Continued UK Sanctions on Russia

What’s this about?

The UK has continued to impose sanctions on Russian individuals and entities under the UK sanctions regime with regard to the war in Ukraine; for more about how the UK sanctions regime works see the What is the UK sanctions regime? section of our article here https://www.corderycompliance.com/add65uksanctions/.

This article lists key sanctions imposed along with licenses granted by the UK concerning Russia and in the last three months.

What are the most recent additional UK sanctions and licences concerning Russia?

The situation concerning Russia sanctions is very fast-moving and much has been done in the last few months, including the following:

APRIL

5 April = HMT/OFSI published a Financial Sanctions Notice – the entry on the consolidated list relating to Wagner Group was amended and remains subject to an asset freeze;
6 April = HMT/OFSI amended two General Licences to allow for any payments in connection with the insolvency proceedings of the UK subsidiary of VTB, which took effect on 01 March 2022 and expires on 1 March 2023;
6 April = HMT/OFSI published a Financial Sanctions Notice – six entries on the consolidated list, including VTB Bank, were amended and remain subject to an asset freeze. Ten further entries have been added to the consolidated list and are now subject to an asset freeze. These include eight individuals, PJSC Sberbank, and the Credit Bank of Moscow;
6 April = The UK announced a new set of sanctions (with the US), including banning new UK investment in Russia, further sanctions on Russia’s largest bank, and the designation of Russian government officials and family members;
7 April = An amendment was made extending the restriction of flying to prevent any aircraft from flying in UK airspace if it is flying in accordance with a flight plan that includes an aerodrome in Russia;
7 April = HMT/OFSI issued a General Licence under which a person may wind down any transactions involving Credit Bank of Moscow or a subsidiary;
8 April = HMT/OFSI published a Financial Sanctions Notice of three entries, including Putin’s two daughters and the daughter of Russian Foreign Minister Sergey Lavrov, who were added to the consolidated list and are now subject to an asset freeze;
13 April = HMT/OFSI published a Financial Sanctions Notice where 206 entries were added to the consolidated list and are now subject to an asset freeze. These include 178 individuals in co-ordination with the EU targeting those who prop up Russian-backed illegal breakaway regions of Ukraine;
The UK sanctioned Russian oligarchs Eugene Tenenbaum and David Davidovich with up to £10bn worth of their assets frozen. Tenenbaum and Davidovich are business associates of Roman Abramovich. Davidovich also received a travel ban;
14 April = New restrictions were imposed by the UK in relation to trade in oil refining goods and technology, quantum computing and advanced materials goods and technology, luxury goods, and iron and steel goods;
19 April = HMRC announced its intention to revoke the Moscow Stock Exchange (MOEX)’s status as a recognised stock exchange, which would mean that investors will not be able to access certain UK tax benefits in future when trading securities on MOEX, although HMRC states that existing investments will be protected;
21 April = HMT/OFSI published a Financial Sanctions Notice – 26 entries were added to the consolidated list and are now subject to an asset freeze. 30 entries were also amended. The new sanctions target key leaders in Russia’s army, as well as senior individuals in vital logistics company Russian Railways and Ilya Kiva, a defecting and expelled Ukrainian MP who has publicly supported Russia’s actions in Ukraine;
21 April = HMT/OFSI issued a General Licence, under which a person may continue to make payments to Gazpormbank/subsidiary under a contract entered into prior to 22 April 2022 for the purposes of making gas available to the EU, and a person, relevant institution, or Gazprombank/subsidiary can carry out any activity reasonably necessary to effect this including the opening and closing of bank accounts;
22 April = The UK government announced further import sanctions against Russia for silver, wood products and high-end Russian goods such as caviar. The government is also increasing tariffs by 35 percentage points on £130m worth of goods from Russia (and Belarus) such as diamonds and rubber;

