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Update to UK Sanctions on Russia-Ukraine-Belarus (up to 9 August 2022)

09 Aug 2022

Further to our blog post on UK Russia sanctions, please find below an updated table of sanctions.

  • 18 February 2022: Amending entries relating to the following individuals who are still subject to asset freeze: Oleksandr Viktorovych Yanukovych (Group ID: 12896), Petr Grigorievich Jarosh (Group ID: 12968) and Andrii Shypitsyn (Group ID: 13781)
  • 22 February 2022: Addition of asset freezes on five Russian banks: Bank Rossiya (Group ID: 14177), IS Bank (Group ID: 14178), JSC GenBank (Group ID:14180), PJSC Promsvyazbank (Group ID:14180) and Black Seal Bank for Development and Construction. Addition of asset freezes on three prominent individuals: Gennady Nikolayevich Timchenko (Group ID 14181), Boris Romanovich Rotenberg (Group ID 14182) and Igor Arkadyevich Rotenberg (Group ID 14183)
  • 23 February 2022: Amendments to the following designated persons who remain subject to asset freezing: Bank Rossiya and Black Sea Bank for Development and Construction
  • 24 February 2022: Amendment of the following entries on the consolidated list: United Aircraft Corporation (Group ID: 13121), Uralvagonzavod (Group ID 13122) and VTB Bank (Group ID 13080)
  • 25 February 2022: Addition of Vladimir Putin and Sergei Lavrov as designated persons and imposition of asset freezes on them, see here
  • 28 February 2022: Addition of the following designated persons to the consolidated list and the imposition of asset freezes on them VEB.RF (Group ID 14198), Bank Otkritie Financial Corporation PJSC (Group ID:14199) and PJSC Sovocombank (Group ID 141200)
  • 1 March 2022: PJSC Sberbank is made subject to additional restrictive measures on clearing in Sterling. In addition Andrei Burdyko, Victor Vladimirovich Gulevich, Sergei Simonenko, Andrey Zhuk, JSC 558 Aircraft Repair Plant and JSC Integral are all added to the asset freeze list
  • 3 March 2022: Addition of Alisher Usmanov and Igor Shuvalov to the asset freeze and travel ban list
  • 10 March 2022: Addition of Andrei Leonidovich KOSTIN, Alexei Borisovich MILLER, Oleg Vladimirovich DERIPASKA, Roman Arkadyevich ABRAMOVICH, Nikolai Petrovich TOKAREV, Dmitri Alekseevich LEBEDEV, Igor Ivanovich SECHIN, to the asset freeze and travel ban list
  • 11 March 2022: 386 individuals have been added to the consolidated list and are subject to an asset freeze. See here for the names of the individuals.
  • 15 March 2022: 350 individuals have been added to the consolidated list and are subject to an asset freeze. See here for the names of the individuals.
  • 15 March 2022: Addition of Armen Sumbatovich GASPARYAN, Suleyman Abusaidovich KERIMOV, Tigray Organesovich KHUDAVERDYAN, Dmitry Yevgenevich KULIKOV, Alexey Viktorovich KUZMICHEV, Alexander Alexandrovich MIKHEEV, Vladimir Valerievich RASHEVSKY, Viktor Filippovich RASHNIKOV, Andrey Valerievich RYUMIN, Marina Vladimirovna SECHINA, Artyom Grigoryevich SHEYNIN, Alexander Nikolayevich SHOKHIN, ROSNEFT AERO, JSC ZELENODOLSK SHIPYARD to the asset freeze list.
  • 18 March 2022: Amended entries to the consolidated list and are still subject to an asset freeze are: FRIDMAN Mikhail Maratovic, AVEN Petr Olegovich, KHAN German Borisovich, TATARCHENKO Denis Sergeyevich, NEZHDANOVA Yevgeniya Vitalyevna, IGNATOVA Ekaterina Sergeevna, SHUVALOVA Maria Igorevna, KOLOKOLTSEV Vladimir, PUCHKOV Andrey Sergeevich, SHCHEGOLEV Igor Olegovich,ENBERG Liliya Arkadyevna, ROTENBERG Roman Borisovich, SHUVALOV Evgeny Igorevich, PRIGOZHIN Pavel Evgenyevich, KRANS Maksim Iosifovich, SOLOVYOV Yuri Alekseyevich, ROTENBERG Pavel Arkedyevich, RASHNIKOV Viktor Filippovich, KRAVCHENKO Vladimir Kasimirovich, LOBACH Tatyana, KIRIYENKO Vladimir Sergeevich, ULYUTINA Galina, VOLFOVICH Aleksandr Grigorievich, BOLOTOVA Maiya Nikolaevna
  • 24 March 2022: Belarus - Addition to the asset freeze list of BANK DABRABYT JOINT STOCK COMPANY, CJSC BELBIZNESLIZING, INDUSTRIAL-COMMERCIAL PRIVATE UNITARY ENTERPRISE MINOTOR-SERVICE, JSC TRANSVIAEXPORT AIRLINES, LIMITED LIABILITY COMPANY BELINVEST-ENGINEERING, OJSC KB RADAR-MANAGING COMPANY HOLDING RADAR SYSTEM.
  • 24 March 2022: 33 individuals and 26 entities have been added to the consolidated list and are subject to an asset freeze. See here for the names of the individuals.
  • 24 March 2022: Wind down of positions involving the designated Banks, Alfa Bank JSC, GazPromBank, Rosselkhozbank, SMP Bank, Ural Bank for Reconstruction and Development and Subsidiaries of the designated persons
  • 24 March 2022: Wind down of positions involving Bank Dabrabyt Joint Stock Company or its subsidiaries
  • 25 March 2022: The designated entity is Russian Railways. The Joint Venture is GEFCO, a Joint Venture owned by Russian Railways and Stellantis, GEFCO S.A Rue Jean Jaures, 20-22, 92800 Puteaux, France. A Subsidiary is any entity owned or controlled by the designated entity, including GEFCO UK Ltd, GEFCO Forwarding UK, Auto XP Limited and XP Tech Limited. NOTE: This was revoked on 12 April 2022
  • 25 March 2022: SOVCOMFLOT has been amended and is still under the asset freeze list and Oleg Yurievich TINKOV and Eugene Markovich SHVIDLER have also been corrected
  • 29 March 2022: The designated entity is Sovcomflot. This licence allows a person (other than the designated entity or a subsidiary) to wind down any transactions to which it is party involving the designated entity or a subsidiary including the closing out of any positions.
  • 31 March 2022: 14 entries have been added to the consolidated list and are now subject to an asset freeze.
    • The 12 designated individuals are: ANISIMOV Anton Sergeevich, ARESHEV Andrey Grigoryevich, BESPALOV Anton Sergeyevich, BRILEV Sergey Borisovich, BUBNOVA Irina Sergeyevna, MAKSIMENKO Vladimir Ilich, MIZINTSEV Mikhail Yevgenyevich, NIKOLOV Alexey Lvovich, SAENKO Sergei Ivanovich, SKOROKHODOVA Natalya Petrovna, ZAMLELOVA Svetlana Georgiyevna, ZHAROV Aleksandr Aleksandrovich.
    • The two designated entities are: ROSSIYA SEGODNYA and TV-NOVOSTI
  • 31 March 2022: The following entries have been added to the consolidated list and are now subject to an asset freeze; PHOTON PRO LLP, MAJORY LLP, DJECO GROUP LP
  • 4 April 2022: Amended entry to the consolidated list is Andrey Anatolyevich TURCHAK and is still subject to an asset freeze
  • 5 April 2022: Amended entry to the consolidated list is Wagner Group and is still subject to an asset freeze
  • 6 April 2022: 10 entries have been added to the consolidated list and are now subject to an asset freeze.
    • The 8 individuals are: IVANOV Sergei Sergeivich, ROTENBERG Boris Borisovich, AKIMOV Andrey Igorevich, DYUKOV Alexander Valeryevich, KOGOGIN Sergey Anatolyevich, GURYEV Andrey Grigoryevich, MIKHELSON, Leonid Viktorovich, KANTOR, Viatcheslav
    • The two designated entities are: CREDIT BANK OF MOSCOW and PJSC SBERBANK (PUBLIC JOINT-STOCK COMPANY SBERBANK)
  • 8 April 2022: Three entries have been added to the consolidated list and are now subject to an asset freeze: Katerina Vladimirovna Tikhonova, Maria Vladimirovna Vorontsova, Yekaterina Sergeyevna Vinokurova Further, the following entry has been amended under the Russia financial sanctions regime and remains subject to an asset freeze: Evgeny Alekseevich Fedorov
  • 11 April 2022: The following entries have been amended and are still subject to an asset freeze: Evgeny Alekseevich FEDOROV, Tigran Organesovich KHUDAVERDYAN, Katerina Vladimirovna TIKHONOVA
  • 13 April 2022: 206 entries have been added to the Consolidated List and are now subject to an asset freeze. Further details can be found in the annex of the Notice, here
  • 13 April 2022: 9 individuals have been corrected to the consolidated list and are still subject to an asset freeze: AZARENOK Grigoriy Yurievich, EISMONT Natalia Nikolayevna, IPATAU Vadzim Dzmitryevich, HUSTYR Yulia Chaslavauna, KALINOUSKY Siarhei Aliakseevich, KASYANCHYK Alina Sergeevna, LUKASHENKO Viktor Aliaksandravich, SAKALOUSKI Ivan Yurievich, YARMOSHINA Lidzia Mihailauna
  • 14 April 2022: The following individuals have been added to the consolidated list and are now subject to an asset freeze: Eugene Tenenbaum, David Davidovich
  • 21 April 2022: 26 entries have been added to the consolidated list and are now subject to an asset freeze. 30 entries have been amended and are still subject to an asset freeze. Further details can be found in the annex to the Notice, here
  • 26 April 2022: 195 entries have been amended and two entries corrected under the Russia financial sanctions regime and remain subject to an asset freeze. Further details can be found in the annex of the Notice, here
  • 4 May 2022: 63 entries have been added to the consolidated list and are now subject to an asset freeze. Also, Rossiya SEGODNYA and TV-NOVOSTI have been amended and are still subject to an asset freeze. Further details can be found in the annex of the Notice, here
  • 5 May 2022: One entry has been added to the consolidated list and is now subject to an asset freeze and this is: EVRAZ PLC
  • 9 May 2022: 88 entries have been amended on the consolidated list and still subject to an asset freeze. Further details can be found in the annex to the Notice, here
  • 13 May 2022: 12 entries have been added to the consolidated list and are now subject to an asset freeze and 10 entries have been corrected on the consolidated list and are still subject to an asset freeze. Further details can be found in the annex to the Notice, here
  • 19 May 2022: 3 entries have been added to the consolidated list and are now subject to an asset freeze and there are: JSC Rossiya Airlines, JSC Ural Airlines, PJSC Aeroflot
  • 24 May 2022: 63 entries have been amended and are still subject to an asset freeze. Further details can be found in the annex to the Notice, here
  • 27 May 2022: 6 entries have been amended under the Belarusian regime and are still subject to an asset freeze. Further details can be found in the annex to the Notice, here
  • 27 May 2022: 299 entries have been amended under the Russia regime and are still subject to an asset freeze. Further details can be found in the annex to the Notice, here
  • 14 June 2022: 39 entries have been amended and are still subject to an asset freeze. Further information can be found in the annex to the Notice, here
  • 16 June 2022: 12 entries have been added to the consolidated list and are now subject to an asset freeze. Further information can be found in the annex to the Notice, here
  • 24 June 2022: 58 entries have been amended and 1 entry corrected and remain subject to an asset freeze. Further information can be found in the annex to the Notice, here
  • 29 June 2022: 13 entries have been added and are now subject to an asset freeze. 1 entry has also been corrected under and remains subject to an asset freeze. Further information can be found in the annex to the Notice, here
  • 4 July 2022: The following entries have been added to the consolidated list and are now subject to an asset freeze: Aleyona Anatolyevna Chuguleva, Yuriy Sergeyevich Fedin, Darya Aleksandrovna Dugina, Yevgeniy Eduardovich Glotov, Aelita Leonidovna Mamakova, Mikhail Anatolyevich Sinelin, United World International. Furthermore, 45 entries have been amended and 1 entry corrected under the Russia regime. Further information can be found in the annex to the Notice, here
  • 5 July 2022: The following entries have been added to the consolidated list and are now subject to an asset freeze: Denis Yakovlevich GAFNER and Valeriya KALABAYEVA. The following entries have been removed from the consolidated list and are no longer subject to an asset freeze: Yakov Vladimirovich REZANTSEV and Galina ULYUTINA. The following entries have been amended and are still subject to an asset freeze: Aleksandra Aleksandrovna KAMYSHANOVA, Yevgeniya Vitalyevna NEZHDANOVA and Valeriy Ivanovich POGREBENKOV. Further information can be found in the annex to the Notice here
  • 7 July 2022: The following entity has been amended under the Belarus regime and remains subject to an asset freeze: LLC Synesis
  • 12 July 2022: 16 entries have been amended and 2 entries corrected under the Russia financial sanctions regime and remain subject to an asset freeze. Further information can be found in the annex to this Notice, here
  • 12 July 2022: 6 entries have been amended under the Belarus financial sanctions regime and remain subject to an asset freeze. Further information can be found in the annex to this Notice, here
  • 15 July 2022: The following entries have been removed from the consolidated list and are no longer subject to an asset freeze: Didier Casimiro and Zeljko Runje The following entries have been amended under the Russia regime and remain subject to an asset freeze: Sergei Ivanovich Saenko, Vladimir Leonidovich Sivkovich, Oleg Anatolyevich Voloshyn and Alrosa
  • 20 July 2022: The following entries have been amended under the Russia regime and remain subject to an asset freeze: Irina Sergeyevna Bubnova, Sergei Sergeivich Ivanov, Natalya Petrovna Skorokhodova, Djeco Group LP, Majory LLP and Photon Pro LLP
  • 26 July 2022: 42 entries have been added to the consolidated list and are now subject to an asset freeze. Further information can be found in the annex to this Notice, here. Also, Vadim Anatolyevich LUKASHEVICH has been corrected on the consolidated list and remains subject to an asset freeze
  • 2 August 2022: The following entries have been added to the Russia regime and are now subject to an asset freeze: Didier Casimiro and Zeljko Runje. Also the following entry has been removed under the Russia regime and is no longer subject to an asset freeze: Olga Ayziman. 18 entries have been amended and are still subject to an asset freeze. Further information can be found in the annex to this Notice, here
  • 9 August 2022: 27 entries have been amended under the Russia financial sanctions regime and remain subject to an asset freeze. Further information can be found in the annex to this Notice, here

