Sanctions Developments Resulting From the Conflict in Ukraine - United Kingdom

Table of Contents:

• Asset Freezes and Similar Measures
• Financial and Economic Restrictions
• General Licenses
• Trade Restrictions

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Asset Freezes[1] and Similar Measures

The United Kingdom (“UK”) has imposed asset freezes on Russian banks, Russian financial institutions, and individuals associated with such entities. On February 22, 2022, the UK imposed asset freezes on five Russian banks (Rossiya, IS Bank, GenBank, PSB and the Black Sea Bank).[2] On February 24, 2022, the UK announced an additional asset freeze on VTB Bank[3] and on February 28, 2022, the UK imposed asset freezes on VEB, Otkritie and Sovcombank.[4] On March 24, 2022, the UK imposed an asset freeze on Alfa Bank and on March 1, 2022, the UK imposed asset freezes on the Russian Direct Investment Fund and its Chief Executive Officer Kirill Alexandrovich Dmitriev.[5] On April 6, 2022, the UK imposed asset freezes on Sberbank and Credit Bank of Moscow.[6] On June 29, 2022, the UK imposed asset freezes on JSC Marshal.Global, JSC Moscow Industrial Bank, JSC New Opportunities and R-Style Softlab.[7] On May 19, 2023, the UK imposed asset freezes on Rosbank PJSC and Tinkoff Bank. [8]  These two banks had been previously sanctioned by the EU in February 2023.

Other Russian bank or financial institution linked individuals who are subject to UK asset freezes include: Dmitri Alekseevich Lebedev (Chairman of the Board of Directors of Bank Rossiya) and Andrei Leonidovich Kostin (Chairman of VTB Bank), both subject to an asset freeze imposed on March 10, 2022; Mikhail Fridman (founder of Alfa Bank), German Khan (business partner of Fridman in Alfa Bank), and Petr Aven (former president of Alfa Bank), all subject to asset freezes and travel bans imposed on March 15, 2022; Oleg Tinkov (the founder of Tinkoff Bank) and Herman Gref (the CEO of Sberbank), both subject to an asset freeze imposed on March 24, 2022; Andrey Akimov (the CEO of Gazprombank), subject to an asset freeze imposed on April 6, 2022; and Said Gutseriev (director controlling directly or indirectly, PJSC SFI), Vladimir Potanin (individual owning or controlling Rosbank), Ivan Tyryshkin (director of SPB Exchange and JSC NRK-R.O.S.T.), all of whom are subject to an asset freeze imposed on June 29, 2022.  

The UK has also imposed asset freezes on Russian and Belarussian entities focused on defence and engineering. On February 24, 2022, the UK imposed asset freezes upon five Russian defence and aerospace manufacturing companies: JSC Research and Production Corporation, PJSC United Aircraft Corporation, PJSC United Shipbuilding Corporation, State Corporation for the Promotion of the Development, Manufacture, and Export of High Technology Products and JSC Tactical Missiles Corporation.[9] On March 1, 2022, the UK imposed asset freezes on two Belarusian defence companies (JSC 558 Aircraft Repair Plant and JSC Integral).[10] On March 24, 2022, the UK imposed an asset freeze on Kronshtadt, the main producer of Russian drones.

In addition to the asset freezes imposed upon Russian banks, financial institutions, defence, and engineering entities, the UK has also imposed sanctions on a number of further Russian and Belarussian entities considered implicated in providing assistance for Russia’s invasion of Ukraine. On March 24, 2022, the UK imposed asset freezes on Russian and Belarusian entities, including Alrosa (the world’s largest diamond mining company), the Wagner Group (an organisation of Russian mercenaries), Russian Railways and Sovcomflot (Russia’s largest shipping company)[11]. On May 5, 2022, the UK imposed an asset freeze on Evraz Plc (a steel manufacturing and mining company which manufactures 97% of rail tracks in Russia)[12]. Top managers and directors of Russian Railways and Sovcomflot have been sanctioned as Designated Persons on May 19, 2023.[13] Additionally, on May 19, 2023 the top managers and directors of Transneft and Gazprom Neft were also sanctioned.

In addition to the asset freezes outlined above, the UK has also imposed a number of asset freezes and travel bans on certain further entities and individuals. These can be broadly broken down into the following groups:

• The UK has imposed asset freezes on a number of “oligarchs” and other individuals “with close ties to President Vladimir Putin”.[14] These include (amongst others): Gennady Timchenko, Igor Rotenberg and Boris Rotenberg (subject to asset freezes imposed on February 22, 2022)[15]; Denis Bortnikov, Petr Fradkov, Elena Georgieva, Kirill Shamalov and Yury Slyusar (subject to asset freezes imposed on February 24, 2022)[16]; Igor Ivanovich Shuvalov and Alisher Burkhanovich Usmanov (subject to asset freezes and travel bans imposed on March 3, 2022)[17]; Roman Arkadyevich Abramovich (owner of Chelsea FC), Igor Ivanovich Sechin (Chief Executive of Rosneft), Oleg Vladimirovich Deripaska (a significant shareholder in En+ Group), Alexei Borisovich Miller (CEO of Gazprom), and Nikolai Petrovich Tokarev (President of Transneft) (subject to asset freezes and travel bans imposed on March 10, 2022)[18]; Andrey Melnichenko (founder of the EuroChem Group)(subject to an asset freeze and travel ban imposed on March 15, 2022)[19]; Oleg Aksyutin (the Deputy Chairman of the Management Board of Gazprom PJSC), Galina Danilchenko (the “mayor” of Melitopol) and Polina Kovaleva (the stepdaughter of Sergey Lavrov)(subject to asset freezes and travel bans imposed on March 24, 2022)[20]; Katerina Vladimirovna Tikhonova and Maria Vladimirovna Vorontsova (the daughters of President Putin), and Yekaterina Sergeyevna Vinokurova (daughter of Sergey Lavrov)(subject to travel bans and asset freezes imposed on April 8, 2022)[21]; Nigina Zairova (Executive Assistant to Mikhail Fridman)(subject to an asset freeze imposed on April 13, 2022)[22]; Pavel Ezubov (cousin of Oleg Deripaska) and Andrey Fursenko (Assistant to President Putin) (subject to asset freezes and travel bans imposed on April 13, 2022)[23]; Eugene Tenebaum and David Davidovich (two longstanding business associates of Roman Abramovich)(subject to asset freezes imposed on April 14, 2022)[24]; and Alina Kabaeva (alleged to have a close personal relationship with Putin, and previously sat as a Deputy in the Duma for Putin’s United Russia), Anna Zatseplina (grandmother of Alina Kabaeva and associate of Gennady Timchenko), Lyudmila Ocheretnaya (former First Lady of the Russian Federation and ex-wife of Putin), Igor Putin (first cousin of Putin), Mikhail Putin (a Russian businessman, relative of Putin, Deputy Chairman of the Management Board of SOGAZ Insurance and Deputy Chairman of the Management Board of Gazprom), Roman Putin (first cousin once removed of Putin), Mikhail Shelomov (a Russian business owner and Putin’s first cousin), Alexander Plekhov (a close friend of Putin), Mikhail Klishin (an executive at Bank Rossiya and a member of the Board of Directors at SOGAZ), Vladimir Kolbin (son of Putin’s childhood friend and alleged business associate, Peter Kolbin), Yuri Shamalov (son of Nikolai Shamalov (sanctioned by the UK in 2014), and brother of Putin’s former son-in-law, Kirill (sanctioned by the UK on February 24, 2022)), Viktor Khmarin (a Russian lawyer and businessman, who is a friend and relative-by-marriage of Putin)(subject to asset freezes imposed on May 13, 2022)[25][26].

• The UK has imposed asset freezes on a number of political figures. These include: Russian President Putin and Russian Minister of Foreign Affairs Sergei Viktorovich Lavrov (subject to asset freezes and travel bans imposed on February 25, 2022)[27]; 386 members of the Russian Duma, the lower house of the Russian parliament, for their support for the Ukrainian breakaway regions of Luhansk and Donetsk (subject to asset freezes and travel bans imposed on March 11, 2022)[28]; Dmitry Medvedev (former Russian President), Mikhail Mishustin (Russian Prime Minister), and “propagandists” such as Dmitry Peskov (Russian President Putin’s press secretary and Kremlin spokesperson) (subject to asset freezes and travel bans imposed on March 15, 2022)[29]; over 150 separatists who support Russian-backed breakaway regions of Ukraine including Alexander Ananchenko and Sergey Kozlov (respectively the self-styled Prime Minister and Chair of Government of the so-called Donetsk and Luhansk People’s Republics) (subject to asset freezes and travel bans imposed on April 13, 2022)[30]; Viktor Medvedchuk (a major Ukrainian oligarch with close ties to Putin, identified by the US as a possible Kremlin puppet leader in Ukraine) (subject to an asset freeze and travel ban imposed on April 13, 2022)[31]; Ilya Kiva (an expelled Ukrainian MP who has supported the Russian invasion of Ukraine) (subject to an asset freeze and travel ban imposed on April 21, 2022)[32]; Serhiy Cherevko (member of the ‘Salvation Committee for Peace and Order’ in Kherson and former deputy Mayor of Kherson) (subject to an asset freeze and travel ban imposed on June 16, 2022); Vladimir Gundyayev, also known as Patriarch Kirill (Primate of the Russian Orthodox Church) (subject to an asset freeze imposed on June 16, 2022); Tetiana Kuzmich (member of the ‘Salvation Committee for Peace and Order’ in Kherson and former deputy Mayor of Kherson (subject to an asset freeze and travel ban imposed on June 16, 2022); Maria Lvova-Belova (Commissioner for Children’s Rights under the President of the Russian Federation) (subject to an asset freeze imposed on June 16, 2022); Volodymir Saldo (member of the Kherson City Council and member of the ‘Salvation Committee for Peace and Order’ in Kherson) (subject to an asset freeze and travel ban imposed on June 16, 2022); Sergey Savostyanov (member of the Moscow City Duma) (subject to an asset freeze and travel ban imposed on June 16, 2022); Kyrylo Stremousov (President of the ‘Salvation Committee for Peace and Order’ in Kherson) (subject to an asset freeze and travel ban imposed on June 16, 2022); and Sergei Tsivilev (subject to an asset freeze imposed on June 29, 2022).