MAY

4 May = The UK Foreign Secretary, Liz Truss, announced: (a) plans to ban UK export services to Russia involving management consulting, accounting and PR services; (b) sanctions targeting individuals and organisations from Russian mainstream media; (c) legislation requiring social media, internet services and app store companies to block content from RT and Sputnik;
5 May = HMT/OFSI published a Financial Sanctions Notice – one entry to the consolidated list, relating to Evraz PLC, was amended and remains subject to an asset freeze; eight entries were corrected and remain subject to an asset freeze; and one entry, relating to Alexander Vladimirovich Korotkiy, was added;
5 May = HMT/OFSI issued a General Licence which allows persons to continue business operations with the North American subsidiaries of Evraz plc., which took effect from 5 May 2022 and expires on 2 September 2022;
9 May = The DIT announced a new package of sanctions on Russia (and Belarus) targeting £1.7bn worth of trade, including platinum and palladium. The planned export bans intend to hit more than £250m worth of goods in sectors of the Russian economy most dependent on UK goods, including key materials;
13 May = HMT/OFSI issued a General Licence which allows for payments and other permitted activities to take place in relation to winding down activities, basic needs and insolvency proceedings associated with the Amsterdam Trade Bank N.V or a subsidiary of the same, which took effect on 12 May 2022 and expires on 12 May 2023;
19 May = The FCDO and the Department for Transport announced new sanctions against Russian airlines which will prevent them from selling their UK landing spots worth an estimated £50m. Three entries were added to the consolidated list and are now subject to an asset freeze sanctions, which are Russian state owned airlines Aeroflot, Ural Airlines and Rossiya Airlines;
23 May = HMT/OFSI issued a General Licence which allows for UK nationals or companies to purchase tickets from a designated person for a journey starting in Russia, which took effect on 23 May 2022 and expires on 23 May 2023;
27 May = HMT/OFSI amended a General Licence under which a person may continue to make payments to Gazpormbank/a subsidiary under a contract entered into prior to 22 April 2022 for the purposes of making gas available to the EU, and a person, relevant institution, or Gazprombank/subsidiary can carry out any activity reasonably necessary to effect this including the opening and closing of bank accounts, which took effect on 21 April 2022 and expires on 31 October 2022;
27 May = HMT/OFSI published a Financial Sanctions Notice – nine entries to the consolidated list of financial sanctions targets in the UK under the Cyber Regime have been amended and remain subject to an asset freeze;
30 May = HMT/OFSI issued a General Licence which allows Interim Managers and trustees to act as receivers and managers with regard to a charity’s property and affairs, which took effect on 20 May 2022 and expires on 20 May 2023;
30 May = HMT/OFSI issued a General Licence which allows for the continuation of certain business operations related to providing Civilian Telecommunications Services and News Media Services, which took effect on 30 May 2022 and expires on 30 May 2024;

JUNE

10 June = HMT/OFSI issued a General Licence regarding the funds of third parties who have not been designated paid to, from or via designated Credit or Financial Institutions, which took effect on 10 June 2022 and expires on 10 September 2022;
16 June = HMT/OFSI published a Financial Sanctions Notice – 12 entries to the consolidated list were added and are now subject to an asset freeze. One entry was corrected and is still subject to an asset freeze. The sanctioned individuals include Russian Children’s Rights Commissioner, Maria Lvova-Belova, who allegedly enabled 2,000 vulnerable children to be taken from the Luhansk and Donetsk regions. Military commanders, Russian and Myanmar arms dealers and the head of the Russian Orthodox Church, Patriarch Kirill, and deputy of the Moscow city Duma and member of Putin’s political elite, Sergey Savostyanov, were also sanctioned;
16 June = HMT/OFSI published a Financial Sanctions Notice – four entries, including three members of the Russian Federal Security Service and the First Deputy Head of the Main Directorate of the General Staff of the Armed Forces of the Russian Federation, on the consolidated list of financial sanctions targets in the UK under the Chemical Weapons Regime, were amended and remain subject to an asset freeze; and,
26 June = The UK Prime Minister’s Office reported that new exports of Russian gold will no longer be allowed to be enter the UK along with Canada, US, and Japan.

Takeaways

With regard to sanctions in general, organisations should consider doing the following:

Undertaking a rigorous due diligence screening against individuals and entities on sanctions lists;
Checking whether any accounts are maintained or any funds or economic resources are held for sanctioned persons and entities;
Freezing sanctioned accounts, and other funds or economic resources and any funds which are owned or controlled by sanctioned persons and entities, and refraining from dealing with the funds or assets or making them available (directly or indirectly) to sanctioned persons (unless licenses have been granted);
Reporting any findings to the regulator and co-operating with any investigations that the regulator may undertake;
Doing a contracts clauses check on relevant contracts to ensure that provisions concerning warranties, force majeure, termination, and, liability are all up to scratch as regards sanctions;
Updating policies, procedures and risk assessments – be prepared to deal with sanctions breaches;
Where possible and of use (either as an alternative or a complement to contract breach risk), considering obtaining insurance (export credit, political risk, and, trade disruption) against sanctions risks; and,
Training staff on sanctions issues.

Resources

We report about sanctions issues here: https://www.corderycompliance.com/news/.

We spoke at an event about Russian sanctions, where we focused on sanctions policies & due diligence/screening issues: https://www.corderycompliance.com/rbcc-dit-russia-uk-02-dec/.

We have also written about the UK Economic Crime (Transparency & Enforcement) Act 2022 here https://www.corderycompliance.com/uk-ecte-act-sanctions-russia-belarus/.

For UK official guidance about the UK sanctions on Russian see here https://www.gov.uk/government/collections/uk-sanctions-on-russia and the UK sanctions list can be found here https://www.gov.uk/government/publications/the-uk-sanctions-list.

The UK Sanctions and Anti-Money Laundering Act 2018 can be found here https://www.legislation.gov.uk/ukpga/2018/13/contents/enacted.

For more information please contact André Bywater or Jonathan Armstrong who are lawyers with Cordery in London where their focus is on compliance issues.

Jonathan Armstrong, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH		André Bywater, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH
Office: +44 (0)207 075 1784		Office: +44 (0)207 075 1785
Jonathan.armstrong@corderycompliance.com		Andre.bywater@corderycompliance.com