ITM
Name of Instrument
Date published
Amends or implements?
Comes into force
Summary of key provisions

1

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022

10 February 2022

Amends the Russia (Sanctions) (EU Exit) Regulations 2019
(2019 UK-Russia Regulations)

10 February 2022

The amendments broaden the categories of people and entities which are capable of being designated under the sanctions regime in the 2019 Regulations.

No new designations have actually occurred and the motivation for the amendments is of course the current threat of invasion by Russia into Ukraine’s sovereign territory.

See further our blog post here.

2

Financial Sanctions Notice

22 February 2022

Implemented under the 2019 UK-Russia Regulations

22 February 2022

The following are added to the UK consolidated list and are subject to an asset freeze:

  • Gennadiy Timchenko
  • Boris Romanovich Rotenberg
  • Igor Arkadyevich Rotenberg
  • Bank Rossiya
  • Black Sea Bank for Development and Reconstruction
  • JSC Genbank
  • IS Bank
  • PJSC Promsvyazbank

As a result, UK and BOTs individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the Russian banks and individuals. Additionally, the designated individuals are banned from entering the UK.

3

Financial Sanctions Notice

24 February 2022

Implemented under the 2019 UK-Russia Regulations

24 February 2022

The following are added to the UK consolidated list and are subject to an asset freeze:

  • Kirill Shamalov
  • Petr Fradkov
  • Denis Bortnikov
  • Yury Slyusar
  • Elena Aleksandrovna Georgieva
  • Rostec
  • Uralvagonzavod
  • Tactile Missile Corporation
  • United Aircraft Corporation
  • United Shipbuilding Corporation

As a result, UK and BOT individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the Russian banks and individuals. Additionally, the designated individuals are banned from entering the UK.