• The UK has imposed asset freezes on a number of Russian and Belarussian military figures and entities involved in the manufacture or supply of military equipment. These include: several Belarusian military officials (Andrei Burdyko, Victor Vladimirovich Gulevich, Sergei Simonenko and Andrey Zhuk) (subject to asset freezes and travel bans imposed on March 1, 2022)[33]; Sergei Shoigu (Russian Defence Minister) (subject to an asset freeze and travel ban imposed on March 15, 2022)[34]; Mikhail Mizintsev (Russian Colonel-General) (subject to an asset freeze and travel ban imposed on March 31, 2022); Oleg Belozyorov (CEO and Board Chairman of Russian Railways, involved in transporting Russian military equipment), Lt Col Azatbek Omurbekov (the Commanding Officer of the unit that occupied Bucha, where there have been reports of war crimes), Colonel General Andrey Serdyukov (Russian Commander Airborne Forces), Maj Gen Valery Flyustikov (Russian Commander Special Operations Forces), Col Gen Nikolay Bogdanovsky (First Deputy Chief of the General Staff), Sergei Borisovich Korolyov (First Deputy Director of the Federal Security Service of Russia), (all subject to a travel bans and asset freezes imposed on April 21, 2022)[35][36] and several Colonels of the 64^th Separate Motorised Rifle Brigade of the 35^th Combined Arms Army of the Russian Federation (Viacheslav Klobukov. Andrei Kurbanov, Aleksandr Shershnev and Aleksandr Vins) (all subject to asset freezes and travel bans imposed on June 16, 2022). The UK has also imposed asset freezes on a number of Russian entities involved in the manufacture or supply of military equipment. These include: GTLK (Russia’s largest leasing company), JSC Arz Machinebuilding Plant (which manufactures the BTR-80 amphibious armoured personnel carriers, which have been used by Russia during the invasion of Ukraine), JSC Kalashnikov Concern (a Russian developer and manufacturer of army Russian equipment, including personal rifles, missiles and vehicles used by Russian Armed Forces), LLC Military Industrial Company (a major arms and military equipment provider to the Russian Armed Forces) (all subject to asset freezes imposed on April 21, 2022)[37].

• The UK has imposed sanctions on: Russian state media organisations such as Kremlin funded TV-Novosti who own RT, formerly Russia Today, and Rossiya Segodnya who control news agency Sputnik, (both subject to asset freezes imposed on March 31, 2022); as well as other strategic propaganda organisations such as Radio Broadcasting (a major Russian state-owned broadcaster), InfoRos (a news agency spreading destabilising disinformation about Ukraine), SouthFront (a disinformation site that has spread false information that seeks to justify Russia’s invasion of Ukraine), the Strategic Culture Foundation (an online journal spreading disinformation about Russia’s invasion of Ukraine) (all subject to asset freezes imposed on May 4, 2022)[38] and United World International (an online news site promoting pro-Russian disinformation), subject to an asset freeze imposed on July 4, 2022[39]. In addition, the UK has also imposed asset freezes and travel bans on a number of individual media figures and “propagandists”.[40] These include, amongst others: Sergey Brilev (TV anchor on Russia state-owned media Rossiya), Aleksandr Zharov (Chief Executive Officer of Gazprom-Media and former Head of the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)), Alexey Nikolov (Managing Director of RT), and Anton Anisimov, (Head of Sputnik International Broadcasting), (all of whom are subject to asset freezes and travel bans imposed on March 31, 2022)[41] and Aleyona Chuguleva (Secretary of the Organizing Committee of Patriotism in Journalism), Darya Dugina (frequent and high-profile contributor on various online platforms), Yuriy Fedin (entrepreneur providing funding to Russian news organization NewsFront), Yevgeniy Glotov (deputy director of Newsfront), Aelita Mamakova (a key individual associated with disinformation website SouthFront), Mikhail Sinelin (cofounder of Newsfront) (all of whom are subject to asset freezes imposed on July 4, 2022)[42], and Denis Gafner and Valeriya Kalabayeva (both individuals involved in spreading disinformation and promoting Russian actions in Ukraine, and subject to asset freezes imposed on July 5, 2022)[43]; and significant individuals at Channel One including Evgeny Poddubny (a war correspondent for the All-Russia State Television and Radio Broadcasting Company), Alexander Kots (a war correspondent for Russian newspaper Komsomolskaya Pravda), and Dmitry Steshin (a Russian journalist and special correspondent for Komsomolskaya Pravda), (all subject to asset freezes imposed on May 4, 2022)[44].

• The UK has also imposed asset freezes on a number of individuals and entities involved in the energy, construction, resources, extraction, agriculture and manufacture sectors considered implicated in providing assistance for Russia’s invasion of Ukraine. These include: Viatcheslav (Moshe) Kantor (the largest shareholder of fertilizer company Acron with vital strategic significance for the Russian government), Andrey Guryev (close associate of Vladimir Putin and founder of PhosAgro, a vital strategic company that produces fertilizer), Sergey Kogogin (director of Kamaz, a manufacturer of trucks and buses, including for the Russian military), Leonid Mikhelson (founder and CEO of leading Russian natural gas producer Novatek), Aleksander Dyukov (CEO of GazpromNeft), Boris Borisovich Rotenberg (son of the co-owner of Russia’s largest gas pipeline producer SGM), Sergey Sergeyevich Ivanov (President of Alrosa, the world’s largest diamond producer), all of whom are subject to asset freezes and travel bans imposed on April 6, 2022,[45] Ruslan Baysarov (Chairman of the Board of Directors of the Bamtonnelstroy-Most Group of Companies, one of Russia’s largest construction enterprises specializing in transport infrastructure), Sait-Salam Gutseriev (director of JSC NK Neftisa, an entity carrying on business in the energy sector), Mihajlo Perenčević (president of the Russian pipeline construction company, Vellesstroy), Anna Tsiveleva (Chair of the Board of Directors of JSC Kolmar Group), and JSC Kolmar Group (a Russian energy and extractives company), all of whom are subject to asset freezes imposed on June 29, 2022[46]. These also include AFK Sistema, PJSC Severstal, Mechel (Chelyabinsk Metallurgical Plant), OMK (United Metallurgical Company), MMK (Magnitogorsk Iron & Steel Works), TMK (Pipe Metallurgical Company), Russian Copper Company ZAO (together with its beneficial owner, Igor Altushkin), the State Grain Operator (together with its top managers and / or directors) (subject to an asset freeze imposed on May 19, 2023).[47]

• The UK has also imposed asset freezes on the Russian airline sector, preventing Russian airlines from selling their unused landing slots at UK airports.[48] The airlines subject to asset freezes are JSC Rossiya Airlines, JSC Ural Airlines, and PJSC Aeroflot.[49] Asset freezes and travel bans have also been imposed on prominent individuals in this sector, including Alexey Isaykin (President and board member of Volga-Dnepr Group, a Russian transport company with significant air operations of strategic significance to the Russian government) (subject to an asset freeze imposed on June 16, 2022). Similarly, asset freezes have been imposed upon several entities in the maritime sector, including Sovfracht and the Far Eastern Shipping Company (subject to an asset freeze imposed on May 19, 2023).[50]

Financial and Economic Restrictions

Following an announcement on February 28, 2022 that the UK would adopt such measures,[51] on March 1, 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022 was adopted, outlining new restrictions on the provision of financial services for the purpose of foreign exchange reserve and asset management.  The amendment prohibits a UK individual or entity from providing financial services for the purpose of foreign exchange reserve and asset management to: (i) the Russian Central Bank, (ii) the Russian National Wealth Fund, (iii) Russian Ministry of Finance, (iv) any person owned or controlled directly or indirectly by any of these government entities; or (v) any person acting on behalf of or at the direction of any of these government entities.  Financial services are broadly defined as “any services of a financial nature in many different forms including insurance and banking.” and “include payment and money transmission services.”

On March 1, 2022, a number of amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 came into force.  

Existing restrictions on dealing with certain financial instruments and providing loans and credit were amended to extend the sanctions prohibitions to a broader range of transferable securities and money market instruments and loans and credit.  Amendments prohibit dealing with transferable securities and money market instruments issued on or after March 1, 2022 by:  

• (1) any person incorporated or constituted under UK law and owned by a designated person  (a list of eleven entities that were previously subject to sectoral sanctions including Sberbank, VTB Bank, Gazprombank and VEB), or an entity acting on behalf of or at the direction of such an entity, where the security or instrument has a maturity exceeding 30 days;

• (2) a “person connected with Russia” or an entity owned by or acting on behalf or at the direction of a “person connected with Russia” (the notion covers persons who are not specifically listed (as per (1)) and who are ordinarily residing, located, domiciled or incorporated in Russia); or

• (3) the Government of Russia itself. 

