (full definition included in regulation 21A). |
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Trade restrictions – Banknotes The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Prohibition on the export/supply/delivery of banknotes
"banknotes" means (1) sterling denominated banknotes issued by the Bank of England and banks in Scotland and Northern Ireland; and (2) banknotes denominated in any official currency of the EU. "person connected with Russia" – see entry at 1 March 2022 below. |
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Trade restrictions – jet fuel and fuel additives The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Prohibition on the export/supply/delivery etc of jet fuel and fuel additives:
Includes a prohibition on related technical assistance, financial services, funds and brokering services. "person connected with Russia" – see entry at 1 March 2022 below. "jet fuel and fuel additives" means the goods listed under that heading in Part 8 of Schedule 2A |
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Trade restrictions – revenue generating goods The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Prohibition on the import/acquisition/supply/delivery of revenue generating goods into the UK which:
Includes a prohibition on related technical assistance, financial services, funds and brokering services. "revenue generating goods" means anything specified in Schedule 3D. This list includes: caviar, cement, chemicals, fertilisers, tyres, wood, paper, glass, metals, jets, propellers, turbines, ships and furniture. Introduction of certain new exceptions to the prohibitions for revenue generating goods. |
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Trade restrictions – expansion of restrictions to non-government controlled Ukrainian territory The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Certain of the existing prohibitions in relation to:
Are expanded to apply equally to non-government controlled Ukrainian territory (i.e. Crimea, Donetsk and Luhansk) |
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Trade restrictions – expansion of existing restrictions The Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 |
Expansion of the existing lists of the prohibited goods/technology, as follows:
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Asset freeze |
2 individuals have been removed from the asset freeze list:
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12 July 2022 | OFSI and NCA Red Alert – Evasion typologies |
In conjunction with OFSI, the JMLIT+ Sanctions Facilitators Cell, law enforcement, private industry and regulators, the National Crime Agency (NCA) have issued a 'Red Alert' on financial sanctions evasion typologies by Russian elites and enablers. The purpose of the alert is to provide information from law enforcement and the legal and financial services sectors on some of the common techniques designated persons and their UK enablers are suspected to be using to evade financial sanctions. |
7 July 2022 | General licence – humanitarian activities |
Certain humanitarian organisations seeking to undertake humanitarian activity in relation to the conflict in Ukraine do not need to apply for individual licences from OFSI, but instead can rely on the permissions within this General Licence to undertake certain humanitarian activity. OFSI has also published a blog outlining the details of the General Licence This licence takes effect from 11:59 pm on 7 July 2022. There is no stated expiry date. |
5 July 2022 |
Belarus: Financial restrictions – dealing with transferable securities or money-market instruments The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Extension on existing capital markets restrictions to include a new prohibition on dealing, directly or indirectly, with a transferable security or money-market instrument issued after 5 July 2022 by a person "connected with Belarus". "connected with Belarus" means:
The prohibition does not apply to entities which on 5 July 2022: (i) were not domiciled in Belarus or (ii) were a branch or subsidiary of an entity in (i), wherever located. |
Belarus: Financial restrictions – loans and credit arrangements The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Extends the existing prohibition on granting new loans and credit to the following 3 categories of loan: "Category A loan" [This category was the subject of the restrictions in place prior to these changes]
"Category B loan"
"Category C loan"
"relevant person" means:
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Belarus: Financial restrictions – foreign exchange reserve and asset management The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Prohibition on the provision of financial services for the purpose of foreign exchange reserve and asset management to:
"financial services" and "foreign exchange reserve and asset management" are both defined widely. |
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Belarus: Trade sanctions – exports to Belarus The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Expands the existing trade restrictions to include new and amended prohibitions on the export, supply and delivery, and making available of the following (i) to or for use in Belarus or (ii) to a person connected with Belarus:
Includes a prohibition on related technical assistance, financial services, funds and brokering services in respect of those goods/technology (except luxury and tobacco industry goods). |
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Belarus: Trade sanctions – imports from Belarus The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Extends and amends the existing import prohibitions to include import prohibitions on the following:
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Belarus: Enabling or facilitating military activities The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
A person must not directly or indirectly provide:
where such provision enables or facilitates the conduct of military activities carried on by the Belarusian military or other military end-user connected with the Belarusian military. |
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Belarus: Movement of aircraft The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Extension of existing aircraft restrictions, to include:
A "Belarusian aircraft" means an aircraft: (a) owned, chartered or operated by a designated person, or a person connected with Belarus, or (b) registered in Belarus. |
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Belarus: Ships The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Introduction of new restrictions relating to ships, including:
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Belarus: General Licence – Wind down of positions involving National Bank of Belarus |
Permits a person to provide financial services for the purpose of winding down any of the following transactions that were entered into prior to 5 July with (i) the National Bank of Belarus, (ii) the Ministry of Finance of Belarus or (ii) persons owned/controlled or acting on behalf/at the direction of those persons:
A person or relevant institution is permitted to carry out any activity reasonable necessary to effect this. This General Licence expires on 4 August 2022. |
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Belarus: General Licence – Transferable securities, money market instruments, loans and credit arrangements |
Permits a person to:
Relevant institutions may process GBP payments made in accordance with the above. This General Licence expires at 23:59 on 12 July 2022. |
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Asset freeze |
2 individuals added:
2 individuals have been removed from the asset freeze list:
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4 July 2022 | Asset freeze |
6 individuals:
1 entity:
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30 June 2022 | General Licence – Wind down of positions involving Rosbank |
Permits a person (other than Rosbank or a subsidiary) to wind down transactions to which it is a party involving Rosbank or a subsidiary, including:
A person, relevant institution, Rosbank or a subsidiary can carry out any activity reasonably necessary to effect this.