4

Financial Sanctions Notice (2)

24 February 2022

Implemented under the 2019 UK-Russia Regulations

24 February 2022

Additionally makes the following entities, which were subject to sectoral sanctions, additionally subject to asset freeze:

  • VTB Bank (but subject to a General Licence (GL) for wind down)
  • Uralvagonzavod
  • United Aircraft Corporation

5

UK Government Announcement

24 February 2022

[To be implemented via amendments to 2019 UK-Russia Regulations]

Ongoing

The following further sanctions and measures announced by the UK Government include:

  • New legislation will ensure that all major Russian banks will have their assets frozen and will be excluded from the UK financial system. This will stop them from accessing sterling and clearing payments through the UK. This included imposing a full and immediate asset freeze on VTB bank
  • Legislation will be imposed early next week to stop major Russian companies and the state from raising finance or borrowing money on UK markets
  • 100 new individuals or entities will be added to the UK’s Sanctions List
  • Aeroflot will be banned from landing in the UK
  • All dual use export licences to cover components which can be used for military purposes have been suspended with immediate effect
  • The UK will stop exports of high-tech items and oil refinery equipment in the next few days
  • There will be a limit of £50,000 on deposits Russians can make into a UK bank account
  • Removing Russia out of the SWIFT international payment system, which has been supported by the European Union and the US

Similar financial sanctions will be extended to Belarus for its role in the assault on Ukraine.

6

Financial Sanctions Notice

25 February 2022

Implemented under 2019 UK-Russia Regulations

25 February 2022

The following are added to the consolidated list and are now subject to an asset freeze:

  • Vladimir Putin
  • Sergei Lavrov

As a result, UK and BOT individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the Russian banks and individuals. Additionally, the designated individuals are banned from entering the UK.

7

General Licence INT/2022/1272278 (VTB)

25 February 2022

Issued under Regulation 64 of 2019 UK-Russia Regulations

Takes effect from 25 February 2022

Expires on 27 March 2022

Importantly, on 25 February 2022, the UK’s office of Financial Sanctions Implementation announced the publication of a new Russia-related general licence allowing for a 30 day wind down of positions involving VTB Bank.

General licence INT/2022/1272278 provides that any person may wind down any transaction to which it is a party which involve VTB Bank or VTB Capital plc (and any entity owned or controlled by VTB Capital plc incorporated in the UK) , including the closing out of any positions.

The GL does not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting will result in funds or economic resources being dealt with or made available in breach of the 2019 UK-Russia Regulations, save for the specific permission mentioned above.

The GL will expire on 27 March 2022.

8

Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022

28 February 2022

Amends the 2019 UK-Russia Regulations

1 March 2022

Existing restrictions on dealing with certain financial instruments and providing loans and credit are amended to extend the sanctions prohibitions to a broader range of transferable securities and money market instruments and loans and credit.

Further restrictions on correspondence banking relationships and processing of sterling payments are also introduced.

Introduction of power for the Secretary of State to designate persons for the purpose of that provision.

The regulations provide for exceptions to, and for licensing powers in relation to, those prohibitions. In particular, there is provision to make clear that a licence may authorise acts which would otherwise be prohibited by any of the regulations for a particular period beginning with the coming into force of the prohibition, or the date of any designation made for the purposes of those provisions. This would allow a period for persons affected to arrange their affairs to comply.

9

Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2022

28 February 2022

Amends the 2019 UK-Russia Regulations

1 March 2022

These regulations provide for significantly enhanced trade sanctions measures in relation to Russia:

  • Prohibitions on the export, supply and delivery and making available of military goods are extended to include dual use goods and “critical industry” goods
  • Prohibitions on the making available and transfer of military technology are extended to include dual use technology and critical industry technology
  • Related prohibitions on the provision of technical assistance, financial services, funds and brokering services are also extended in relation to dual use goods and technology and critical industry goods and technology

A number of exceptions from the trade prohibitions on critical-industry goods and technology are provided for as well as licensing arrangements.

10

UK Statement on Further Economic Sanctions Targeted at the Central Bank of the Russian Federation

28 February 2022

[To be implemented via amendments to 2019 UK-Russia Regulations]

On-going

Additional measures were announced on 28 February 2022 which will introduce a prohibition on UK persons undertaking financial transactions involving the Central Bank of Russia, the Russian National Wealth Fund and the Ministry of Finance of the Russian Federation and the UK Government announced that it will immediately take all necessary steps to bring into effect restrictions.

Other points to note include:

  • Restrictions on Russian financial institutions – VTB Bank was designated by the UK last week, along with five other Russian banks and it is not yet known what additional financial institutions may be subjected to restrictions
  • Restrictions to prevent Russian companies from issuing transferable securities and money market instruments in the UK, in addition to the restrictions on the Russian state raising sovereign debt
  • Powers to prevent designated banks from accessing Sterling and clearing payments through the UK

Additional trade restrictions, including a prohibition on the export of certain high-end critical technical equipment and components in sectors including electronics, telecommunications and aerospace. The announcement reiterated that trade restrictions applicable to Crimea will be extended to apply to Donetsk and Luhansk.

11

Financial Sanctions Notice

28 February 2022

Implemented under 2019 UK-Russia Regulations

28 February 2022

The following persons have been added to the UK asset freeze list:

  • VEB.RF
  • Bank Otkritie Financial Corporation PJSC
  • PJSC Sovcombank

As a result, UK and BOT individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the Russian banks and individuals.

12

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4)

Regulations 2022

1 March 2022

Amends 2019 UK-Russia Regulations

1 March 2022

The Regulations prohibit Russian ships, and other ships specified by the Secretary of State, from entering ports in the UK There is a notification and publicity requirement where the specification power is used. The Regulations provide the Secretary of State with a power to control the movement of Russian ships or specified ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are.

The Regulations also confer powers on the Secretary of State and harbour authorities to detain Russian ships or specified ships at ports or anchorages. The registration of ships on the UK Ship Register is prohibited where they are owned, controlled, chartered or operated by a designated person or persons connected with Russia, or where they are a specified ship.

13

Financial Sanctions Notice

1 March 2022

Implemented under 2019 UK-Russia Regulations

1 March 2022

The following entity is subject to enhanced restrictive measures:

  • PJSC Sberbank

Whilst not subject to an asset freeze, it is subject to a prohibition on correspondent banking and sterling clearing.

14

Financial Sanctions Notice

1 March 2022

Implemented under 2019 UK-Russia Regulations

1 March 2022

The following persons have been added to the UK asset freeze list:

  • Andrei Burdyko
  • Victor Vladimirovich Gulevich
  • Sergei Simonenko
  • Andrey Zhuk
  • JSC 558 Aircraft Repair Plant
  • JSC Integral

As a result, UK and BOT individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the Russian banks and individuals. Additionally, the designated individuals are banned from entering the UK.

15

The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022

1 March 2022

Amends 2019 UK-Russia Regulations

1 March 2022

Prohibits the provision of financial services for the purpose of foreign exchange reserve and asset management to:

  • The Central Bank of the Russian Federation
  • The National Wealth Fund of the Russian Federation
  • The Ministry of Finance of the Russian Federation
  • An entity owned or controlled by, or acting on behalf/at the direction of, the above 3 entities

16

Russia: Regulatory Authorities – Prudential Supervision or Financial Stability (Notice)

General License INT/2022/1280976

1 March 2022

This licence is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019

1 March 2022

The licence pertains to VTB Capital plc and any entity owned or controlled by VTB Capital plc incorporated in the United Kingdom.

The licence relates to prudential supervision or protecting, maintaining or enhancing the stability of the financial system of the United Kingdom.

The licence takes effect from 1 March 2022 and expires on 1 March 2023.

17

Russian Banks – UK subsidiaries – Basic needs, routine holding and maintenance and the payment of legal fees” (Notice)

General License INT/2022/1280876

1 March 2022

This licence is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019

1 March 2022

The licence pertains to VTB Capital plc and any entity owned or controlled by VTB Capital plc incorporated in the United Kingdom.

The licence allows for the basic needs of UK subsidiaries and routine holding and maintenance o UK subsidiaries frozen funds or economic resources and the payment of legal fees.