Amendments also expand the scope of the existing prohibitions on issuing loans or credit to include loans or credit made or granted to those listed in (1), (2), and (3) above.  For persons falling under categories 1 and 2 (as well as persons previously made subject to sectoral sanctions) those loans and credit cannot exceed 30 days and for the Government of Russia no loans are permitted.

Amendments also introduce restrictions on correspondent banking relationships and the processing of sterling payments.  UK credit or financial institutions are prohibited from establishing or continuing a correspondent banking relationship, and from processing sterling payments to, from or via a designated person or a credit or financial institution owned or controlled by them (with the exception of processing of a sterling payment for any fee or charge required to permit an aircraft to overfly, land in or take off from Russia).

On March 3, 2022, the UK announced that it would adopt additional sanctions targeting the provision of insurance and reinsurance services to Russian companies in the aviation and space industries.[52]  The announcement stated that under the forthcoming legislation UK-based insurance and reinsurance providers will be prohibited from undertaking financial transactions connected to such companies.  This prohibition was adopted as part of the March 8, 2022 amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 described in further detail below.  On March 8, 2022, the Department of International Trade’s Export Control Joint Unity published a “General Trade Licence: Russia Sanctions, Aviation Insurance” authorizing, under contracts concluded before March 8, 2022 and subject to certain exceptions, insurance providers to provide insurance and reinsurance services relating to aviation and space-related goods and technology until March 28, 2022 (provided that the insurance provider did not and does not reinsure any of their obligations to provide those insurance services before March 8, 2022 and that no such reinsurance has, as a matter of applicable law, been rendered unenforceable, suspended, frustrated or prohibited by any applicable sanctions).[53]

On March 8, 2022, the UK adopted further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019, implementing new air travel and trade sanctions, in addition to the insurance/reinsurance prohibition described above.[54]  The amendments prohibit aircraft registered in Russia or otherwise owned, chartered or operated by a designated person or entity or a person or entity “connected with Russia” from overflying or landing in the UK (subject to certain safety-related exceptions).  The amendments also empower the Secretary of State, air traffic control and airport operators to issue directions preventing Russian aircraft from entering UK airspace or landing in the UK, and requiring Russian aircraft to leave UK airspace.  The Secretary of State is also empowered to direct an airport operator to detain or secure the movement of Russian aircraft, to direct the Civil Aviation Authority to refuse, suspend or revoke permissions regarding Russian aircraft, and to prohibit registration under the Civil Aviation Authority of aircraft owned, operated or chartered by a designated person.  The new amendments expand the definitions of “restricted goods” and “restricted technology” subject to export bans with respect to Russia to include aviation and space-related goods and technology.  The amendments also make it a criminal offense to violate the new prohibitions or to fail to comply with directions from the Secretary of State.

On April 6, 2022, the UK announced an outright prohibition on all new outward investment to Russia.[55] On July 14, 2022, the UK adopted further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 to introduce these investment restrictions (which entered into force on July 19, 2022). The regulations prohibit individuals and legal persons from undertaking certain investment activities, including, amongst others, (i) the direct acquisition of any ownership interest in Russian land and entities connected with Russia, (ii) the indirect acquisition of any ownership interest in Russian land and entities connected with Russia for the purpose of making funds or economic resources available (directly or indirectly) to, or for the benefit of, persons connected with Russia, (iii) establishing joint ventures with a person connected with Russia and (iv) the provision of investment services directly related to such activities (and all others listed in sub-paragraphs 18B(2)(a) – (g) of the Regulations).

On May 4, 2022, the UK adopted further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 resulting in social media, internet services and app store companies now being required to take action to block content from two of Russia’s major sources of disinformation – RT and Sputnik.[56]

On June 29, 2022, the UK announced that it would be acting alongside international allies to introduce new measures that will prevent Russia from accessing UK trusts services.[57] As of the date of this blog post, no regulations introducing these measures have been published and adopted and, therefore, they have not yet come into effect, although one may expect this to occur in the near future.

On July 14, 2022, the UK adopted further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 to amend the designation criteria under the Russia sanctions regime by: (i) expanding the definition of “involved in obtaining a benefit from or supporting the Government of Russia” to include working as a “manager” of or otherwise “holding the right, directly or indirectly, to nominate at least one director (whether executive or non-executive), trustee or equivalent” of a Russian government-affiliated entity, an entity carrying on business as a Government of Russia-affiliated entity or an entity carrying on business of economic significance to the Government of Russia, (ii) identifying individuals occupying certain official roles under the Russian government or affiliates as being involved in “destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine” or “obtaining a benefit from or supporting the Government of Russia”, and (iii) expanding the definition of being “associated with” a person to include being an immediate family member of that person.

On July 19, 2022, the UK published the Sanctions (EU) (Exit) (Miscellaneous Amendments) (No. 2) Regulations 2022 which amends, amongst others, the Russia (Sanctions) (EU Exit) Regulations 2019 to expand the definition of “relevant firms” to include cryptoasset exchange providers and custodian wallet providers. Upon the amendments coming into force on August 30, 2022, these firms will become subject to the obligation to notify the Office of Financial Sanctions Implementation as soon as practicable when encountering a designated person in the course of their business.

On December 14, 2022, the UK introduced further amendments to the Russia (Sanctions) (EU Exit) Regulations 2019, which expanded the scope of restrictions on dealings with financial instruments and the provision of loans and credit arrangements.[58] As a result, dealings with transferable securities and money-market instruments issued after 15 December, 2022 by entities not connected with Russia; and the provision of credit after 15 December, 2022 to entities not connected with Russia, will be restricted if the respective issuance or provision of loans is made for the purpose of prohibited investments in relation to Russia.[59]

The amendments also altered the definition of ‘relevant entity’ in Russia (Sanctions) (EU Exit) Regulations 2019, which from 16 December 2022 onwards means ‘all persons not connected with Russia’. This change expands the scope of the relevant term to ensure that the imposed investment restrictions cannot be sidestepped by investing before funds are used for the purposes of restricted investment into Russia.

Additionally, the amendments impose restrictions upon the provision of trust services to, or for the benefit of, designated persons and persons connected with Russia from 16 December, 2022 onwards. The restrictions pertain not only to the creation of a new trust, but also to the operation and management of a trust, the acting as, or providing assistance in finding, a trustee, and the provision of a registered office or another relevant address for a trust. Trust services provided to persons connected with Russia on the basis of an ongoing pre-16 December 2022 arrangement are excluded from the above limitations. Likewise, trust services may be offered after 16 December 2022 to: (i) amateur sports clubs, charities, pension schemes, authorised unit trust schemes or by way of business in certain circumstances; and (ii) make funds and economic resources available to underage or legally incapable individuals, so long as said services are not provided primarily for the benefit of a designated person or a person connected with Russia. The exceptions also cover trust services provided: (i) to comply with UK statutory and regulatory obligations, including asset freezes and other financial restrictions under Russia (Sanctions) (EU Exit) Regulations 2019; or (ii) in connection with non-sanctioned dealing in transferable securities or money-market instruments.  

General Licenses

On February 25, 2022, the Office of Financial Sanctions Implementation published a GL concerning the wind down of positions involving VTB Bank.[60]  The GL states that a person or relevant institution may wind down any transactions to which it is party involving VTB Bank or VTB Bank’s subsidiaries, including the closing out of any positions.  The GL took effect on February 25, 2022 and expired on March 27, 2022.  This GL was amended on March 9, 2022 to clarify that funds becoming payable to VTB Bank as a necessary part of a wind-down transaction do not need to be paid into a frozen account.  Regarding funds becoming payable to VTB Bank’s subsidiaries as a necessary part of a wind-down transaction, the Office of Financial Sanctions Implementation suggested that parties consider how VTB Bank’s ownership and control of such entities make the asset freeze applicable, if at all.

On March 1, 2022, the Office of Financial Sanctions implementation issued five further GLs.  The first, “Transferable securities, money-market instruments, loans and credit arrangements,”[61] authorized until March 8, 2022 certain dealings with transferable securities or money-market instruments otherwise prohibited by the UK sanctions on Russia.  The second, “Correspondent Banking Relationships & Processing Sterling Payments,”[62] authorized until March 31, 2022 correspondent banking relationships between UK credit or financial institutions and Sberbank (and connected entities), and the processing of certain sterling payments between these entities.  The third, “Correspondent Banking Relationships & Processing Sterling Payments in relation to Energy,”[63] authorizes until June 24, 2022 the processing of sterling payments between UK credit or financial institutions and Sberbank (and connected entities) for the purposes of making “Relevant Energy Products” (meaning crude oil, petroleum products and gas) available for use in the UK. This GL was amended on April 6, 2022 as Sberbank became subject to an asset freeze. The amendment ensures that the GL in respect of energy related payments may continue to be used in spite of the asset freeze of Sberbank. The fourth, “Regulatory Authorities – Prudential Supervision or Financial Stability,”[64] allowed until March 1, 2023 anything to be done by, or on behalf of a “Relevant Authority” (meaning the Financial Conduct Authority, the Prudential Regulations Authority, the Financial Services Compensation Scheme and the Bank of England) in respect of a UK subsidiary of VTB Capital for the purposes of the statutory functions of that authority as they relate to prudential supervision or protecting, maintaining or enhancing the stability of the financial system of the UK.  The fifth, “Russian Banks – UK subsidiaries - Basic needs, routine holding and maintenance and the payment of legal fees,” permits VTB Capital plc and any entity owned or controlled by VTB Capital plc that is incorporated in the UK to make basic needs payments (as outlined in further detail in the GL). Pursuant to this GL, 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. On April 22, 2022, this GL was amended to also include Sberbank CIB (UK) Ltd. The GL takes effect in its amended form from April 22, 2022, and expires on April 3, 2023.[65]

On March 4, 2022, the Office of Financial Sanctions Implementation issued a GL authorizing persons (other than Otkritie, PSB, Rossiya, Sovcombank, VEB, Novikombank, and their subsidiaries) to wind down any transactions to which they are a party that involve Otkritie, PSB, Rossiya, Sovcombank, VEB, Novikombank or their subsidiaries, including closing out their positions.[66]  The GL took effect on March 4, 2022 and expired on April 3, 2022.