This General Licence has been extended on 29 July 2022 and now expires on 30 September 2022. |
29 June 2022 | Asset freeze |
8 individuals including:
5 entities:
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G7 statement – Russian energy |
The G7 Leaders' Communiqué from the summit in Elmau contained the following statements regarding Russian energy:
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Further sanctions – restrictions on trust services (announced but not yet implemented) |
Announcement of new measures to prevent Russia from accessing UK trust services (services which allow a person or business to manage the assets of another). | |
26 June 2022 |
Trade restrictions – gold exports (announced but not yet implemented) |
Announcement of a prohibition on new exports of Russian gold entering the UK. This import ban will apply to newly mined or refined gold and will not impact Russian-origin gold previously exported from Russia. The ban will be introduced "shortly". Canada, US and Japan are due to introduce similar measures. |
23 June 2022 [THESE REGULATIONS HAVE BEEN REVOKED AND REPLACED BY A SIMILAR SET OF REGULATIONS THROUGH THE RUSSIA (SANCTIONS) (EU EXIT) (AMENDMENT) (NO 11) REGULATIONS 2022] |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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The Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 |
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16 June 2022 | Asset freeze |
12 individuals including:
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10 June 2022 | General Licence – Funds of non-designated third parties involving designated credit or financial institutions |
Permits:
Subject to specific reporting and record-keeping requirements. |
Financial sanctions - strict liability for breach The Economic Crime (Transparency and Enforcement) Act 2022 (Commencement No. 2 and Saving Provision) Regulations 2022 |
The provisions of the Economic Crime Act (see 15 March below) introducing a new strict civil liability test for imposing monetary penalties (section 54) will come into force on 15 June 2022. "In determining for the purposes of subsection (1) [of Section 146 of the Policing and Crime Act 2017] whether a person has breached a prohibition, or failed to comply with an obligation, imposed by or under financial sanctions legislation, any requirement imposed by or under that legislation for the person to have known, suspected or believed any matter is to be ignored." |
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8 June 2022 | Updated OFSI guidance – Monetary penalties |
OFSI has published an updated version of its enforcement and monetary penalty guidance reflecting measures in the Economic Crime (Transparency and Enforcement) Act 2022, including:
This guidance comes into force on 15 June 2022. Read more in the OFSI article accompanying this update. |
Guidance from the Department for International Trade: Trading under sanctions with Russia |
The Department for International Trade has published guidance on what import and export restrictions apply due to sanctions for UK companies when trading with Russia. It outlines the rules in respect of:
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31 May 2022 |
Trade restrictions – increased import tariffs The Customs (Additional Duty) (Russia and Belarus) (Amendment) Regulations 2022 |
Updates the list of products from Russia and Belarus which are subject to the previously announced tariff increases of 35% (see further below at 21 April and 21 May 2022). This comes into force from 1 June 2022. Access the Belarusian Additional Duties Document (version 1.1, dated 24 May 2022) and the Russian Additional Duties Document (version 1.1, dated 24 May 2022) here. |
30 May 2022 |
General Licence – Telecommunications Services and News Media Services (Continuation of Business and Basic Needs) |
Permits certain activity which would otherwise breach the prohibitions in Regulations 11 to 17A of the Russia Regulations (i.e. the asset freeze provisions and the capital markets restrictions):
A relevant institution may process any of the above payments. The permissions are subject to specified notification and record-keeping requirements. This General Licence expires on 30 May 2024. This General Licence has been amended – please see 26 June 2023 entry. |
General Licence – Charities associated with designated persons |
Permits an Interim Manager and/or trustee of a charity associated with a Designated Person (a "Charity") to authorise certain payments for:
The General Licence also permits an Interim Manager and/or trustee to authorise:
The General Licence expires on 30 May 2023. This General Licence has been amended – please see 26 June 2023 and 23 August 2023 entries. |
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23 May 2022 |
General Licence – Russian travel |
Permits a UK national/entity to purchase tickets from the following designated Russian travel companies, or any subsidiary, for flights or rail journeys within Russia or originating in Russia:
Permits a UK national/entity, relevant institution or designated person to carry out reasonably necessary activities to enable the purchase of tickets for those journeys. This General Licence expires on |
19 May 2022 | Asset Freeze |
3 entities:
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14 May 2022 | Further sanctions announced - G7 Foreign Ministers' statement |
In a further statement, the G7 Foreign Ministers stated that:
For the UK Government's press release on this, see here |
13 May 2022 | Asset Freeze | 12 individuals including Putin's ex-wife, cousins and childhood friends who support him financially |
General Licence – Amsterdam Trade Bank (basic needs and wind down) |
Permits:
This General Licence expires on 12 May 2023. |
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8 May 2022 | Further sanctions announcement - G7 meeting |
A collective commitment from the G7 to taking the following measures:
[The UK has already taken steps to enact these measures, for instance announcing on 7 March that it will phase out Russian oil imports, announcing on 4 May a ban on services exports to Russia, and continuing to impose asset freezes on Russian individuals and entities – all detailed below.] See also the latest press release from the UK Government, published on 14 May 2022, which discusses the G7 Foreign Ministers' Statement on Russia's war against Ukraine. The Ministers reaffirmed their commitment "to reduce and end reliance on Russian energy supplies as quickly as possible" For more information, see here. |
5 May 2022 | General Licence – Evraz |
Permits the continuation of business operations involving the North American subsidiaries of Evraz plc, including payments to and from those subsidiaries and any third party under any obligations or contracts. The General Licence expires on |
Asset Freeze | One entity, Evraz plc, a major manufacturer of Russian steel | |
4 May 2022 |
Trade restrictions – a ban on services exports to Russia (announced but not yet implemented) |
The UK has announced a ban on services exports to Russia, including management consulting, accounting and PR services. |
Asset Freeze |
13 individuals including war correspondents from Channel One, a major state-owned outlet in Russia 32 entities, including a number of strategic propaganda organisations such as:
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29 April 2022 | Social media and internet services restrictions The Russia (Sanctions) (EU Exit) (Amendment) (No.9) Regulations 2022 |
Imposes obligations on internet companies, including requirements that :
The Secretary of State can designate persons to whom these restrictions will apply. Grants new powers to OFCOM to request information/documents in relation to internet services. OFCOM is also granted new enforcement rights, including the power to impose civil monetary penalties Creates information offences in relation to internet services. Failure to comply is also a criminal offence. |
27 April 2022 | General licence - Law Enforcement and Regulatory Authorities Asset Recovery |
Permits certain specified activities in connection with law enforcement and asset recovery, including:
Subject to a prior authorisation requirement in certain circumstances and reporting requirements. The licence is of indefinite duration. |
22 April 2022 |
General licence – Russian banks UK subsidiaries (basic needs) -amendment (Sberbank UK subsidiary) |
Extended the VTB basic needs General Licence granted on 1 March 2022 to include Sberbank CIB (UK) Ltd (the UK subsidiary of Sberbank). The General Licence expires on 3 April 2023. (Sberbank CIB (UK) entered special administration on 1 April 2022 – see here.) |
21 April 2022 |
General licence – Gazprombank Energy Payments [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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General licence – Russian banks (wind-down) – amendment to publication notice |
Amendment to publication notice accompanying the existing wind-down licence for to Alfa Bank, GazPromBank, Rosselkhozbank, SMP Bank and the Ural Bank for Reconstruction and Development issued on 24 March 2022 (see below).
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Trade restrictions – Russian goods (announced but not yet implemented) |
The UK Government announced further trade sanctions which will impose tariffs and bans on over £1bn of additional Russian goods. This will include import bans on silver, wood products and high-end products from Russia including caviar. Tariffs will be increased by 35% on around £130m worth of products from Russia and Belarus, including diamonds and rubber. A full list of products targeted is available here. |
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Asset Freeze |
16 individuals including individuals who are members of or linked to Russia's military 10 entities:
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19 April 2022 |
Financial sanctions - Moscow Stock Exchange (announced but not yet implemented) |
HMRC has announced its intention to revoke the Moscow Stock Exchange's (MOEX) status as a recognised stock exchange, limiting access to certain UK treatments and reliefs for future investments in securities traded on MOEX. Access to those treatments and reliefs for existing investments will remain unaffected. Financial Secretary to the Treasury, Lucy Frazer, said: "As we continue to isolate Russia in response to their illegal war on Ukraine, revoking Moscow Stock Exchange's recognised status sends a clear message – there is no case for new investments in Russia." |
14 April 2022 | Asset Freeze |
2 individuals:
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Trade restrictions – luxury goods
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Prohibition on the export/supply/delivery etc of luxury goods:
"person connected with Russia" – see entry at 1 March 2022 below. "luxury goods" are listed in Schedule 3A along with the specified sales price threshold and include: horses, caviar, truffles, alcoholic drinks, cigars, perfume, leather goods, clothing/accessories/shoes, rugs, precious stones, coins/banknotes, silverware, tableware, lead crystal, electronic items for personal use / recording, vehicles, clocks/watches, musical instruments, art, sports equipment, and gambling equipment. Extension of certain existing exceptions to luxury goods. |
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Trade restrictions – iron and steel products The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 |
Prohibition on
"iron and steel products" are listed in Schedule 3B Extension of certain existing exceptions to iron and steel products. |
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Trade restrictions – oil refining and quantum computing goods/technology The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 |
Prohibition on the export/supply/delivery etc of oil refining and quantum computing goods/technology:
Includes a prohibition on related technical assistance, financial services, funds and brokering services. "person connected with Russia" – see entry at 1 March 2022 below. "oil refining goods/technology" are listed in Schedule 2D. "quantum computing goods/technology" are listed in Schedule 2E Extension of certain existing exceptions. |