Notifications requirements will need to be complied with.

Record keeping requirements will also need to be complied with.

The licence took effect from 1 March 2022 and expires on 1 March 2023.

18

Financial Sanctions Notice

3 March 2022

Implemented under 2019 UK-Russia Regulations

3 March 2022

The following persons have been added to the asset freeze and travel ban list:

  • Alisher Usmanov
  • Igor Shuvalov

19

Wind Down of Positions Involving Various Designated Banks

General License INT/2022/1295476

4 March 2022

This licence is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019

4 March 2022

The designated persons under the licence are:

  • Bank Otkritie
  • Promsvyazbank
  • Bank Rossiya
  • Sovcombank
  • Vnesheconombank (Veb)

Subsidiaries (entities owned or controlled) of any of the above are also within scope of the licence.

The licence allows persons to wind down any transactions to which the person is a party involving any of the designated persons (including JSCB Novikombank) and their subsidiaries.

The licence takes effect from 4 March and expires on 3 April 2022.

20

GENERAL LICENCE – Wind Down of Positions Sberbank

General License INT/2022/1298776

4 March 2022

This licence is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019

4 March 2022

The designated person under the licence is PJSC Sberbank, including any subsidiary (an entity owned or controlled by PJSC Sberbank).

The licence allows that a person may provide financial services to Sberbank for the purposes of winding down that activity.

The licence takes effect from 4 March and expires on 3 April 2022.

21

Financial Sanctions Notice

4 March 2022

Implemented under 2019 UK-Russia Regulations

4 March 2022

The notice is to issue a correction to an entry on the consolidated list brining the entry into line with the UK sanctions list.

Igor Ivanovich Shuvalov (Group ID: 14209) is still subject to an asset freeze.

22

Updated Russia Guidance

4 March 2022

Guidance for the financial and investment restrictions in Russia (Sanctions) (EU Exit) Regulations 2019

4 March 2022

The Office of Financial Sanctions is the competent authority responsible for improving the understanding, implementation and enforcement of financial sanctions in the UK. This guidance sets out an overview of the sanctions regime on Russia to date.

23

GENERAL LICENCE – Wind Down of Positions Involving VTB

General License INT/2022/1272278

7 March 2022

This licence is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019

7 March 2022

The designated person under the licence is VTB Bank and subsidiary entity owned or controlled by VTB Bank.

The licence allows that a person may provide financial services to VTB Bank for the purposes of winding down that activity.

The licence took effect from 25 February and expires on 27 March 2022.

24

The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022

8 March 2022

Amends 2019 UK-Russia Regulations

8 March 2022

These regulations provide for new aviation and trade sanctions measures in relation to Russia. The Regulations confer powers on the Secretary of State, air traffic control and airport operators to prevent Russian aircraft from entering the airspace, landing in or requiring aircraft to leave the airspace of the United Kingdom.

An exception from the prohibitions is when the lives of persons and the safety of the aircraft are in danger.

25

GENERAL LICENCE: Provision of navigational data to civilian aircrafts for flight safety

General Licence INT/2022/1322576

9 March 2022

This licence is granted under regulation 32 of The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (The Belarus Regulations).

9 March 2022

This licence pertains to provision of navigational data to civilian aircrafts for flight safety.

Records must be kept by flight data providers for up to 6 years.

The licence takes effect on 9 March 2022 and is of indefinite duration.

26

Financial Sanctions Notice

10 March 2022

Implemented under 2019 UK-Russia Regulations

10 March 2022

The following entries have been added to the consolidated list and are now subject to an asset freeze:

  • Roman Arkadyevich ABRAMOVICH
  • Igor Ivanovich SECHIN
  • Oleg Vladimirovich DERIPASKA
  • Dmitri Alekseevich LEBEDEV
  • Alexei Borisovich MILLER
  • Andrei Leonidovich KOSTIN
  • Nikolai Petrovich TOKAREV

27

GENERAL LICENCE – Football Matches

General Licence INT/2022/1327076

10 March 2022

This licence is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019

10 March 2022

This licence pertains to football matches and covers, who can be paid by the clubs and for what purposes.

Persons will be required under this licence to keep accurate, complete and readable records of any activity purporting to have been permitted under the licence with a value exceeding £5,000 for a minimum of 6 years.

The licence takes effect from 10 March 2022 and expires on 31 May 2022.

28

Financial Sanctions Notice

11 March 2022

Implemented under 2019 UK-Russia Regulations

11 March 2022

386 individuals have been designated on the UK sanctions list and are now subject to an asset freeze.

29

Financial Sanctions Notice

15 March 2022

Implemented under 2019 UK-Russia Regulations

15 March 2022

350 individuals have been designated on the UK sanctions list and are now subject to an asset freeze.

The following entries have been amended and are still subject to an asset freeze:

  • Anatoly Borisovich VYBORNY
  • Aleksei Mikhailovich CHALIY

30

Financial Sanctions Notice

15 March 2022

Implemented under 2019 UK-Russia Regulations

15 March 2022

The following entries have been designated on the UK sanctions list and are now subject to an asset freeze.

  • Armen Sumbatovich GASPARYAN
  • Suleyman Abusaidovich KERIMOV
  • Tigray Organesovich KHUDAVERDYAN
  • Dmitry Yevgenevich KULIKOV
  • Alexey Viktorovich KUZMICHEV
  • Alexander Alexandrovich MIKHEEV
  • Vladimir Valerievich RASHEVSKY
  • Viktor Filippovich RASHNIKOV
  • Andrey Valerievich RYUMIN
  • Marina Vladimirovna SECHINA
  • Artyom Grigoryevich SHEYNIN
  • Alexander Nikolayevich SHOKHIN
  • ROSNEFT AERO
  • JSC ZELENODOLSK SHIPYARD

The following entries have been amended and are still subject to an asset freeze:

  • Yulia Vasilievna OGLOBLINA
  • Anatoly Vladimirovich VORONOVSKY
  • Mikhail Nikolaevich BERULAVA
  • Oleg Dmitrievich DIMOV
  • Sergei Mikhailovich SOKOL
  • Tatyana Ivanovna DYAKONOVA
  • Dmitri Alekseevich LEBEDEV
  • Anatoly Alexandrovich WASSERMAN

31

Financial Sanctions Notice

18 March 2021

Implemented under 2019 UK-Russia Regulations

18 March 2021

The following entries have been corrected and are still subject to an asset freeze:

  • FRIDMAN Mikhail Maratovic
  • AVEN Petr Olegovich
  • KHAN German Borisovich
  • TATARCHENKO Denis Sergeyevich
  • NEZHDANOVA Yevgeniya Vitalyevna
  • IGNATOVA Ekaterina Sergeevna
  • SHUVALOVA Maria Igorevna
  • KOLOKOLTSEV Vladimir
  • PUCHKOV Andrey Sergeevich
  • SHCHEGOLEV Igor Olegovich
  • ENBERG Liliya Arkadyevna
  • ROTENBERG Roman Borisovich
  • SHUVALOV Evgeny Igorevich
  • PRIGOZHIN Pavel Evgenyevich
  • KRANS Maksim Iosifovich
  • SOLOVYOV Yuri Alekseyevich
  • ROTENBERG Pavel Arkedyevich
  • RASHNIKOV Viktor Filippovich
  • KRAVCHENKO Vladimir Kasimirovich
  • LOBACH Tatyana
  • KIRIYENKO Vladimir Sergeevich
  • ULYUTINA Galina
  • VOLFOVICH Aleksandr Grigorievich
  • BOLOTOVA Maiya Nikolaevna

32

GENERAL LICENCE – Wind down of derivatives, repurchase, and reverse repurchase transactions

General Licence INT/2022/1381276

22 March 2022

Implemented under 2019 UK-Russia Regulations

22 March 2021

For the purposes of this General Licence the entities referred to consist of the:

  • Central Bank of the Russian Federation (CBR)
  • National Wealth Fund of the Russian Federation (NWF)
  • Ministry of Finance of the Russian Federation (MF)

Under General Licence INT/2022/1381276 a Person may provide financial services for the purposes of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 1st March 2022 with the CBR, the NWF or the MF. A Person or Relevant Institution, can carry out any activity reasonably necessary to effect this.