On March 4, 2022, the Office of Financial Sanctions Implementation issued a GL authorizing persons to provide financial services to Sberbank or its subsidiaries for the purposes of winding down such activity.[67]  The GL authorized persons, relevant financial institutions and Sberbank and its subsidiaries to carry out any activity reasonably necessary to effect such services.  The GL took effect on March 4, 2022 and expired on April 3, 2022.

On March 8, 2022, the Department of International Trade’s Export Control Joint Unity published a “General Trade Licence: Russia Sanctions, Aviation Insurance” which authorized, under contracts concluded before March 8, 2022 and subject to certain exceptions, insurance providers to provide insurance and reinsurance services relating to aviation and space-related goods and technology until March 28, 2022 (provided that the insurance provider did not and does not reinsure any of their obligations to provide those insurance services before March 8, 2022 and that no such reinsurance has, as a matter of applicable law, been rendered unenforceable, suspended, frustrated or prohibited by any applicable sanctions).[68]

On March 9, 2022, the Office of Financial Sanctions Implementation issued a GL authorizing flight data providers to make payments directly or via a relevant institution to Belaeronavigatsia (a Belarusian state-owned provider of air navigation services) for aeronautical information and data.[69]  Under this GL, Belaeronavigatsia is also permitted to provide aeronautical information and data to flight data providers for the purposes of civil aircraft flight safety and allows flight data providers to use this data.  The GL took effect on March 9, 2022 and may be revoked by HM Treasury at any time.

On March 10, 2022, the Office of Financial Sanctions Implementation issued a GL authorising Chelsea FC to continue operating on certain terms, in spite of the asset freeze now imposed on its owner, Roman Abramovich. Pursuant to the GL, (i) Chelsea FC are able to pay the wages of all employees, including players and coaching staff, (ii) the club can pay ‘reasonable’ costs of travel to and from fixtures not exceeding £20,000 per game per team, (iii) the club can pay ‘reasonable’ costs towards hosting home fixtures, not exceeding £500,000 per fixture per team, (iv) parties who bought season tickets or individual tickets before March 10, 2022 are able to attend games, but no further tickets can be sold, and (v) broadcasters can continue to broadcast club fixtures. This GL expired on May 31, 2022 and has not been extended. It is no longer applicable.

On March 22, 2022, the Office of Financial Sanctions Implementation issued a GL permitting the wind down of derivative, repurchase and reverse repurchase transactions with the Russian Central Bank, the Russian Ministry of Finance and the Russian National Wealth Fund.[70]  In addition, the GL permits the provision of financial services for the purpose of winding down any derivative, repurchase or reverse transaction entered into prior to March 1, 2022 with the Russian Central Bank, the Russian Ministry of Finance or the Russian National Wealth Fund. This GL expired on May 2, 2022.

On March 24, 2022, the Office of Financial Sanctions Implementation issued two additional GLs.  The first, which took effect on March 24, 2022 and expired on April 23, 2022, provided a 30-day period to wind down positions involving Bank Dabrabyt Joint Stock Company.[71]  The second, which took effect on March 24, 2022 and expired on April 23, 2022, provided a 30-day period to wind down positions involving Alfa Bank JSC, Gazprombank, Rosselkhozbank, SMP Bank and Ural Bank for Reconstruction and Development.[72] This GL was amended on April 21, 2022 to clarify that the GL does not contain a requirement that funds becoming payable to the designated persons as a necessary part of a person winding down any transactions they have with the designated persons be paid into a frozen account.[73]

On March 25, 2022, the Office of Financial Sanctions Implementation issued a GL permitting the continuation of business operations involving GEFCO (a Joint Venture owned by Russian Railways and Stellantis) or its subsidiaries, including GEFCO UK Ltd, GEFCO Forwarding UK, Auto XP Limited or XP Tech Limited.[74] Activities permitted pursuant to the terms of this GL included making payments to or from GEFCO or its subsidiaries under any obligations or contracts and making payments to or from a third party which were necessary for the continuation of any obligations or contracts. This GL took effect on March 25, 2022. This GL was amended on April 4, 2022 to permit persons or a relevant institution to process payments or transactions related to the sale and transfer of GEFCO’s shares by Russian Railways. This GL was revoked on April 12, 2022 following the sale of Russian Railways’ stake in GEFCO to non-designated persons (which was completed on April 8, 2022). This had the effect of GEFCO no longer being impacted by UK sanctions.

On March 29, 2022, the Office of Financial Sanctions Implementation issued a GL permitting the wind down of any transactions involving Sovcomflot or a subsidiary, including the closing out of any positions.[75]  This GL took effect on March 29, 2022. This GL expired on June 30, 2022.

On April 1, 2022, the Office of Financial Sanctions Implementation issued a GL permitting the provision of financial services (and any other activity reasonably necessary to affect such services) for the purposes of the receipt and onward transfer of non-rouble-denominated interest/coupon or maturity/principal payments from the Russian Central Bank, the Russian Ministry of Finance and the Russian National Wealth Fund in connection with debt issued by those entities before March 1, 2022.[76]  This GL took effect on April 1, 2022 and expired on June 30, 2022.

On April 6, 2022, the Office of Financial Sanctions Implementation issued a GL permitting a 30 day wind down period of positions involving Credit Bank of Moscow. Under this GL a person (other than the Credit Bank of Moscow or a subsidiary) may wind down any transactions to which it is a party, involving the Credit Bank of Moscow or a subsidiary including the closing out of any positions, and a person, relevant institution, or the Credit Bank of Moscow or a subsidiary can carry out any activity reasonably necessary to effect this.[77] This GL took effect on April 6, 2022 and expired on May 6, 2022.

On April 21, 2022, the Office of Financial Sanctions Implementation issued a GL to allow payments to Gazprombank or a subsidiary for the purpose of making gas available in the European Union. Under this GL a person may continue to make payments to Gazprombank or a subsidiary under a contract entered into prior to the date of the licence (April 21, 2022) for the purpose of making gas available for use in the European Union and a person, relevant institution, or Gazprombank or a subsidiary can carry out any activity reasonably necessary to effect this.[78] Any person making payments under this GL must keep accurate, complete and readable records of any activity purporting to have been permitted under this licence for a minimum of 6 years.

This GL took effect on April 21, 2022 and expired on October 31, 2022.

On April 27, 2022, the Office of Financial Sanctions implementation issued a GL under the Russia and Global Anti-Corruption sanctions regimes. Subject to certain conditions as outlined in the GL, this GL indefinitely authorises an officer of a non-Crown relevant organisation (the Financial Conduct Authority (“FCA”) or another organisation authorised by HM Treasury) to carry out their duties, including investigating suspected proceeds of crime, undertaking activities connected to asset preservation associated with the proceeds of crime, and activities related to the enforcement and recovery of proceeds of crime. The GL also permits FCA officers to carry out actions necessary to comply with specified orders, negotiated settlements, or approved deferred prosecution agreements.[79]   

On May 5, 2022, the Office of Financial Sanctions Implementation issued a GL permitting the continuation of business of Evraz Plc’s North American subsidiaries.[80] Under this license, a person may continue business operations involving the North American subsidiaries of Evraz including: payments to or from the North American subsidiaries under any obligations or contracts; payments to or from any third party under any obligations or contracts; and receipt of payments made by the North American Subsidiaries for audit services. This GL took effect on May 5, 2022 and, following an extension on August 18, is now set to expire on March 31, 2023.

On May 13, 2022 the Office of Financial Sanctions Implementation issued a GL[81] allowing the Amsterdam Trade Bank N.V (a majority owned subsidiary of Alfa-Bank JSC) to make payments for its basic needs including payment of remuneration, allowances or pensions of employees, payment of tax, and payment for goods and services. Under this GL a person (other than Amsterdam Trade Bank N.V or a subsidiary of Amsterdam Trade Bank N.V) may wind down any transactions to which it is a party, involving Amsterdam Trade Bank N.V or a subsidiary including the closing out of any positions and the restructuring of loans or other debt, and a person can carry out any activity reasonably necessary to effect this. This GL took effect on May 12, 2022 and expires on May 12, 2023.

On May 23, 2022 the Office of Financial Sanctions Implementation issued a GL[82] allowing payments and other permitted activities to take place in relation to the purchase of tickets by United Kingdom persons from PSJC Aeroflot, JSC Rossiya Airlines, JSC Ural Airlines or Russian Railways or any entity owned or controlled by these entities, for flights or rail journeys originating in, or within, Russia. Under the GL, a United Kingdom person, relevant institution or designated person may carry out any activity reasonably necessary to effect the purchase of tickets for flights or rail journeys referred to above. This GL took effect on May 23, 2022 and expires on May 23, 2023.

