What is this about?
The UK has imposed yet more sanctions on Russian individuals. This article is a very brief look at this development.
What are the latest additional UK sanctions concerning Russia?
Under the UK sanctions regime (for more about this see the What is the UK sanctions regime? section of our article here https://www.corderycompliance.com/add65uksanctions/) further sanctions have been imposed, this time on the following Russian propagandists and state media who the UK government accuses of spreading lies and deceit about Russia’s invasion of Ukraine:
- Sergey Brilev, a prominent Russian presenter on the state-owned TV channel Rossiya;
- TV-Novosti, the institution that controls RT and is funded by the Kremlin;
- Rossiya Segodnya, a media group owned and operated by the Russian government, which controls Sputnik, a Russian state-owned news agency;
- Colonel-General Mikhail Mizintsev, a senior Russian general and Chief of the National Defence Management Centre of the Russian Federation;
- Aleksandr Zharov, Chief Executive Officer of Gazprom-Media;
- Alexey Nikolov, the Managing Director of RT, formerly Russia Today;
- Anton Anisimov, Editor-in-Chief of Sputnik;
- Vladimir Ilich Maksimenko, Director at the Strategic Culture Foundation;
- Andrey Grigoryevich Areshev, Director at the Strategic Culture Foundation;
- Irina Sergeyevna Bubnova, Social Media Editor at the Strategic Culture Foundation;
- Anton Sergeyevich Bespalov, Social Media Editor at the Strategic Culture Foundation;
- Sergei Ivanovich Saenko, Social Media Operations at the Strategic Culture Foundation;
- Natalya Petrovna Skorokhodova, Human Resources, Finance, at the Strategic Culture Foundation; and,
- Svetlana Georgiyevna Zamlelova, Chief Editor, Journal Kamerton.
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 spoke at a recent 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 report about sanctions issues here: https://www.corderycompliance.com/news/.
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 | |
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