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British overseas territories – extension of recent changes to the UK sanctions on Russia The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022 |
Amendments to the legislation extending the UK's sanctions regime in relation to Russia (re Ukraine) to British overseas territories to bring it in line with the amendments to that regime since Russia's invasion of Ukraine (as set out below). That regime is extended to all British overseas territories by way of the Russia (Sanctions) (Overseas Territories) Order 2020. This Order does not apply to Bermuda and Gibraltar which implement sanctions under their own legislative arrangements. |
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13 April 2022 | Asset Freeze | 206 individuals, including: 178 separatists who have been supporting Russian-backed breakaway regions of Ukraine, 6 oligarchs, close associates and employees, and an additional 22 individuals. |
8 April 2022 |
Asset freeze |
3 individuals: Katerina Vladimirovna Tikhonova and Maria Vladimirovna Vorontsova (daughters of Vladimir Putin); and Yekaterina Sergeyevna Vinokurova (daughter of Sergey Lavrov) |
General Trade Licence - Vessels NOW REVOKED |
[THIS GENERAL TRADE LICENCE WAS REVOKED ON 1 AUGUST 2022]
[A replacement general licence was granted on 1 August 2022 – see above.] |
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7 April 2022 |
Further sanctions – announcement (G7 foreign ministers' statement) |
"We stress the necessity of further increasing the economic pressure inflicted on Russia and the Lukashenka regime in Belarus. Together with international partners, the G7 will sustain and increase pressure on Russia by imposing coordinated additional restrictive measures to effectively thwart Russian abilities to continue the aggression against Ukraine. We will work together to stop any attempts to circumvent sanctions or to aid Russia by other means. We are taking further steps to expedite plans to reduce our reliance on Russian energy, and will work together to this end." |
6 April 2022 | Asset Freeze |
8 individuals:
2 entities: Credit Bank of Moscow and PJSC Sberbank |
Further sanctions – announcement (announced but not yet implemented) |
Other sanctions announced, but yet to be implemented, include:
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General licence - Credit Bank of Moscow (wind-down) | Permits the wind down of any transactions involving Credit Bank of Moscow (or a subsidiary) including the closing out of any positions, and any activity reasonably necessary to effect this, until 6 May 2022. | |
General licence – Sberbank (energy) - amendments | Amendment to the General Licence granted on 1 March 2022 in respect of energy-related payments (see below). The amendment ensures that the General Licence in respect of energy related payments may continue to be used since Sberbank became subject to an asset freeze on 6 April 2022. | |
4 April 2022 |
General licence – GEFCO (amendment) [NOW REVOKED] |
[THIS GENERAL TRADE LICENCE HAS BEEN REVOKED – SEE BELOW]
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Further wave of sanctions – announcement (announced but not yet implemented) |
In a speech delivered at a the British Embassy in Poland, Foreign Secretary Liz Truss announced a "tough new wave of sanctions", said to comprise:
[Update on 5 April 2022: In a speech delivered at the Polish Ministry of Foreign Affairs on 5 April 2022, the Foreign Secretary explained that she would be urging the UK's NATO and G7 partners to go further in sanctions by joining the UK in introducing the above restrictions, which the UK has already introduced.] The Foreign Secretary also said that "There should be no talk of removing sanctions whilst Putin’s troops are in Ukraine and the threat of Russian aggression looms over Europe". |
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1 April 2022 |
General licence - Payments by the Central Bank of the Russian Federation and others (exemption to Regulation 18A restrictions) [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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General licence – VTB (basic needs) – amendment |
Amendment of the VTB basic needs general licence (see 1 March 2022 below) to allow any payments in connection with the insolvency proceedings of the UK subsidiary of VTB. Any person, including any subsidiary of VTB incorporated in the UK, may make, receive or process any payments, or take any other action, in connection with any insolvency proceedings relating to VTB Capital plc. Permits the receipt and processing of any such payments. "insolvency proceedings" includes all those set out in the Insolvency Act 1986 and the Banking Act 2009 |
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31 March 2022 | Asset freeze |
12 individuals: including Russian propagandists and military personnel. 2 entities: Rossiya Segodnya and TV-Novosti (both Russian media organisations) |
Asset freeze |
3 entities: Photon Pro LLP; Majory LLP; Djeco Group LP [Note: Each of these entities has a UK address, and has been designated under the new "urgent" procedure on the basis that they have been sanctioned by the US. No other reasons were given by OFSI. An OFAC press release said that these entities were part of an international "sanctions evasion network" which conceals the Russian military and intelligence end-users of western technology.] |
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30 March 2022 |
Financial restrictions – investments in Donetsk and Luhansk regions The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 (amendments to Regulation 18) |
Extension of the existing investment restrictions in respect of Crimea to the Donetsk and Luhansk regions (defined as "non-government controlled Ukrainian territory"). Those restrictions comprise a prohibition on:
The exceptions to these restrictions have been similarly extended. |
Trade restrictions - Donetsk and Luhansk regions The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 (amendments to Chapter 5 and 6) |