On May 30, 2022 the Office of Financial Sanctions Implementation issued a GL[83] permitting an interim manager appointed by the Charity Commission to act as receiver and manager in respect of the property and affairs of a charity and/or trustee to authorise payments for the basic needs of any charity linked to a designated person and being administered by the interim manager and/or the trustees, including but not limited to the payment of insurance premiums, payment of reasonable fees for the provision of property management services, allowances or pensions of employees, payment of tax, payment of rent or mortgage payments and utility payments. An interim manager or trustee may also authorise payments for reasonable fees or reasonable service charges arising from the routine holding and maintenance of a charity’s frozen funds or economic resources, and may authorise payment of reasonable professional fees (e.g., for legal, accountancy and audit services), or reasonable expenses associated with the provision of those services and the investment manager’s remuneration as authorised by the Charity Commission. This GL took effect on May 30, 2022 and expires on May 30, 2023.

On May 30, 2022 the Office of Financial Sanctions Implementation issued a GL[84] permitting persons, other than persons designated under Regulation 5 of the Russia (Sanctions) (EU Exit) Regulations 2019, to continue business operations involving the provision of ‘electronic communication networks’ or ‘electronic communication services’ as defined by Section 32 of the Communications Act 2003 that is used for civilian purposes (“Civilian Telecommunications Services”). Permitted business operations include (but are not limited to) payments to or from ZAO TransTeleCom Company (“ZAO”, a designated person) under any contracts or other obligations with ZAO, payments to or from any third party necessary to the continuation of any such contracts or other obligations between such person and ZAO, including payments to, from or via designated credit or financial institutions and any activity reasonably necessary to effect the receipt or provision of Civilian Telecommunications Services from ZAO. Such payments may also be processed by relevant financial institutions. This GL took effect on May 30, 2022 and expires on May 30, 2024.

On June 30, 2022, the Office of Financial Sanctions Implementation issued a GL[85] permitting a 30-day wind down period of positions involving Rosbank PJSC (“Rosbank”), or a Rosbank subsidiary. Under this GL, a person (other than Rosbank or a Rosbank subsidiary), may wind down any transactions to which it is a party, involving Rosbank or a Rosbank subsidiary including the closing out of any positions, repayment of loans, withdrawal of deposits and closing of accounts, and a person, relevant institution, Rosbank or a Rosbank subsidiary can carry out any activity reasonably necessary to effect this. This GL took effect on June 30, 2022 and expired on September 30, 2022.

On July 7, 2022, the Office of Financial Sanctions Implementation issued a GL[86] permitting “Relevant Persons” (including the United Nations and its agencies, funds, programmes and appeal partners, the International Committee of the Red Cross, any UK funded person and members of the UK Disasters Emergency Committee) to undertake humanitarian activity in relation to the conflict in Ukraine without applying for individual licenses. This GL took effect on July 7, 2022 with no set expiration date, though the HM Treasury may, pursuant to the terms of the GL, vary, revoke or suspend the license at any time. 

On July 19, 2022, the Office of Financial Sanctions Implementation issued a GL[87] permitting “Persons” (including individuals, legal persons and any organization or association or combinations of persons) to undertake investment activities banned by the outward investment ban in order to allow for a 7-day wind down period. This GL took effect on July 19, 2022 and expired on July 26, 2022.

On July 22, 2022, the Office of Financial Sanctions Implementation issued a GL[88] allowing individuals or entities designated under the UK Sanctions Regimes (“UK DPs”) – with the exception of entities or individuals subject to United Nations sanctions – to make payments to insurers for insurance premiums and broker commissions relating to the provision of building and insurance cover provided to UK properties. The licence also permits UK insurers to make payments to UK DPs due as a result of a successful claim made against an insurance policy or refunds due as a result of any overpayments made under the licence. The licence came into force on July 22, 2022 and was amended on August 17, 2022 to include payments in respect of terrorism insurance, property owners’ liability insurance, and claims preparation costs insurance.

On August 5, 2022, the Office of Financial Sanctions Implementation issued a GL[89] allowing “Persons” (including individuals, legal persons and any organization or association or combination of persons) to make use of the retail banking services of a designated Credit or Financial Institution to make or receive payments exclusively for the purpose of winding down business operations in Russia. The GL took effect on August 5, 2022 and expired on November 5, 2022.

On August 16, 2022, the Office of Financial Sanctions Implementation issued a GL[90] allowing “Persons” (including individuals, a body of persons corporate or unincorporate, any organization or any association or combination of persons) to make payments to a Sanctioned Bank (including Credit Bank of Moscow, Gazprombank, Sberbank and Rosbank PJSC) or a Subsidiary of a Sanctioned bank for the purpose of making energy available for use in Mongolia. The GL took effect on August 15, 2022 and expires on August 14, 2023.

On August 22, 2022, the Office of Financial Sanctions Implementation issued a GL[91]  allowing banks to take payments of bank and service fees from accounts frozen under the Russia (Sanctions) (EU Exit) Regulations 2019, arising from the routine holding or maintenance of those accounts. The GL took effect on August 22, 2022 with no planned expiration date, but is subject to variation or suspension by HM Treasury at any time.

On August 22, 2022, the Office of Financial Sanctions Implementation issued a GL[92] allowing Crown Servants, contractors of the Crown, and their family members in Russia (as well as family members visiting Russia) to carry out activities in their personal capacity which would otherwise be prohibited by Regulations 11-15 and 17A of the Russia (Sanctions) (EU Exit) Regulations 2019. The GL takes effect from August 19, 2022 with no planned expiration date, but is subject to variation or suspension by HM Treasury at any time.

On October 17, 2022, the Office of Financial Sanctions Implementation issued a GL[93] allowing Designated Persons (“DPs”), companies owned or controlled by DPs or their legal representatives to make payments to the London Court of International Arbitration (“LCIA”) to cover arbitration costs. The GL also permits the LCIA to use funds previously deposited by DPs (or companies owned by DPs or their legal representatives) to pay for arbitration costs. The GL takes effect from October 17, 2022 with no planned expiration date, but is subject to variation or suspension by HM Treasury at any time.

On October 28, 2022, the Office of Financial Sanctions Implementation issued a GL[94] allowing payments to be made by persons designated under the Russia Regulations or the Belarus Regulations (a “DP”), or an individual or body corporate (or unincorporate) owned or controlled by a DP for legal professional fees (including counsel fees) and expenses associated with the provision of legal services. The GL took effect from October 28, 2022 and expires on April 28, 2023.

On October 29, 2022 the Office of Financial Sanctions Implementation issued a GL[95] allowing “Persons” a 7-day wind down period to enter into arrangements granting “category 5” loans (as defined in the Russia Regulations.. The GL took effect from October 28, 2022 and expired on November 5, 2022.

On October 29, 2022, the Office of Financial Sanctions Implementation issued a GL[96] permitting “Persons” (including an individual, a body of persons corporate or unincorporate) to grant certain loans to Gazprom Germania (“Gazprom”) or its subsidiaries, known as Securing Energy for Europe, for the following activities: (i) trading in gas and power market trades; (ii) payments in respect of credit arrangements and invoices by Gazprom or its subsidiaries; (iii) consumer credit or other customer arrangements to make prepayments to Gazprom; (iv) providing clearing services to Gazprom or its subsidiaries; (v) payments and loan arrangements between Gazprom and its subsidiaries; or (vi) issuing and providing financing for letters of credit. The GL took effect on October 28, 2022 and expires on October 29, 2023.

On November 2, 2022, the Office of Financial Sanctions Implementation issued a GL[97] permitting Truphone Limited (including its subsidiaries as of November 2, 2022 but excluding Cellnetrix Technology LLC) to make and receive payments for the purpose of continuing to provide telecommunication services under existing arrangements.  It also explicitly prohibits any person (including any individual, body corporate or unincorporate, any organization or any association or combination of persons; for the avoidance of doubt, including shareholders, directors, and, expressly, designated persons Mr Alexander Grigoryevich Abramov and Mr Alexander Vladimirovich Frolov) from directly or indirectly paying or repaying any loans or debt facilities extended to the Truphone, with the sole exception that Truphone may, subject to certain conditions, receive loan funding of £4,000,000 from a director of Truphone. The GL took effect on November 2, 2022 and expires on April 28, 2023.

On November 4, 2022, the Office of Financial Sanctions Implementation issued a GL[98] to allow exporters, certain financial institutions, insurance providers, UK corporates or certain UK nationals to enter into economic transactions related to export, sale, production and transport of agricultural commodities (including the provision of insurance and other services). The GL took effect from November 4, 2022 with no planned expiration date, but is subject to variation or suspension by HM Treasury at any time.

On December 15, 2022, the Office of Financial Sanctions Implementation issued a GL[99] to temporarily permit dealings with financial instruments and the provision of loans which have otherwise become prohibited following the latest amendments to Russia (Sanctions) (EU Exit) Regulations 2019 introduced on December 14, 2022. The GL took effect from December 16, 2022 and expired on December 22, 2022. The brief nature of the GL is explained on the basis of it simply providing a short wind-down period in respect of the new financial restrictions.

Trade Restrictions

On February 28, 2022, the UK removed Russia as a permitted destination from numerous open general export licences (“OGELs”),[100] and suspended the approval of new export licences for dual-use items to Russia with immediate effect.[101]

On March 1, 2022, a number of further amendments were made to the 2019 Regulations, expanding the scope of the existing ban on the export, supply and delivery, making available and transfer of military goods and technology to and for use in Russia, to include critical-industry goods and technology and dual-use goods and technology, and military goods and technology.  