33

Updated Financial Sanctions General Guidance

22 March 2022

22 March 2022

New paragraph (4.14) added to the Ownership and Control subject and clarifies OFSI's position on aggregation and reads as follows:

"When making an assessment on ownership and control, OFSI would not simply aggregate different designated persons’ holdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated parties or one party controls the rights of another. Consequently, if each of the designated person's holdings falls below the 50% threshold in respect of share ownership and there is no evidence of a joint arrangement or that the shares are held jointly, the company would not be directly or indirectly owned by a designated person.

It should be noted that ownership and control also relates to holding more than 50% of voting rights, the right to appoint or remove a majority of the board of directors and it being reasonable to expect that a designated person would be able in significant respects to ensure that the affairs of a company are conducted in accordance with their wishes. If any of these apply, the company could be controlled by a designated person."

34

Financial Sanctions Notice Belarus

24 March 2021

Implemented under 2019 Belarus (Sanctions) (EU Exit) Regulations

24 March 2022

The following entries have been added to the consolidated list and are subject to an asset freeze:

  • BANK DABRABYT JOINT STOCK COMPANY
  • CJSC BELBIZNESLIZING (
  • INDUSTRIAL-COMMERCIAL PRIVATE UNITARY ENTERPRISE MINOTOR-SERVICE
  • JSC TRANSVIAEXPORT AIRLINES
  • LIMITED LIABILITY COMPANY BELINVEST-ENGINEERING
  • OJSC KB RADAR-MANAGING COMPANY HOLDING RADAR SYSTEM

35

Financial Sanctions Notice

Russia

24 March 2022

Implemented under 2019 UK-Russia Regulations

24 March 2022

33 individuals and 26 entities have been designated on the UK sanctions list and are now subject to an asset freeze.

36

GENERAL LICENCE – Wind Down of Positions Involving Various Designated Banks

General License INT/2022/1424276

24 March 2022

Implemented under 2019 UK-Russia Regulations

24 March 2022

Under this license, the designated persons (DPs) are:

  • Alfa Bank JSC
  • GazPromBank
  • Rosselkhozbank
  • SMP Bank
  • Ural Bank for Reconstruction and Development
  • Subsidiaries of the DPs

The GL permits a person (other than the DPs or a subsidiary) to wind down any transactions to which it is party including the closing out of positions. A person, relevant institution, or the DPs or a subsidiary, can carry out any activity reasonably necessary to effect this.

37

GENERAL LICENCE – Wind Down of Positions Involving Bank Dabrabyt

General License INT/2022/1424277

24 March 2022

Implemented under 2019 Belarus (Sanctions) (EU Exit) Regulations

24 March 2022

This license allows a person to wind down any transactions to which it is party including the closing out of positions with Bank Dabrabyt Joint Stock Company or its subsidiaries.

38

Amended
GENERAL LICENCE - Wind down of derivatives, repurchase, and reverse repurchase transactions with the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation and Ministry of Finance of the Russian Federation

General License INT/2022/1381276

24 March 2022

Implemented under 2019 UK-Russia Regulations

24 March 2022

The amendment clarifies that: "Under General Licence INT/2022/1381276 a Person may provide financial services for the purposes of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 1 March 2022 with the CBR, the NWF or the MF or those persons set out in regulation 18A d to e of the Russia Regulations. A Person or Relevant Institution can carry out any activity reasonably necessary to effect this."

39

Financial Sanctions Notice

25 March 2022

Implemented under 2019 UK-Russia Regulations

25 March 2022

The following entry has been amended and is still subject to an asset freeze:

  • SOVCOMFLOT

Also the following entries have been corrected:

  • Oleg Yurievich TINKOV
  • Eugene Markovich SHVIDLER

40

GENERAL LICENCE – Continuation of Business and Basic Needs of GEFCO UK Subsidiaries

General License INT/2022/1438977

NOTE: This has since been revoked, see row 54 below for more details.

25 March 2022

Implemented under 2019 UK-Russia Regulations

25 March 2022

Under this license the designated entity is Russian Railways. The Joint Venture is GEFCO, a Joint Venture owned by Russian Railways and Stellantis, GEFCO S.A Rue Jean Jaures, 20-22, 92800 Puteaux, France.

A Subsidiary is any entity owned or controlled by the designated entity, including:

  • GEFCO UK Ltd
  • GEFCO Forwarding UK
  • Auto XP Limited
  • XP Tech Limited

Under this licence a Person may continue business operations involving the Joint Venture or its Subsidiaries including, but not limited to: Payments to or from the Joint Venture or its Subsidiaries under any obligations or contracts; Payments to or from any third party necessary to the continuation of any obligations or contracts.

NOTE: This has since been revoked, see row 54 below for more details.

41

GENERAL LICENCE – Wind Down of Positions Involving Sovcomflot

General License INT/2022/1469378

29 March 2022

Implemented under 2019 UK-Russia Regulations

29 March 2022

Under this license the designated entity is Sovcomflot. A subsidiary is any entity owned or controlled by the designated entity.

This licence allows a person (other than the designated entity or a subsidiary) to wind down any transactions to which it is party involving the designated entity or a subsidiary including the closing out of any positions.

42

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022

30 March 2022

Amends 2019 UK-Russia Regulations

30 March 2022

These amendments introduce a power to designate persons by description, extend existing finance, trade and shipping sanctions measures in relation to Crimea and Sevastopol to the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine. The amendments introduce prohibitions on technical assistance relating to aircraft and ships, for the purposes set out in regulation 4 of the 2019 Regulations.

43

Updated Russia Guidance

31 March 2022

Amends 2019 UK-Russia Regulations

31 March 2022

This guidance has been updated to reflect extending the financial restrictions in place to all non-government controlled Ukrainian Territory.

44

Financial Sanctions Notice

31 March 2022

Implemented under 2019 UK-Russia Regulations

31 March 2022

14 entries (12 individuals and 2 entities) have been added to the consolidated list and are now subject to an asset freeze.

45

Financial Sanctions Notice

31 March 2022

Implemented under 2019 UK-Russia Regulations

31 March 2022

Under this license, the following entities have been added to the consolidated list and are now subject to an asset freeze.

  • PHOTON PRO LLP
  • MAJORY LLP
  • DJECO GROUP LP

46

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.

General License INT/2022/1495176

1 April 2022

Implemented under 2019 UK-Russia Regulations

1 April 2022

Under this licence, a Person may provide financial services for the purposes of the receipt and onward transfer of non-rouble denominated interest/coupon or maturity/principal payments from the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (or those persons set out in regulation 18A (2) (d) - (e) of the Russia Regulations) in connection with debt issued by them before 1 March 2022. A Person or Relevant Institution can carry out any activity reasonably necessary to effect this.

47

Financial Sanctions Notice

4 April 2022

Implemented under 2019 UK-Russia Regulations

4 April 2022

This entry has been amended and is still subject to an asset freeze:

  • Andrey Anatolyevich TURCHAK

48

Financial Sanctions Notice

5 April 2022

Implemented under 2019 UK-Russia Regulations

5 April 2022

This entry has been amended and is still subject to an asset freeze:

  • WAGNER GROUP

49

Financial Sanctions Notice

6 April 2022

Implemented under 2019 UK-Russia Regulations

6 April 2022

10 entries have been added to the consolidated list and are now subject to an asset freeze:

Individuals listed:

  • IVANOV Sergei Sergeivich
  • ROTENBERG, Boris Borisovich
  • AKIMOV, Andrey Igorevich
  • DYUKOV, Alexander Valeryevich
  • KOGOGIN, Sergey Anatolyevich
  • GURYEV, Andrey Grigoryevich
  • MIKHELSON, Leonid Viktorovich
  • KANTOR, Viatcheslav

Entities listed:

  • CREDIT BANK OF MOSCOW
  • PJSC SBERBANK (PUBLIC JOINT-STOCK COMPANY SBERBANK)

The following entries have been amended and are still subject to an asset freeze:

  • GAZPROMBANK
  • RUSSIAN AGRICULTURAL BANK
  • PUBLIC JOINT STOCK COMPANY “UNITED AIRCRAFT CORPORATION
  • JSC RESEARCH AND PRODUCTION CORPORATION URALVAGONZAVOD
  • VEB.RF
  • VTB BANK (PUBLIC JOINT-STOCK COMPANY)

50

GENERAL LICENCE –Wind Down of Positions Involving Credit Bank of Moscow

General License INT/2022/1544176

6 April 2022

Implemented under 2019 UK-Russia Regulations

6 April 2022

Under this General Licence a Person (other than the Designated Person (DP) or a Subsidiary) may wind down any transactions to which it is a party, involving the DPs or a Subsidiary including the closing out of any positions, and a Person, Relevant Institution, or the DPs or a Subsidiary can carry out any activity reasonably necessary to effect this.