Extension of the existing trade restrictions in respect of Crimea to the Donetsk and Luhansk regions (defined as "non-government controlled Ukrainian territory"). Those restrictions comprise a prohibition on:
The exceptions to these restrictions have been similarly extended. Specific exceptions to the Donetsk/Luhansk restrictions have also been introduced – see new Regulation 60ZA. |
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Technical assistance relating to aircraft and ships The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 (new Regulation 46A) |
Prohibition on the provision of technical assistance to or for the benefit of a designated person relating to an aircraft or a ship. "technical assistance" means (a) technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or (b) any other technical service relating to the goods or technology. |
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Ships - Donetsk and Luhansk regions The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 (amendments to Regulation 57) |
Extension of existing shipping restrictions in respect of Crimea (see 1 March 2022 below) to the Donetsk and Luhansk regions. A British cruise ship may be directed not to enter a port in Crimea/Donetsk/Luhansk. |
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29 March 2022 |
General licence - Wind down of positions involving Sovcomflot [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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28 March 2022 |
Procurement Policy Note - contracts with suppliers from Russia or Belarus (accompanying FAQs) |
Guidance issued by the Cabinet Office asks all public sector organisations to review contracts to identify any with Russian and Belarusian companies and, if possible to switch suppliers with minimal disruption, pursue legal routes of cancelling them. The PPN also suggests that public sector organisations consider whether there are Russian/Belarusian subcontractors (being relied on to deliver the contract) in supply chains, but confirms that there is no requirement to ask contractors to consider terminating subcontracts with Russian/Belarusian subcontractors at this stage. |
27 March 2022 | Research and innovation sanctions |
Suspension of publicly funded research and innovation collaborations with Russian Universities and companies of strategic benefit to the Russian state:
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25 March 2022 |
General licence - continuation of business and basic needs of GEFCO UK subsidiaries [NOW REVOKED] |
[THIS GENERAL LICENCE WAS REVOKED ON 12 APRIL 2022: following the sale of Russian Railways' stake in GEFCO to non-designated persons, GEFCO is no longer impacted by UK sanctions]
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24 March 2022 | Asset freeze |
33 individuals, including:
26 entities, including:
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Belarus: asset freeze |
Six entities:
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General licence – wind down of positions with five designated banks [EXPIRED] |
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Belarus: General licence – wind down of positions with Bank Dabrabyt [EXPIRED] |
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Trade restrictions – increased import tariffs The Customs (Additional Duty) (Russia and Belarus) Regulations 2022 |
Additional 35 per cent duty payable on imports of key products from Russia and Belarus. The products include:
The full lists of impacted products, including commodity codes, are available here. |
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Open general export licence ("OGEL") - amendments |
Four existing OGELs have been amended to require registration before first use of the licence:
In addition, the export of dual-use items to EU member states OGEL has been updated to include Iceland as a permitted destination. |
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22 March 2022 |
General licence - Wind down of certain transactions with the Central Bank, National Wealth Fund and Ministry of Finance [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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Update to OFSI guidance – ownership and control |
OFSI has added a new paragraph (4.1.4) to its general guidance on ownership and control which clarifies OFSI's position on aggregation, including the following: "When making an assessment on ownership and control, OFSI would not simply aggregate different designated persons’ holdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated parties or one party controls the rights of another. Consequently, if each of the designated person's holdings falls below the 50% threshold in respect of share ownership and there is no evidence of a joint arrangement or that the shares are held jointly, the company would not be directly or indirectly owned by a designated person." (emphasis added) |
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17 March 2022 | Tax – suspension of cooperation | The UK has suspended all exchange of tax information with Russia and Belarus under the UK’s exchange of information agreements, including the Convention on Mutual Administrative Assistance in Tax Matters and under bilateral Double Tax Agreements. |
Oligarch Task Force - meeting |
Inaugural ministerial meeting of the Russian Elites, Proxies and Oligarchs Task Force (the "Task Force"). Joint statement confirmed:
Signatories include representatives from: the US, Australia, Canada, France, Germany, Italy, Japan, the UK and the EU. |
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General Trade Licence – vessels [NOW REVOKED] |
[THIS GENERAL TRADE LICENCE WAS REVOKED ON 8 APRIL 2022] Permits the provision of technical assistance, financial services and funds, and brokering services relating to vessels / their component parts / associated technology, where:
The General Licence also contains a number of conditions relating to insurance/reinsurance in respect of the above. Use is subject to a notification requirement. The licence is stated to be "a temporary measure which will address a shortcoming" in the relevant regulation.