The critical‑industry goods and technology include certain electronics, computers, telecommunications equipment and information security, sensors and lasers, marine-related items and aerospace and propulsion-related items.  The related prohibition on the provision of technical assistance, financial services, funds and brokering services to these additional categories of goods/technologies is also extended.  A number of exceptions from the trade prohibitions on critical-industry goods and technology are provided for, including, in relation to personal items and diplomatic missions, consular posts and international organisations, the movement of aircraft and vessels, consumer communication devices and software updates, and emergencies.

On March 8, 2022, in connection with a similar announcement by the United States, UK Business Secretary Kwasi Kwarteng announced that the UK will phase out the importation of Russian oil by the end of 2022 (acknowledging that Russian oil imports would be necessary during the phase-out period), and that the UK government will establish a new “Taskforce on Oil” to support private industry in finding alternative supplies.[102]

On March 15, 2022, in connection with similar announcements by its allies, the UK announced a ban on exports to Russia of certain high-end luxury goods (including certain vehicles, fashion items and artwork) and the imposition of new import tariffs on certain Russian and Belarusian products (including iron, steel, fertilisers, wood, tyres, railway containers, cement, copper, aluminium, silver, lead, iron ore, food waste products, beverages, spirits and vinegar (including vodka), glass and glassware, cereals, oil seeds, paper and paperboard, machinery, works of art, antiques, fur (and artificial fur), ships, and white fish).[103]  In addition, the UK announced it will deny both Russia and Belarus access to World Trade Organization (WTO) most favoured nation (MFN) tariff treatment.

On April 6, 2022, it was further announced that the UK will, by the end of 2022, end all dependency on Russian coal and oil, and end imports of gas as soon as possible thereafter. From the week commencing April 11, 2022, the export of key oil refining equipment and catalysts will also be banned. The announcement also outlined action implemented by the UK against key Russian strategic industries and state owned enterprises. This includes banning imports of iron and steel products and new restrictions on Russia’s ability to acquire UK quantum and advanced material technologies.[104]

On April 14, 2022, the UK Parliament adopted the Russia (Sanctions) (EU Exit)(Amendment)(No.8) Regulations 2022 [105] pursuant to which it is prohibited to directly or indirectly export luxury goods to, or for use in, Russia. In addition, these regulations prohibit the import of iron and steel products which are consigned from Russia, the import of iron and steel products which originate in Russia, and the direct or indirect acquisition of iron and steel products which are located in or originate from Russia.

On May 8, 2022, the UK announced a package of Russia and Belarus trade sanctions for which legislation would be passed in due course. The measures announces include an additional 35% import tariff which shall be imposed on £1.4 billion of goods, including platinum and palladium; and export bans covering £250 million worth of goods in sectors of the Russian economy most dependent on UK goods, including chemicals, plastics, rubber and machinery[106][107].

On July 18, 2022, the UK adopted the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 pursuant to which: (i) prohibitions on the provision (directly or indirectly) of accounting, business and management consulting and public relations services to persons connected to Russia (including Russian residents temporarily located in another country such as the UK) were introduced, (ii) prohibitions on energy-related goods and services were expanded to include the export of energy-related goods to Russia (regardless of their eventual point of use), the making available of energy-related goods to a person connected with Russia and the provision of energy-related services to all oil and gas exploration and production projects in Russia, (iii) prohibitions on the export, supply and delivery and making available of items listed on the G7 Dependencies and Further Goods List to, or for use in Russia (as well as related services) were introduced and (iv) prohibitions on the import, acquisition and supply or delivery of gold that originates in Russia on or after July 21, 2022 (as well as ancillary services) were introduced. These prohibitions came into force on July 21, 2022. The following prohibitions were also introduced to come into effect on later dates, and relate to the import, acquisition and supply or delivery of: (i) oil and oil products (enters into force on December 31, 2022), and (ii) coal and coal products (enters into force on August 10, 2022). 

In October 2022, the UK further expanded the scope of the Russia (Sanctions) (EU Exit) Regulations 2019 to include restrictions on trade in gold jewellery and processed gold, liquefied natural gas, and so-called “vulnerable goods”.[108]  The 2019 Regulations will now prohibit the import of (i) gold jewellery or processed gold from Russia into the United Kingdom (as well directly or indirectly assisting such trade, including its financing); and (ii) liquefied natural gas located from Russia into the United Kingdom (as well as directly or indirectly assisting such trade, including its financing).  The Regulations now also prohibit export of “vulnerable goods” from the United Kingdom to Russia, including assisting in or financing their export. Vulnerable goods are listed in Schedule 3I of the Regulations and include a wide range of products such as sewing machines, heavy machinery like cranes and fork-lifts, wood in various forms, small tools and electrical parts. The amendments also expand the scope of certain definitions in the 2019 Regulations, including to categories of loans which are subject to the restrictions on granting loans and credit arrangements. The amendments came into force on October 29, 2022, with the exception of the provisions relating to liquefied natural gas, which will come into force on January 1, 2023.

On November 4, 2022, the UK published a number of amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 relating to maritime trade in crude oil and oil products falling under HST Codes 2709[109] and 2710[110] and originating from Russia. [111]  The new amendments prohibit the supply or delivery by ship of these products from Russia to a third country or between third countries. The amendments also prohibit the funding or provision of brokering services, whether direct or indirect, in relation to maritime trade in these products. In addition to the oil price cap mentioned below, there are exceptions to the prohibition in circumstances where the oil being traded does not originate from Russia, is not owned by a person connected to Russia, and is only being loaded in, departing from or transiting through Russia. The Regulations will now also extend the scope of the Treasury’s power to impose severe monetary penalties for breaches of the new provisions, which start from £1,000,000 and can reach up to 50% of the value of the infringement, if higher than £1,000,000.  The Treasury will be required to provide sufficient detail to the infringing person about the grounds for imposing a penalty, the amount of the penalty, and procedure for seeking review of the Treasury’s decision.

The UK and Price Cap Coalition, which includes G7 countries and Australia, have agreed an exception to the prohibition for trade in Russian oil and oil products if sold at or below an agreed price (“the price cap”). The cap has been agreed at $60 per barrel. The price cap will be implemented in the UK by the following four general licenses which were issued by OFSI on December 5, 2022 and which take effect on the same date:

• GL INT/2022/2469656 (the “Oil Price Cap”) enables a person (meaning an individual, a body of persons corporate or unincorporate or any organization or association or combination of persons) to deliver Russian oil by ship from Russia to a third country, or from one third country to another, provided that the unit price of the oil is at or below $60 per barrel, the price cap. It also enables service providers and other institutions to facilitate such trade in oil, provided that the unit price of oil is below the price cap. The GL requires participants in the trading process to maintain detailed records concerning the price information of the oil being traded as well as the purpose of the supply or delivery. The GL is in place indefinitely, subject to amendment, variation or revocation by OFSI.

• GL INT/2022/2470256 (“Winddown”) enables persons to continue to carry out maritime trade in oil which exceeds the price cap of $60 per barrel if and only if it was loaded onto a ship at the port of loading prior to 5:01am, GMT on December 5, 2022 and it is offloaded at the port of destination prior to 5:01am, GMT, on January 19, 2023. It also enables services providers and institutions to facilitate such trade in oil, provided the strict timing conditions are met. The GL is in place indefinitely, subject to amendment, variation or revocation by OFSI.

• GL INT/2022/2470056 (“Correspondent banking and payment processing”) enables an institution to process, clear or send payments from a person in connection with trading activities which would otherwise breach the prohibition on maritime oil trade only if that institution acts as an intermediary and has no direct relationship with the person providing trade services (in other words, the person is a “non-account party”). The GL is in place indefinitely, subject to amendment, variation or revocation by OFSI.

• GL INT/2022/2470156 (“Oil Price Cap: Exempt Projects and Countries) enables persons undertaking a “specified activity”, which is defined in Schedules 1 and 2 of the GL, to carry out maritime trade in Russian oil and oil products for the duration specified in the relevant schedule. For example, the supply or delivery by ship of Russian oil originating in or consigned from the Sakhalin-2 Project in Russia to Japan is permitted between December 5, 2022 until September 29, 2023. The GL is in place indefinitely, subject to amendment, variation or revocation by OFSI.

The general maritime services ban, and its price cap exception for Russian oil, come into effect on December 5, 2022. Further guidance on these measures, as well as all forms, attestations and applications relating to the oil price cap and associated GLs, can be found here.

On 14 December 2022, the UK published several amendments to the Russia (Sanctions) (EU Exit) Regulations 2019, which, among other things, expanded the range of professional and business services that cannot be provided to persons connected to Russia. Consequently, restricted services now also include advertising, architectural, auditing, engineering and IT consultancy and design services.[112]

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[1] The asset freezes put in place mean that all funds and economic resources that are owned, held or controlled by the designated persons, and that are under UK jurisdiction, must be frozen, and that no funds or economic resources can be made available (directly or indirectly) to or for the benefit of these persons, unless permitted by a licence issued by Office of Financial Sanctions Implementation. Moreover, the funds or economic resources of an entity that is greater than 50% owned or controlled directly or indirectly by a designated person are also subject to such asset freezes and restrictions on making funds and economic resources available.