51

GENERAL LICENCE: Asset Freeze, Correspondent Banking Relationships & Processing

Amended General License INT/2022/1277877

6 April 2022

Implemented under 2019 UK-Russia Regulations

6 April 2022

This General Licence has been amended. Now that Sberbank is subject to an asset freeze under the Russia (Sanctions) (EU Exit) Regulations 2019, this amendment ensures that the General Licence in respect of energy related payments may continue to be used.

52

Financial Sanctions Notice

8 April 2022

Implemented under 2019 UK-Russia Regulations

8 April 2022

The following entries have been added to the consolidated list and are now subject to an asset freeze:

  • Katerina Vladimirovna Tikhonova
  • Maria Vladimirovna Vorontsova
  • Yekaterina Sergeyevna Vinokurova

Further, the following entry has been amended under the Russia financial sanctions regime and remains subject to an asset freeze:

  • Evgeny Alekseevich Fedorov

53

Financial Sanctions Notice

11 April 2022

Implemented under 2019 UK-Russia Regulations

11 April 2022

The following entries have been amended and are still subject to an asset freeze:

  • Evgeny Alekseevich FEDOROV
  • Tigran Organesovich KHUDAVERDYAN
  • Katerina Vladimirovna TIKHONOVA

54

GENERAL LICENCE – Continuation of Business and Basic Needs of GEFCO UK Subsidiaries

Revoked General License INT/2022/1438977

12 April 2022

Implemented under 2019 UK-Russia Regulations

12 April 2022

This General License has been revoked. This is following the sale of Russian Railways' stake in GEFCO to non-designated persons, meaning GEFCO is no longer impacted by UK sanctions.

The sale was completed on 8 April 2022.

55

Financial Sanctions Notice - Russia

13 April 2022

Implemented under 2019 UK-Russia Regulations

13 April 2022

206 entries have been added to the consolidated list and are now subject to an asset freeze.

56

Financial Sanctions Notice - Belarus

13 April 2022

Implemented under 2019 Belarus (Sanctions) (EU Exit) Regulations

13 April 2022

9 individuals have been corrected to the consolidated list and are still subject to an asset freeze:

  • AZARENOK Grigoriy Yurievich
  • EISMONT Natalia Nikolayevna
  • IPATAU Vadzim Dzmitryevich
  • HUSTYR Yulia Chaslavauna
  • KALINOUSKY Siarhei Aliakseevich
  • KASYANCHYK Alina Sergeevna
  • LUKASHENKO Viktor Aliaksandravich
  • SAKALOUSKI Ivan Yurievich
  • YARMOSHINA Lidzia Mihailauna

57

Financial Sanctions Notice

14 April 2022

Implemented under 2019 UK-Russia Regulations

14 April 2022

The following individuals have been added to the consolidated list and are now subject to an asset freeze:

  • Eugene Tenenbaum
  • David Davidovich

58

The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022

14 April 2022

Amends 2019 UK-Russia Regulations

14 April 2022

This instrument provides for a number of trade restrictions.

These include:

  • to prohibit the export, supply and delivery, making available and transfer of Quantum computing and advanced materials-related goods and technology to, or for the use in, Russia, or to a person connected with Russia (as well as related technical assistance, financial services, funds and brokering services);
  • to prohibit the export, supply and delivery, making available and transfer of oil refining goods and technology (including oil catalysts) to, or for use in, Russia, or to a person connected with Russia (as well as, where appropriate, related technical assistance, financial services, funds and brokering services).
  • to prohibit the export of export, supply, delivery, making available and transfer of certain luxury goods, to, or for use in, Russia, or to a person connected with Russia. 3 7.7
  • This instrument also amends the 2019 Regulations to introduce a new prohibition on the import, acquisition, supply and delivery of certain iron and steel products originating in or consigned from Russia.
  • The purpose of this measure is to limit Russia’s exporting capability in a major market. 7.8
  • The instrument also makes amendments to the 2019 Regulations to provide for exceptions from these measures, licensing and enforcement, including the expansion of criminal offences.

59

Notice NTE 2022/14: Introduction of additional sanctions against Russia

14 April 2022

Implemented under 2019 UK-Russia Regulations

14 April 2022

This Notice is giving guidance on the new trade sanctions on Russia by the newly issued Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022. See line 58.

60

Notice 2953: Russia import sanctions

14 April 2022

Implemented under 2019 UK-Russia Regulations

14 April 2022

Updated Notice to provide an overview of the import prohibitions on certain goods imported into the UK and sets out the licensing process for traders looking to import goods subject to prohibitions

61

Financial Sanctions Notice - Russia

21 April 2022

Implemented under 2019 UK-Russia Regulations

21 April 2022

26 entries have been added to the consolidated list and are now subject to an asset freeze and 30 entries have been amended and are still subject to an asset freeze.

62

GENERAL LICENCE: Gazprombank Energy Payments

General License INT/2022/1630477

21 April 2022

Implemented under 2019 UK-Russia Regulations

21 April 2022

Under this General Licence a Person may continue to make payments to Gazprombank or a Subsidiary under a contract entered into prior to the date of this licence 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 including the opening and closing of bank accounts.

A Person making payments under this licence must keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years.

63

GENERAL LICENCE - Russian Banks – UK subsidiaries - Basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments

Amended General License INT/2022/1280876

22 April 2022

Implemented under 2019 UK-Russia Regulations

22 April 2022

This General Licence has been amended to also include Sberbank CIB (UK) Ltd.

64

Financial Sanctions Notice

26 April 2022

Implemented under 2019 UK-Russia Regulations

22 April 2022

195 entries have been amended and 2 entries corrected under the Russia financial sanctions regime and remain subject to an asset freeze.

65

General Licence – Publication Notice

General licence INT/2022/1679676

27 April 2022

Implemented under 2019 UK-Russia Regulations

27 April 2022

Under General Licence INT/2022/1679676, subject to the conditions set out in that licence, an officer of a Non-Crown Relevant Organisation is permitted to carry out their duties including through making use of powers available to them under UK legislation or common law for Asset Recovery Purposes.

66

The Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022

29 April 2022

Amends 2019 UK-Russia Regulations

29 April 2022

This instrument is made under the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’) to make amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) (‘the 2019 Regulations’). These amendments will introduce new trade sanctions measures relating to internet services and online media services, for the purposes set out in regulation 4 of the 2019 Regulations.

This instrument amends Part 5 (Trade) of the 2019 Regulations, which contains trade sanctions measures, and makes related consequential amendments. This instrument provides for a number of restrictions in the form of trade in services sanctions. It introduces requirements that: Social media services, including video sharing platforms, must take reasonable steps to prevent content that is generated directly on the service, or uploaded to or shared on the service, by a designated person being encountered by a user of the service in the United Kingdom. Internet access services, including fixed and wireless broadband providers, must take reasonable steps to prevent users of the service in the United Kingdom from accessing websites provided by a designated person. This will likely take the form of URL blocking. Application stores, including those on smartphones, must take reasonable steps to prevent users of the application store in the United Kingdom from downloading or otherwise accessing an application provided by a designated person.

The instrument confers powers on the Secretary of State to designate persons to whom these online restrictions will apply. The instrument also confers on the Office of Communications (Ofcom) the power to impose civil monetary penalties on a person who fails to comply with the new trade sanctions. Failing to comply with the new sanctions is also a criminal offence.

67

Financial Sanctions Notice

4 May 2022

Implemented under 2019 UK-Russia Regulations

4 May 2022

63 entries have been added to the consolidated list and are now subject to an asset freeze.