[A replacement general licence was granted on 8 April 2022 – see above.] |
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15 March 2022 | Asset freeze |
345 individuals, including a number of designations under the newly-introduced urgent procedure in the Economic Crime (Transparency and Enforcement) Act pursuant to the new "mirroring provisions" (i.e. because those individuals have already been sanctioned by the US, EU, Canada or Australia). 5 entities: Gas Industry Insurance Company SOGAZ, Geopolitica, Internet Research Agency, New Eastern Outlook, Oriental Review Oligarchs:
Political allies:
Propagandists:
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Asset freeze |
12 individuals 2 entities: Rosneft Aero and JSC Zelenodolsk Shipyard |
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Economic Crime (Transparency and Enforcement) Act 2022 – strict liability and new designation procedure |
Economic Crime (Transparency and Enforcement) Act (the "2022 Act") receives Royal Assent. In terms of sanctions, the key provisions are as follows:
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Trade/financial restrictions: Export finance | The UK government announced it will no longer issue any new guarantees, loans and insurance for exports to Russia and Belarus. | |
13 March 2022 | Investments in Russia – Government statement |
Statement from the Chancellor, Rishi Sunak:
The government recognises that some firms may find winding down their positions is a long-term process, given market conditions and the ability to sell assets due to the global sanctions placed on the Russian economy. The Chancellor said the government would do all it could to stand behind and support businesses who want to divest. |
11 March 2022 |
Trade – revocation of "most favoured nation" status (announced but not yet implemented – G7 leaders' joint statement) |
Denial of Russia's Most-Favoured-Nation (MFN) status relating to key products - the products of Russian companies will no longer receive Most-Favoured-Nation treatment in those economies. [Implemented in part - by way of import tariff increases on key products from Russia (see 24 March 2022 above).] A statement by a broad coalition of WTO members, including the G7, announcing their revocation of Russia’s Most-Favoured-Nation status is being prepared. [Update: the statement was published in 15 March 2022 – accessible here.] |
Financial restrictions – removal of access to leading multilateral financial institutions (announced but not yet implemented – G7 leaders' joint statement) |
Prohibition on Russia from obtaining financing from the leading multilateral financial institutions, including the International Monetary Fund, the World Bank and the European Bank for Reconstruction and Development. [See equivalent entry for the EU for further detail.] |
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Financial restrictions – closing loop-holes (announced but not yet implemented – G7 leaders' joint statement) |
Focus on cracking down on evasion and to closing loop-holes in existing sanctions. Specifically, ensuring that existing measures include digital / crypto-assets. | |
Financial restrictions – new debt/equity (announced but not yet implemented – G7 leaders' joint statement) |
Prohibition on Russian entities who are directly or indirectly supporting the war accessing new debt and equity investments and other forms of international capital. |
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Asset freeze – individuals |
386 individuals: members of the State Duma of the Russian Federation who voted in favour of the laws which recognised the Donetsk People’s Republic and the Luhansk People’s Republic as independent states. | |
10 March 2022 | Asset freeze – individuals |
Seven individuals:
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General licence – Chelsea football club [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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9 March 2022 |
General licence – amendment to VTB wind-down licence (payment into frozen accounts) [EXPIRED] |
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Belarus: General licence - Provision of navigational data to civilian aircrafts for flight safety |
Exemption to the existing asset freeze provisions to permit Belaeronavigatsia (the provider of air navigation services in Belarus) to provide navigational data to civilian aircraft, and for flight data providers to make payments to Belaeronavigatsia in respect of the same. This licence is of indefinite duration. |
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7 March 2022 | Russian oil imports – announcement |
The UK Government announced that:
in order to move will increase the growing pressure on Russia’s economy by choking off a valuable source of income. Note: no associated sanctions have been announced. See also the further statement from Kwasi Kwarteng, Secretary of State for Business, Energy and Industrial Strategy, on 10 March 2022. |
General licence – amendment (VTB wind-down) [EXPIRED] |
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General trade licence – aviation insurance [NOW REVOKED] |
[THIS GENERAL TRADE LICENCE WAS REVOKED ON 29 MARCH 2022]
