On 22 February 2022, the United Kingdom announced the designation of five Russian financial institutions and three individuals following the Russian Government’s recognition of Donetsk and Luhansk in Ukraine as independent entities.
The UK’s consolidated list of persons and organisations (the UK Sanctions List) that are subject to financial sanctions has now been updated to include the following:
- Designated persons: Gennadiy Nikolayevich Timchenko, Boris Romanovich Rotenberg, and Igor Arkadyevich Rotenberg
- Designated organisations: Bank Rossiya; Black Sea Bank for Development and Reconstruction; Joint Stock Company Genbank; IS Bank; and Public Joint Stock Company Promsvyazbank
The recent designation of the persons and organisations referred to above will be relevant to Anguilla, the British Virgin Islands and the Cayman Islands, as all of these territories are Overseas Territories of the UK (the UK OTs), and the UK sanctions legislation applies directly in the UK OTs. Bermuda implements its own domestic sanctions legislation that follows the UK legislation.
Regulated persons and persons in the wider financial services sector in the UK OTs should review their books of business to check whether any of the persons and/or organisations referenced above are clients or applicants for business. If, based on the checks conducted, it is revealed that one or a combination of more than one of the persons and/or organisations are clients, UK OTs should take the necessary steps to comply with the applicable sanctions framework as implemented in each UK OT respectively.
Should you need any help, please do reach out to your usual Harneys contact.