The following 2 entries have been amended and are still subject to an asset freeze: Rossiya SEGODNYA and TV-NOVOSTI

68

GENERAL LICENCE – Continuation of Business of Evraz Plc’s North American Subsidiaries


General licence - INT/2022/1710676

5 May 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulations

5 May 2022

Under General Licence INT/2022/1710676, a person may continue business operations involving the North American Subsidiaries of Evraz including but not limited to 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. Evraz North America plc is also permitted to pay for the audit services referred to in the previous sentence.

69

Financial Sanctions Notice

5 May 2022

Implemented under 2019 UK-Russia Regulations

5 May 2022

The following entry has been added to the consolidated list and is now subject to an asset freeze:

EVRAZ PLC

70

Financial Sanctions Notice

9 May 2022

Implemented under 2019 UK-Russia Regulations

9 May 2022

88 entries have been amended on the consolidated list and still subject to an asset freeze.

71

GENERAL LICENCE – Amsterdam Trade Bank N.V – winding down, basic needs and insolvency related payments

General licence - INT/2022/1678476

12 May 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulation

12 May 2022

Under General Licence INT/2022/1678476, there are provisions relating to winding down, basic needs and insolvency related payments in connection with Amsterdam Trade Bank N.V

72

Financial Sanctions Notice

13 May 2022

Implemented under 2019 UK-Russia Regulations

13 May 2022

12 entries have been added to the consolidated list and are now subject to an asset freeze. Furthermore, 10 entries have been amended and remain subject to an asset freeze.

73

Financial Sanctions Notice

19 May 2022

Implemented under 2019 UK-Russia Regulations

19 May 2022

The following entries have been added to the consolidated list and are now subject to an asset freeze:

  • JSC Rossiya Airlines
  • JSC Ural Airlines
  • PJSC Aeroflot

74

GENERAL LICENCE – Russian Travel

23 May 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulations

23 May 2022

Under this licence, subject to the conditions below;

  • A United Kingdom Person may purchase tickets from a Designated Person or any Subsidiary for flights or rail journeys originating in, or within, Russia.
  • 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 in accordance with paragraph above

75

Financial Sanctions Notice

24 May 2022

Implemented under 2019 UK-Russia Regulations

24 May 2022

63 entries have been amended and are still subject to an asset freeze.

76

Financial Sanctions Notice

Belarus

27 May 2022

Implemented under 2019 Belarus (Sanctions) (EU Exit) Regulations

27 May 2022

6 entries have been amended under the Belarus regime and are still subject to an asset freeze.

77

Financial Sanctions Notice

Russia

27 May 2022

Implemented under 2019 UK-Russia Regulations

27 May 2022

299 entries have been amended under the Russia regime and are still subject to an asset freeze.

78

GENERAL LICENCE – Continuation of Business and Basic Needs for Telecommunications Services and News Media Services

General licence - INT/2022/1875276

30 May 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulations

30 May 2022

Under General licence INT/2022/1875276, business operations involving the provision of Civilian Telecommunication Services that include ZAO TransTeleCom Company, can continue subject to the conditions contained in the licence. The licence also permits business operations related to News Media Services to continue subject to certain conditions.

79

GENERAL LICENCE – Russia Designated Persons – Charities and Interim Managers and trustees

General licence - INT/2022/1834876

30 May 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulations

30 May 2022

General licence – INT/2022/1834876, allows for Interim Managers and trustees to act as receiver(s) and manager(s) in respect of the property and affairs of a charity, as specified in this General Licence. The full details of the permissions and usage requirements can be found within the General licence, here and the Publication Notice here.

80

Guidance

Trading under sanctions with Russia

8 June 2022

Implemented under 2019 UK-Russia Regulations

8 June 2022

This Guidance is issued to advise what import and export restrictions apply due to sanctions for UK companies when trading with Russia.

81

GENERAL LICENCE – Funds of non-designated third parties involving designated credit or financial Institutions

General licence - INT/2022/1919908

10 June 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulations

10 June 2022

Under General Licence INT/2022/1919908:

  • Subject to the conditions set out in the licence a Person may make use of the retail banking services of a designated Credit or Financial Institution provided that the payments made or received are intended for the personal use of a Person
  • During the period from the Date of Issue to the Date of Expiry (inclusive), a Person may only make payments in accordance with paragraph 4.1 of the licence provided that the total value of such payments made by the Person does not exceed £50,000
  • A Relevant Institution may process payments made in accordance with the permissions above provided that the total value of such payments processed by that Relevant Institution during the period from the Date of Issue to the Date of Expiry (inclusive) in respect of a Person does not exceed £50,000

Reporting Requirement - General Licence INT/2022/1919908 includes a reporting requirement that within 14 days of processing a payment in accordance with paragraphs 4.1 and 4.3 of the licence, a Relevant Institution must report to HM Treasury, with details and supporting evidence of:

  • The amount(s) processed
  • The payment route used
  • The date on which the funds were processed

82

Guidance

Russia sanctions: notes on designations data

10 June 2022

Implemented under 2019 UK-Russia Regulations

10 June 2022

This guidance is published to explain how the UK Government collates this data on designations and what it means.

83

Financial Sanctions Notice

14 June 2022

Implemented under 2019 UK-Russia Regulations

14 June 2022

39 entries have been amended to the consolidated list and are still subject to an asset freeze. Further information can be found in the annex of the Notice.

84

Financial Sanctions Notice

16 June 2022

Implemented under 2019 UK-Russia Regulations

16 June 2022

12 entries have been added to the consolidated list and are now subject to an asset freeze. Further information can be found in the annex of the Notice.

85

The Russia (Sanctions) (EU Exit) (Amendment) (No.10) Regulations 2022

22 June 2022

Amends to 2019 UK-Russia Regulations

23 June 2022

The Regulations and the Notice 2022/18 adopted further trade sanctions, that include;

Prohibitions on the export, supply and delivery, making available and transfer (as well as related technical assistance, financial services, funds and brokering services) of:

  • Internal repression goods and technology
  • Goods and technology relating to chemical and biological weapons
  • Maritime goods and technology
  • Additional oil refining goods and technology
  • Additional critical industry goods and technology

Prohibitions on the export to, or for use in Russia of jet fuel and fuel additives, as well as prohibitions on the making available, export, and supply, directly or indirectly, of such products to Russia or for use in Russia (as well as related technical assistance, financial services, funds, and brokering services).

Prohibitions on the export to, or for use in, Russia, of Sterling or EU denominated banknotes; as well as prohibitions on the making available, supply, or delivery of such banknotes to a person connected with Russia; and on the making available of such banknotes for use in Russia.

Some of the above prohibitions will relate to Russia, and the non-government controlled Ukraine territories.

Prohibitions on the import, acquisition or supply and delivery of revenue generating goods that originate in or are consigned from Russia (as well as related technical assistance, financial services, funds, and brokering services.

Prohibitions on the provision of technical assistance, and financial services, funds, and brokering services relating to iron and steel imports.

86

Financial Sanctions Notice

24 June 2022

Implemented under 2019 UK-Russia Regulations

24 June 2022

58 entries have been amended and 1 entry corrected and remain subject to an asset freeze. Further information can be found in the annex of the Notice.

87

Financial Sanctions Notice

29 June 2022

Implemented under 2019 UK-Russia Regulations

29 June 2022

13 entries have been added and are now subject to an asset freeze. 1 entry has also been corrected under and remains subject to an asset freeze.

88

GENERAL LICENCE – Wind Down of Positions Involving Rosbank

General licence - INT/2022/1968500

30 June 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulations

30 June 2022

General Licence INT/2022/1968500 allows for a 30 day wind down period of positions involving Rosbank PJSC (Rosbank) or any entity owned or controlled by Rosbank.

89

Financial Sanctions Notice

4 July 2022

Implemented under 2019 UK-Russia Regulations

4 July 2022

The following entries have been added to the consolidated list and are now subject to an asset freeze:

  • Aleyona Anatolyevna Chuguleva
  • Yuriy Sergeyevich Fedin
  • Darya Aleksandrovna Dugina
  • Yevgeniy Eduardovich Glotov
  • Aelita Leonidovna Mamakova
  • Mikhail Anatolyevich Sinelin
  • United World International

Furthermore, 45 entries have been amended and 1 entry corrected under the Russia regime. Further information can be found in the annex to this Notice.