[2] Foreign, Commonwealth & Development Office, “UK hits Russian oligarchs and banks with targeted sanctions: Foreign Secretary’s statement” (Feb. 22, 2022),available at https://www.gov.uk/government/news/uk-hits-russian-oligarchs-and-banks-with-targeted-sanctions-foreign-secretary-statement.

[3] Foreign, Commonwealth & Development Office, “Foreign Secretary imposes UK’s most punishing sanctions to inflict maximum and lasting pain on Russia” (Feb. 24, 2022), available at https://www.gov.uk/government/news/foreign-secretary-imposes-uks-most-punishing-sanctions-to-inflict-maximum-and-lasting-pain-on-russia.

[4] HM Treasury Notice, Russia, 28/02/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057799/Notice_Russia_280222.pdf.

[5] HM Treasury Notice, Russia, 01/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058112/Notice_Russia__010322.pdf.

[6] HM Treasury Notice, 06/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1066934/Notice_Russia_060422.pdf

[7] HM Treasury Notice, 29/06/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1086638/Notice_Russia_290622.pdf

[8] HM Treasury Notice 19/05/2023, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1157892/Notice_Russia_190523.pdf

[9] Foreign, Commonwealth & Development Office, “Foreign Secretary imposes UK’s most punishing sanctions to inflict maximum and lasting pain on Russia” (Feb. 24, 2022), available at https://www.gov.uk/government/news/foreign-secretary-imposes-uks-most-punishing-sanctions-to-inflict-maximum-and-lasting-pain-on-russia.

[10] HM Treasury Notice, Russia, 01/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058003/Notice___Russia_010322.pdf.

[11] HM Treasury Notice 24/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1062892/Notice_Russia_240322.pdf.

[12] HM Treasury Notice 05/05/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1073490/Notice_Russia_050522.pdf

[13] HM Treasury Notice 19/05/2023, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1157892/Notice_Russia_190523.pdf

[14] On March 3, 2022, the UK announced the formation of an “Oligarch Taskforce” that will coordinate the investigation and sanctioning of Russian oligarchs. On March 4, 2022, in order to expedite the process of implementing sanctions, the UK announced amendments to the Economic Crime (Transparency and Enforcement) Bill to allow the UK to move faster in sanctioning Russian oligarchs and businesses associated with the Russian government. Specifically, the amendments remove the test for “appropriateness” from the designation process, which allows the UK to move faster when designating individuals.

[15] Foreign, Commonwealth & Development Office, “UK hits Russian oligarchs and banks with targeted sanctions: Foreign Secretary’s statement” (Feb. 22, 2022),available at https://www.gov.uk/government/news/uk-hits-russian-oligarchs-and-banks-with-targeted-sanctions-foreign-secretary-statement.

[16] HM Treasury Notice, Russia, 01/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058003/Notice___Russia_010322.pdf.

[17] HM Treasury Notice, Russia, 03/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058701/Notice_Russia_030222.pdf.

[18] HM Treasury Notice, Russia, 10/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1059928/Notice_Russia_100322.pdf.

[19] HM Treasury Notice 15/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1060784/Notice_Russia_150322.pdf.

[20] HM Treasury Notice 24/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1062892/Notice_Russia_240322.pdf.

[21] HM Treasury Notice 08/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1067418/Notice_Russia_080422.pdf

[22] HM Treasury Notice 13/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1068919/Notice_Russia_130422.pdf

[23] HM Treasury Notice 13/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1068919/Notice_Russia_130422.pdf

[24] HM Treasury Notice 14/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1069383/Notice_Russia_140422.pdf

[25] HM Treasury Notice 13/05/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1075063/Notice_Russia_130522.pdf

[26] Foreign, Commonwealth & Development Office, “UK sanctions the shady network funding Putin’s lavish lifestyle”, available at https://www.gov.uk/government/news/uk-sanctions-the-shady-network-funding-putins-lavish-lifestyle

[27] Foreign, Commonwealth & Development Office, “UK Government sanctions Vladimir Putin and Sergey Lavrov” (Feb. 25, 2022), available at https://www.gov.uk/government/news/uk-government-sanctions-vladimir-putin-and-sergey-lavrov.

[28] HM Treasury Notice 11/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1060263/Notice_Russia_110322.pdf.

[29] HM Treasury Notice 15/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1060784/Notice_Russia_150322.pdf.

[30] HM Treasury Notice 13/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1068919/Notice_Russia_130422.pdf

[31] HM Treasury Notice 13/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1068919/Notice_Russia_130422.pdf

[32] HM Treasury Notice 21/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070063/Notice_Russia_210422.pdf 

[33] HM Treasury Notice, Russia, 01/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058003/Notice___Russia_010322.pdf.

[34] HM Treasury Notice 15/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1060784/Notice_Russia_150322.pdf.

[35] HM Treasury Notice 21/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070063/Notice_Russia_210422.pdf 

[36] Foreign, Commonwealth & Development Office Press Release – “New sanctions targeting Putin’s war leaders”, available at https://www.gov.uk/government/news/new-sanctions-targeting-putins-war-leaders

[37] HM Treasury Notice 21/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070063/Notice_Russia_210422.pdf 

[38] HM Treasury Notice 04/05/2022, available at

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1073104/Notice_Russia_040522.pdf

[39] HM Treasury Notice 04/07/2022, available at

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1087942/Notice_Russia_040722.pdf

[40] “Foreign Secretary announces sanctions on Putin’s propaganda” (Mar 31, 2022), available athttps://www.gov.uk/government/news/foreign-secretary-announces-sanctions-on-putins-propaganda--2

[41] HM Treasury Notice 31/03/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1065135/Notice_Russia_310322.pdf

[42] HM Treasury Notice 04/07/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1087942/Notice_Russia_040722.pdf

[43] HM Treasury Notice 05/07/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1088189/Notice_Russia_050722.pdf

[44] HM Treasury Notice 04/05/2022, available at

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1073104/Notice_Russia_040522.pdf

[45] HM Treasury Notice 06/04/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1066934/Notice_Russia_060422.pdf

[46] HM Treasury Notice 29/06/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1086638/Notice_Russia_290622.pdf

[47] HM Treasury Notice 19/05/2023, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1157892/Notice_Russia_190523.pdf

[48] Foreign, Commonwealth & Development Office Press Release – “UK targets Russian airlines with new sanctions”, available at https://www.gov.uk/government/news/uk-targets-russian-airlines-with-new-sanctions

[49] HM Treasury Notice 19/05/2022, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1076657/Notice_Russia_190522.pdf

[50] HM Treasury Notice 19/05/2023, available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1157892/Notice_Russia_190523.pdf

[51] HM Treasury and Office of Financial Sanctions Implementation, “UK Statement on Further Economic Sanctions Targeted at the Central Bank of the Russian Federation” (Feb. 28, 2022), available at https://www.gov.uk/government/news/uk-statement-on-further-economic-sanctions-targeted-at-the-central-bank-of-the-russian-federation.

[52] HM Treasury, “UK to bring in further sanctions targeting provision of insurance” (Mar. 3, 2022), available at https://www.gov.uk/government/news/uk-to-bring-in-further-sanctions-targeting-provision-of-insurance.

[53] Department for International Trade, General Trade Licence Russia Sanctions, Aviation Insurance (Mar. 8, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1059528/general-trade-licence-russia-sanctions-aviation-insurance.pdf.

[54] Foreign, Commonwealth & Development Office, “UK strengthens ban on Russia aircraft and introduces new trade sanctions” (Mar. 9, 2022), available at  https://www.gov.uk/government/news/uk-strengthens-ban-on-russia-aircraft-and-introduces-new-trade-sanctions.

[55] Foreign, Commonwealth & Development Office, “UK imposes sweeping new sanctions to starve Putin’s war machine” (Apr. 6, 2022), available at https://www.gov.uk/government/news/uk-imposes-sweeping-new-sanctions-to-starve-putins-war-machine

[56] Foreign, Commonwealth & Development Office, “Russia cut off from UK services” (May. 4, 2022), available at https://www.gov.uk/government/news/russia-cut-off-from-uk-services

[57] Foreign, Commonwealth & Development Office, “UK sanctions Russia’s second richest man” (June 29, 2022), available at https://www.gov.uk/government/news/uk-sanctions-russias-second-richest-man

[58] Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022.

[59] Regulation 18B, Russia (Sanctions) (EU Exit) Regulations 2019 available at

https://www.legislation.gov.uk/uksi/2019/855/regulation/18B

[60] Office of Financial Sanctions Implementation, General Licence – Wind Down of Positions Involving VTB (Feb. 25, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057549/INT.2022.1272278_General_Licence___Wind_Down_of_Positions_Involving_VTB.pdf.

[61] Office of Financial Sanctions Implementation, General Licence – INT/2022/1277777 (Mar. 1, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057862/Notice_INT.2022.1277777_.pdf.

[62] Office of Financial Sanctions Implementation, General Licence – INT/2022/1277778 (Mar. 1, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057864/Notice_INT.2022.1277778_.pdf.

[63] Office of Financial Sanctions Implementation, General Licence – INT/2022/1277877 (Mar. 1, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057866/Notice_INT.2022.1277877.pdf.

[64] Office of Financial Sanctions Implementation, General Licence – INT/2022/1280976 (Mar. 1, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058125/INT20221280976_010322.pdf.

[65] Office of Financial Sanctions Implementation, General Licence – INT/2022/1280876 (Mar. 1, 2022, as amended Apr. 22, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070607/INT.2022.1280876_GL.pdf

[66] Office of Financial Sanctions Implementation, General Licence – Wind Down of Positions Involving Various Designated Banks (Mar. 4, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058765/OFSI_General_Licence_INT20221295476.pdf.

