Sanctions Developments Resulting From the Conflict in Ukraine - United Kingdom

May 17, 2022

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Table of Contents:


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]

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; and Andrey Akimov (the CEO of Gazprombank), subject to an asset freeze imposed on April 6, 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.[7] On March 1, 2022, the UK imposed asset freezes on two Belarusian defence companies (JSC 558 Aircraft Repair Plant and JSC Integral).[8] 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)[9]. 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)[10].

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”.[11] These include (amongst others): Gennady Timchenko, Igor Rotenberg and Boris Rotenberg (subject to asset freezes imposed February 22, 2022)[12]; Denis Bortnikov, Petr Fradkov, Elena Georgieva, Kirill Shamalov and Yury Slyusar (subject to asset freezes imposed February 24, 2022)[13]; Igor Ivanovich Shuvalov and Alisher Burkhanovich Usmanov (subject to asset freezes and travel bans imposed March 3, 2022)[14]; 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)[15]; Andrey Melnichenko (founder of the EuroChem Group)(subject to an asset freeze and travel ban imposed on March 15, 2022)[16]; Oleg Aksyutin (the Deputy Chairman of the Management Board of Gazprom PJSC), Didier Casimiro (the First Vice President of Rosneft), 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)[17]; 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)[18]; Nigina Zairova (Executive Assistant to Mikhail Fridman)(subject to an asset freeze imposed on April 13, 2022)[19]; 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)[20]; Eugene Tenebaum and David Davidovich (two longstanding business associates of Roman Abramovich)(subject to asset freezes imposed on April 14, 2022)[21]; 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)[22][23].
  • 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)[24]; 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)[25]; 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)[26]; 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)[27]; 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)[28]; and 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)[29].
  • 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)[30]; Sergei Shoigu (Russian Defence Minister) (subject to an asset freeze and travel ban imposed on March 15, 2022)[31]; Mikhail Mizintsev (Russian Colonel-General) (subject to an asset freeze and travel ban imposed 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)[32][33]. 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)[34].
  • 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), and 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)[35]. In addition, the UK has also imposed asset freezes and travel bans on a number of individual media figures and “propagandists”.[36] 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)[37]; 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 May 4, 2022)[38].
  • The UK has also imposed asset freezes on a number of individuals involved in the energy, resources, 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), and 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.[39]

Financial and Economic Restrictions

Following an announcement on February 28, 2022 that the UK would adopt such measures,[40] 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.[41]  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).[42]

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.[43]  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.[44]

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.[45]

General Licenses

On February 25, 2022, the Office of Financial Sanctions Implementation published a GL concerning the wind down of positions involving VTB Bank.[46]  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,”[47] authorizes 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,”[48] authorizes 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,”[49] 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,”[50] allows 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 ffrom April 22, 2022, and expires on April 3, 2023.[51]

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.[52]  The GL took effect on March 4, 2022 and expires 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.[53]  The GL authorities 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 expires 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” 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).[54]

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.[55]  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.

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.[56]  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.

On March 24, 2022, the Office of Financial Sanctions Implementation issued two additional GLs.  The first, which took effect on March 24, 2022 and expires on April 23, 2022, provides a 30-day period to wind down positions involving Bank Dabrabyt Joint Stock Company.[57]  The second, which took effect on March 24, 2022 and expires on April 23, 2022, provides a 30-day period to wind down positions involving Alfa Bank JSC, Gazprombank, Rosselkhozbank, SMP Bank and Ural Bank for Reconstruction and Development.[58] 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.[59]

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.[60] 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.[61]  This GL took effect on March 29, 2022. The original expiry date of this GL has been amended and the GL now expires 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.[62]  This GL took effect on April 1, 2022 and expires 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.[63] This GL took effect on April 6, 2022 and expires 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.[64] 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 expires on May 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.[65]

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.[66] Under this licence, 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 expires on September 2, 2022.

On May 13, 2022 the Office of Financial Sanctions Implementation issued a GL[67] 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.

Trade Restrictions

On February 28, 2022, the UK removed Russia as a permitted destination from numerous open general export licences (“OGELs”),[68] and suspended the approval of new export licences for dual-use items to Russia with immediate effect.[69]

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.[70]

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).[71]  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.[72]

On April 14, 2022, the UK Parliament adopted the Russia (Sanctions) (EU Exit)(Amendment)(No.8) Regulations 2022 [73] 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 4, 2022, it was announced that a ban on services exports to Russia will come into force which will cut Russia off from doing business with UK sectors which are critical to the Russia economy. The new measures will stop Russian businesses from benefitting from the UK’s accountancy, management consultancy, and PR services.[74]

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[75][76].


[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] 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.

[8] 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.

[9] 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.

[10] 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

[11] 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.

[12] 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.

[13] 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.

[14] 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.

[15] 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.

[16] 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.

[17] 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.

[18] 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

[19] 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

[20] 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

[21] 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

[22] 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

[23] 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

[24] 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.

[25] 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.

[26] 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.

[27] 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

[28] 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

[29] 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

[30] 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.

[31] 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.

[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] 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

[34] 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

[35] 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

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

[37] 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

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

[40] 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.

[41] 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.

[42] 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.

[43] 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.

[44] 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

[45] 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

[46] 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.

[47] 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.

[48] 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.

[49] 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.

[50] 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.

[51] 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

[52] 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.

[53] 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.

[54] 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.

[55] 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.

[56] 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.

[57] 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.

[58] 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.

[59] 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

[60] 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

[61] 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

[62] 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.

[63] 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

[64] 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

[65] 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

[66] 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

[67] 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

[68] 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.

[69] 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.

[70] 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.

[71] 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.

[72] 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

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

[74] 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

[75] 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

[76] 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