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Trade sanctions - aviation and space goods or technology The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022 |
Prohibition on the export/supply/delivery etc of certain specified aviation and space goods or technology:
"person connected with Russia" – see entry at 1 March 2022 below. "aviation and space goods or technology" – specified in Schedule 2C of the 2019 Regulations (as amended. Includes "any tangible storage medium on which aviation and space technology is recorded". Also includes a prohibition on the provision, directly or indirectly, of insurance or reinsurance services relating to aviation and space goods or technology Extension of certain existing exceptions to aviation and space goods or technology. |
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Ships - prohibition on port entry The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022 |
Amendments to the existing prohibitions introduced on 1 March 2022 (see entry below):
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Prohibition on Russian aircraft The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022 |
Prohibition on Russian aircraft overflying or landing in the UK. Air traffic controllers may (or may be instructed to) give such directions to Russian aircraft. Airport operators may (or may be instructed to) give instructions to Russian aircraft not to take off, to take off or not to land at an airport. Airport operators giving instructions not to take off must take reasonable steps to detain the aircraft. The Civil Aviation Authority (CAA) may also be required to refuse certain permissions under the Air Navigation Order (ANO). "Russian aircraft" means an aircraft (i) registered in Russia; or (ii) owned, chartered or operated by a designated person (under these aircraft restrictions), or a person connected with Russia. Persons/entities can be "designated" for the purposes of the above restrictions/prohibitions. Exceptions on grounds of safety to other aircraft, passengers or people on the ground. |
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4 March 2022 |
General licence - Wind Down of Positions Sberbank [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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General licence - Wind Down of Positions Involving Various Designated Banks [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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3 March 2022 | Asset freeze | Two individuals: Igor Ivanovich Shuvalov (Chairman of VEB) and Alisher Burkhanovich Usmanov (prominent Russian businessman and pro-Kremlin oligarch) |
Asset freeze – all Russian Banks (announced but not yet implemented) |
The Government announced that it intends to "asset freeze every Russian bank". The Foreign Secretary also stated at a press conference that "We need to make sure no Russian bank has access to SWIFT". Boris Johnson repeated this message in an article published on 6 March 2022 ("We must go further on economic sanctions, expelling every Russian bank from SWIFT.") |
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1 March 2022 |
Financial restrictions – dealing with Central Bank and others The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022 |
Prohibition on UK individuals/entities from providing financial services for the purpose of foreign exchange reserve and asset management to:
"foreign exchange reserve and asset management" includes money market instruments (including cheques, bills and certificates of deposit); foreign exchange; derivative products (including futures and options); exchange rate and interest rate instruments (including products such as swaps and forward rate agreements); transferable securities; other negotiable instruments and financial assets (including bullion); and/or special drawing rights. Licences may be granted in certain circumstances, including humanitarian assistance, financial regulation, financial stability, soundness of a firm or extraordinary circumstances. |
General licence – financial restrictions – VTB (regulators) |
Grants an exemption to UK financial regulators in relation to VTB Capital plc / any other VTB UK subsidiary "for the purposes of the functions of that authority including as they relate to prudential supervision or protecting, maintaining or enhancing the stability of the financial system of the United Kingdom" until [Note: This general licence was extended on 24 February 2023, please see entry above for more information] Relevant UK regulators include the FCA, FSCS, PRA and Bank of England. |
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General licence - financial restrictions – VTB (basic needs) |
Grants an exemption to VTB Capital plc / any other VTB UK subsidiary to permit it to make payments for basic needs, including:
Grants an exemption to allow persons to receive, and UK financial institution to process, such payments. [Amendment on 1 April 2022] Any person, including any subsidiary of VTB incorporated in the UK, may make, receive or process any payments, or take any other action, in connection with any insolvency proceedings relating to VTB Capital plc. Permits the receipt and processing of any such payments.