[67] Office of Financial Sanctions Implementation, General Licence – Wind Down of Positions Sberbank (Mar. 4, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1058967/Sberbank_Wind_down_General_licence.pdf.

[68] Department for International Trade, General Trade Licence Russia Sanctions, Aviation Insurance (Mar. 8, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1059528/general-trade-licence-russia-sanctions-aviation-insurance.pdf.

[69] Office of Financial Sanctions Implementation, General Licence – Provision of navigational data to civilian aircrafts for flight safety (Mar. 9, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1059822/Belarus_General_Licence_INT-2022-1322576.pdf.

[70] Office of Financial Sanctions Implementation, General Licence – INT/2022/1381276 (Mar. 22, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1062349/GENERAL_LICENCE_.pdf.

[71] Office of Financial Sanctions Implementation, General Licence – INT/2022/1424277 (Mar. 24, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1063227/GL_INT20221424277.pdf.

[72] Office of Financial Sanctions Implementation, General Licence – INT/2022/1424276 (Mar. 24, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1063223/INT20221424276_GL.pdf.

[73] Office of Financial Sanctions Implementation, General Licence – INT/2022/1424276 (as amended Apr. 21, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070502/GL_INT20221424276_notice.pdf

[74] Office of Financial Sanctions Implementation, General Licence – Continuation of Business and Basic Needs of GEFCO UK Subsidiaries - INT/2022/1438977, (now revoked), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1066363/INT.2022.1438977__Continuation_of_Business_wth_GEFCO_general_licence.pdf    

[75] Office of Financial Sanctions Implementation, General Licence – Wind Down of Positions Involving Sovcomflot - INT/2022/1469378, available at  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1075246/INT.2022.Wind_down_Sovcomflot_29.03.22.pdf

[76] Office of Financial Sanctions Implementation, General Licence – Payments by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation related to debt issued by them before 1 March 2022. - INT/2022/1495176 (Apr. 1, 2022), available at  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1065790/INT.2022.1495176.pdf.

[77] Office of Financial Sanctions Implementation – General Licence – Wind Down of Positions Involving Credit Bank of Moscow – INT/2022/1544176 (Apr. 6, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1066997/INT20221544176_gl.pdf

[78] Office of Financial Sanctions Implementation – General Licence – Gazprombank Energy Payments INT/2022/1630477 (Apr. 21, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070506/GENERAL_LICENCE_Gazprombank_21.04.22.pdf

[79] Office of Financial Sanctions Implementation – General Licence – Law Enforcement and Regulatory Authorities Asset Recovery (Apr. 27, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1071806/Asset_Recovery_GL_27.04.2022.pdf

[80] Office of Financial Sanctions Implementation – General Licence – Continuation of Business of Evraz Plc’s North American Subsidiaries – INT/2022/1710676 (May. 6, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1073553/GL_INT20221710676_Evraz.pdf

[81] Office of Financial Sanctions Implementation – General Licence – Amsterdam Trade Bank N.V – winding down, basic needs and insolvency related payments – INT/2022/1678476 (May. 13, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1074954/INT.2022.1678476_Amsterdam_Trade_Bank_N.V_-_winding_down_-_basic_needs_-_insolvency_GL.pdf

[82] Office of Financial Sanctions Implementation – General License – Russia Travel for UK nationals – INT/2022/1839676 (May. 23, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1077827/23.05.2022_Travel_General_Licence.pdf

[83] Office of Financial Sanctions Implementation – General License – Russia Designated Persons – Charities and Interim Managers and trustees – INT/2022/1834876 (May. 30, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1079599/GENERAL_LICENCE_CC_20220530_.pdf

[84] Office of Financial Sanctions Implementation – General License – Continuation of Business and Basic Needs for Telecommunication Services and News Media Services – INT/2022/1875276 (May. 30, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1079706/INT20221875276_OFSI_Telecoms_and_News_General_Licence_.pdf

[85] Office of Financial Sanctions Implementation – General License – Wind Down of Positions involving Rosbank – INT/2022/1968500 (June 30, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1087379/GL_INT20221968500_Rosbank_winddown.pdf

[86] Office of Financial Sanctions Implementation – General License – Humanitarian Activity – INT/2022/1947936 (July 7, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1089102/General_Licence_INT-2022-1947936_.pdf

[87] Office of Financial Sanctions Implementation – General License – Investments in relation to Russia – INT/2022/2002560 (July 19, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1092029/Outward_Investment_Wind_Down_GL_.pdf

[88] Office of Financial Sanctions Implementation – General License – Permitted Payments to UK Insurance Companies – INT/2022/2009156 (July 22, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1098989/General_Licence_INT-2022-2009156_Amendment_Final.pdf  

[89] Office of Financial Sanctions Implementation – General License –  Companies winding down operations in Russia – INT/2022/2055384 (August 5, 2022), available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1096670/INT-2022-2055384_Companies_winding_down_operations_in_Russia_.pdf

[90] Office of Financial Sanctions Implementation – General License – Mongolia Energy Payments – INT/2022/2085212 (August 15, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1098300/INT.2022.2085212_Mongolia_Energy_Payments_GL.pdf

[91] Office of Financial Sanctions Implementation – General License – Bank Fees – INT/2022/2104808 (August 22, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1099576/General-Licence-2104808.pdf  

[92] Office of Financial Sanctions Implementation – General License – Crown Servants, Contractors & their Family Members – INT/2022/1845976 (August 19, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1099510/General_Licence_INT-2022-1845976.pdf.

[93] Office of Financial Sanctions Implementation – General License – London Court of International Arbitration (LCIA) Arbitration Costs – INT/2022/1552576 (October 17, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1111562/17102022_INT-2022-1552576_LCIA_Fees_GL__FINAL_VERSION_.pdf.

[94] Office of Financial Sanctions Implementation – General License – Legal Services – INT/2022/2252300 (October 28, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1114563/General_Licence_INT20222252300.pdf

[95] Office of Financial Sanctions Implementation – General License – Loans and Securities Amendment – INT/2022/2307324 (October 29, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1114563/General_Licence_INT20222252300.pdf

[96] Office of Financial Sanctions Implementation – General License – Securing Energy for Europe - INT/2022/ 2305324 (October 29, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1114576/General_Licence_INT20222305324.pdf 

[97] Office of Financial Sanctions Implementation – General License – Truphone telecoms services – INT/2022/ 2339452

 (November 2, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1116875/Truphone_licence_INT.2022.2339452_amended_10.11.22.pdf

[98] Office of Financial Sanctions Implementation – General License – Transactions related to agricultural commodities including the provision of insurance and other services  – INT/2022/ 2339452

 (November 2, 2022), available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1116875/Truphone_licence_INT.2022.2339452_amended_10.11.22.pdf

[99] Office of Financial Sanctions Implementation – General License – Trade 5 – Financial Prohibitions – 7 Day Winddown  – INT/2022/2448692 (December 15, 2022), available at

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1124800/OFFSEN_09.12.2022_GL__Trade_5_SI_-_Financial_Prohibitions_.pdf

[100] Department for International Trade Notice NTE 2022/03: License Suspensions and OGELs Revised (Feb. 28, 2022), available at https://www.gov.uk/government/publications/notice-to-exporters-202203-licence-suspensions-and-ogels-revised/nte-202203-licence-suspensions-and-ogels-revised.

[101] Statement by Mr. Ranil Jayawardena, the Parliamentary Under-Secretary of State for International Trade (Feb. 28, 2022), available at https://hansard.parliament.uk/Commons/2022-02-28/debates/2202289000005/RussiaSanctions?highlight=russia#contribution-57284ED8-FCCD-44E6-8B7D-8F5F6C8A6F19.

[102] Department for Business, Energy & Industrial Strategy, “UK to phase out Russian Oil Imports” (Mar. 8, 2022), available at https://www.gov.uk/government/news/uk-to-phase-out-russian-oil-imports.

[103] Department of International Trade, “UK announces new economic sanctions against Russia” (Mar. 15, 2022), available at https://www.gov.uk/government/news/uk-announces-new-economic-sanctions-against-russia.

[104] Foreign, Commonwealth & Development Office, “UK imposes sweeping new sanctions to starve Putin’s war machine” (Apr. 6, 2022), available at https://www.gov.uk/government/news/uk-imposes-sweeping-new-sanctions-to-starve-putins-war-machine

[105] Available at https://www.legislation.gov.uk/uksi/2022/452/made

[106] Guidance – Additional duties on goods originating in Russia and Belarus, available at https://www.gov.uk/guidance/additional-duties-on-goods-originating-in-russia-and-belarus?utm_medium=email&utm_campaign=govuk-notifications-topic&utm_source=dd11cd07-e9fd-4505-abf5-083f9f6a2c98&utm_content=daily

[107] Department of International Trade, “UK punishes Putin with new round of sanctions on £1.7 billion of goods” (May 8, 2022), available at https://www.gov.uk/government/news/uk-punishes-putin-with-new-round-of-sanctions-on-17-billion-of-goods

[108] Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022.

[109] Petroleum Oils And Oils From Bituminous Minerals, Crude.

[110] HTS Code 2710: Petroleum oils and oils obtained from bituminous minerals (excluding crude); preparations containing >= 70% by weight of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations, n.e.s.; waste oils containing mainly petroleum or bituminous minerals

[111] Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022.

[112] Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022.