[Amendment on 22 April 2022] The General Licence now also includes Sberbank CIB (UK) Ltd, the UK subsidiary of Sberbank. [Amendment on 22 August 2022] The General Licence now also includes Guernsey subsidiary VTBC Asset Management International Limited and EU subsidiary VTB Bank (Europe) SE (VTBE) and any entity owned or controlled by VTBE incorporated in Germany. [Amendment on 6 October 2022] The General Licence now includes payments related to Insolvency Proceedings under the German Banking Act. [Amendment on 24 February 2023] The general licence was extended to expire on 3 April 2025 at 23:59- please see the entry above for more information]. |
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Prohibition on port entry The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022 |
Ban on Russian ships entering UK ports. Includes ships:
Any such ship can be directed to enter or leave a port in a specific direction, proceed to a specific location or remain where it is, including that a ship be detained in a UK port. A British cruise ship may be directed not to enter a Crimean port. Persons/entities can be "designated" for the purposes of the above restrictions |
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Asset freeze | One individual: Kirill Alexandrovich Dmitriev (CEO of Russian Direct Investment Fund) One entity: Russian Direct Investment Fund (Russia's sovereign wealth fund) |
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Financial restrictions – capital markets / loans The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022 |
Extended the existing capital markets prohibition, as follows: 1. Prohibition on dealing with a transferable security or money-market instrument a maturity exceeding 30 days and issued on or after 1 March 2022 by:
2. Prohibition on dealing with any transferable security or money-market instrument issued on or after 1 March 2022 by:
Extended the existing restrictions on the granting of loans/credit. It is prohibited to grant the following loans/credit:
"connected with Russia" means:
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Financial restrictions - correspondent banking relationships The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022 |
Prohibition on UK credit/financial institutions:
any designated person or any credit/financial institutions owned/controlled by a designated person. Note: OFSI has expressly confirmed that these restrictions apply to Sberbank (but when the restriction was introduced, Sberbank was not subject to an asset-freeze). Sberbank became subject to an asset freeze on 6 April 2022. |
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Trade restrictions The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2022 |
Extension of existing trade restrictions applicable to military goods/technology to dual-use goods and certain specified goods referred to as "critical-industry goods/technology" (set out in Schedule 2A), which include:
Certain exceptions for: personal effects, consumer communication devices and software updates |
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General Licence – capital markets restrictions [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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General Licence – correspondent banking relationships & processing sterling payments - Sberbank [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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General Licence - processing sterling payments – energy/Sberbank |
Grants an exemption to the prohibition on the processing of sterling payments from/to/via:
for the purposes of making crude oil, petroleum products or gas available for use in the UK until on 24 June 2022. [General licence was amended on 6 April 2022 – see above] |
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Asset freeze |
Four individuals: Andrei Burdyko, Victor Vladimirovich Gulevich, Sergei Simonenko and Andrey Zhuk (all senior members of the Belarussian Military/Ministry of Defence) Two entities: JSC 558 Aircraft Repair Plant, JSC Integral (both Belarussian defence companies) |
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28 February 2022 | Asset freeze | Three entities: VEB, Bank Otkritie, Sovocombank. |
28 February 2022 |
Financial restrictions – Russian Central Bank and others (announced but not yet implemented) 1 |
In addition to those measures announced on 24 February 2022 (see below), new sanctions will include a prohibition on any UK natural or legal persons from undertaking financial transactions involving the CBR or the Ministry of Finance of the Russian Federation. [Implemented in part – see above (1 March ) - but not subject to asset freezes.] |
26 February 2022 (announced but not yet implemented) |
Visa restrictions – "golden passports" | Introduction of measures to limit the sale of citizenship—so called golden passports—that let wealthy Russians connected to the Russian government become citizens of Western countries and gain access to their financial systems. [Note: the UK ended its Tier-1 investor visa scheme on 17 February 2022.] |
25 February 2022 | Asset freeze | Two individuals: Vladimir Putin and Sergei Lavrov. |
General Licence– Wind Down of Positions Involving VTB [EXPIRED] |
[THIS GENERAL LICENCE HAS NOW EXPIRED]
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24 February 2022 |
Asset freeze and travel ban | Five individuals: Kirill Shamalov, Petr Fradkov, Denis Bortnikov, Yury Slyusar and Elena Aleksandrovna Georgieva (described as being part of "Putin’s inner circle"). |
Asset freeze | VTB Bank (one of Russia's largest banks) – see General Licence below. Five Russian defence companies:
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24 February 2022 |
Asset freeze (announced, awaiting implementation) 2 |
All Russian banks (to the extent not already covered) – implemented in part (see below/above) |
Financial and investment restrictions |
Prohibition on Russian individuals' access to UK banks, including £50,000 limits on bank accounts. |
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22 February 2022 | Asset freeze and travel ban | Three individuals: Gennady Timchenko, Igor Rotenberg and Boris Rotenberg. |
Asset freeze | Five Russian banks: Bank Rossiya, Black Sea Bank, Genbank, IS Bank, and Promsvyazbank. | |
10 February 2022 |
Additional basis for designation under UK sanctions regime: The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022 |
Amended the Russia (Sanctions) (EU Exit) Regulations 2019 to include an additional basis for designation under the UK sanctions regime, namely if a person is/has been involved in "obtaining a benefit from or supporting the Government of Russia". This is defined as including: a) carrying on business as a Government of Russia-affiliated entity; b) carrying on business of economic significance to the Government of Russia; or c) carrying on business in a sector of strategic significance to the Government of Russia, those sectors being: chemicals, construction, defence, electronics, energy, extractives, financial services, information, communications and digital technologies, and transport. |
TYPE | GUIDANCE |
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Consolidated list |
Designated person/asset freeze (Russia-specific) Investment ban targets (Russia-specific Consolidated list search tool (not Russia-specific) |
Notices |
OFSI Financial sanctions - Russia OFSI Financial sanctions - Belarus General Licences (OFSI) |
Guidance |
Financial sanctions: general guidance (OFSI) Statutory guidance (Russia sanctions) Russia guidance (OFSI) Enforcement and monetary penalties guidance (OFSI) Statutory guidance (Republic of Belarus sanctions) Guidance (Trading under sanctions with Russia) |
Additional contributors: Adela Mackie and Aaron Marchant
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
Readers should take legal advice before applying it to specific issues or transactions.