90

GENERAL LICENCE – Financial services regarding wind down of derivatives, repurchase, and reverse repurchase transactions with the National Bank of Belarus, and Ministry of Finance of Belarus.

General Licence - INT/2022/1976232

5 July 2022

Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (“the Belarus Regulations”)

5 July 2022

This General Licence allows a period of until 04 August 2022 for a Person to provide financial services for the purpose of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 05 July 2022 involving:

  • National Bank of Belarus (NBB);
  • Ministry of Finance of Belarus (MF); and
  • Those persons set out in regulation 15CA c to d of the Belarus Regulations.

91

GENERAL LICENCE: Transferable securities, money-market instruments, loans and credit arrangements

General Licence - INT/2022/1976332

5 July 2022

Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (“the Belarus Regulations”)

5 July 2022

This General Licence allows for a 7-day wind down period in respect of, category C loans (as defined by Regulation 15B (5)) as well as transferable securities and money market instruments (as defined by Regulation 15A (2C)).

92

Financial Sanctions Notice

5 July 2022

Implemented under 2019 UK-Russia Regulation

5 July 2022

The following entries have been added to the consolidated list and are now subject to an asset freeze:

  • Denis Yakovlevich GAFNER
  • Valeriya KALABAYEVA

The following entries have been removed from the consolidated list and are no longer subject to an asset freeze:

  • Yakov Vladimirovich REZANTSEV
  • Galina ULYUTINA

The following entries have been amended and are still subject to an asset freeze:

  • Aleksandra Aleksandrovna KAMYSHANOVA
  • Yevgeniya Vitalyevna NEZHDANOVA
  • Valeriy Ivanovich POGREBENKOV

93

Financial Sanctions Notice - Belarus

7 July 2022

Implemented under 2019 UK-Belarus Regulations

7 July 2022

The following entity has been amended under the Belarus regime and remains subject to an asset freeze:

  • LLC Synesis

94

GENERAL LICENCE: Humanitarian Activity

General Licence - INT/2022/1947936

7 July 2022

Implemented under Regulation 64 of 2019 UK-Russia Regulations

7 July 2022

Under General Licence INT/2022/1947936 relevant persons seeking to undertake humanitarian activity in relation to the conflict in Ukraine do not need to apply for individual licences from OFSI, but instead can rely on the permissions within this General Licence.

95

Financial Sanctions Notice

12 July 2022

Implemented under 2019 UK-Russia Regulations

12 July 2022

16 entries have been amended and 2 entries corrected under the Russia financial sanctions regime and remain subject to an asset freeze.

96

Financial Sanctions Notice - Belarus

12 July 2022

Implemented under 2019 UK-Belarus Regulations

12 July 2022

6 entries have been amended under the Belarus financial sanctions regime and remain subject to an asset freeze.

97

Financial Sanctions Notice

15 July 2022

Amends 2019 UK-Russia Regulations

15 July 2022

The following entries have been removed from the consolidated list and are no longer subject to an asset freeze:

  • Didier Casimiro
  • Zeljko Runje

The following entries have been amended under the Russia regime and remain subject to an asset freeze:

  • Sergei Ivanovich Saenko
  • Vladimir Leonidovich Sivkovich
  • Oleg Anatolyevich Voloshyn
  • Alrosa

98

Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022

15 July 2022

Amends 2019 UK-Russia Regulations

15 July 2022

These Regulations are made under the Sanctions and Anti-Money Laundering Act 2018 (c. 13) to amend the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) (“the 2019 Regulations”). Regulations 3 to 8 and 12(2) to (5) and (8) amend Part 5 of the 2019 Regulations relating to trade, and both amend existing Schedules and insert new ones. New restrictions are imposed in relation to trade in:

  • Maritime goods and maritime technology in certain circumstances (regulation 5)
  • Military goods and technology with non-government controlled Ukrainian territory (as specified in new Chapter 2A of Part 5)
  • Defence and security goods and technology (as specified in Parts 2 to 4 of new Schedule 3C)
  • Interception and monitoring services
  • Banknotes
  • Jet fuel and fuel additives (as specified in an addition to Part 8 of Schedule 2A)
  • Goods which generate significant revenues for Russia (as specified in new Schedule 3D)

As a result of those amendments:

  • Regulation 3 amends the definitions of “critical-industry goods”, “critical-industry technology”, “restricted goods” and “restricted technology” for the purposes of Part 5 of the 2019 Regulations
  • Regulation 7 inserts additional prohibitions in Chapter 4C of Part 5 of the 2019 Regulations relating to trade in ancillary services relating to iron and steel goods and makes consequential amendments
  • Regulation 9 extends prohibitions in Part 5 of the 2019 Regulations in relation to trade in certain items with non-government controlled Ukrainian territory
  • Regulation 12(6) adds further things to the list of oil and refining goods and technology in Schedule 2D and regulation 12(7) adds further things to the list of energy-related goods in Schedule 3 in respect of which trade is prohibited

Regulation 10 amends Part 7 of the 2019 Regulations to create exceptions to some of the new prohibitions.

Regulation 11 makes consequential amendments in relation to offences.

Regulation 13 revokes the Russia (Sanctions) (EU Exit) (Amendment) (No. 10) Regulations 2022 (S.I. 2022/689).

99

The Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022

19 July 2022

Amends 2019 UK-Russia Regulations

19 July 2022

These Regulations are made under the Sanctions and Anti-Money Laundering Act 2018 (c. 13) to amend the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) (“the 2019 Regulations”).

These Regulations add new financial sanctions to Part 3 (Finance) of the 2019 Regulations. The amendments insert restrictions regarding investments (and services directly related to those investments) in respect of land located in Russia, persons connected with Russia, relevant entities, joint ventures, opening a representative office or establishing a branch or subsidiary located in Russia. These Regulations provide for exceptions to, and licensing powers in relation to, these new provisions.

100

GENERAL LICENCE – Investments in relation to Russia

General Licence - INT/2022/2002560

19 July 2022

Implemented under regulation 64 of 2019 UK-Russia Regulations

19 July 2022

This General Licence INT/2022/2002560 allows for a 7-day wind down period in respect of the outward investment ban outlined in the Amendment 12 Regulations.
This licence takes effect from 19 July 2022 and expires on 26 July 2022.

101

The Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022

18 July 2022

Amends 2019 UK-Russia Regulations

18 July 2022

These Regulations are made under the Sanctions and Anti-Money Laundering Act 2018 (c.13) to amend the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) (“the 2019 Regulations”).

Part 2 makes amendments to the designation criteria in regulation 6 of the 2019 Regulations: first, to specify additional activities for which a person may be designated; second, to make minor amendments to the definition of “being involved in obtaining a benefit from or supporting the Government of Russia”; and third, to broaden the interpretation of being “associated with” a designated person.

Part 3 provides for a new exception from trade sanctions measures for humanitarian assistance activity in non-government controlled areas of the Donetsk and Luhansk oblasts.

Part 4 makes provision to correct or resolve a number of issues arising from the 2019 Regulations or amendments made to them: first, to expand upon the definition of ownership in relation to ships and aircraft; and second, to correct drafting errors or omissions in regulations 76, 78 and 94.

102

Russia Guidance - Updated

19 July 2022

Implements under 2019 UK-Russia Regulations

19 July 2022

The guidance has a new section on investments in Russia on page 5 to 6. It also updates the FAQs section on page 8 to 11 to reflect the Russia financial sanctions that have come into force since the Russian invasion of Ukraine.

103

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2022

and

The Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2022

19 July 2022

9 August 2022

These regulations extend the definition of ‘relevant firms’ that have financial sanctions reporting obligations to include cryptoasset exchange providers and custodian wallet providers.

There is a requirement for 'relevant firms', as defined in sanctions regulations, to notify OFSI of certain information as soon as practicable when encountering a designated person in the course of their business. This requirement applies to relevant firms in the UK or under UK jurisdiction including people working for them.

Chapter 5 of OFSI's general guidance covers reporting obligations. For further information on reporting obligations, including how to report to OFSI can be found here.

104

Financial Sanctions Notice

20 July 2022

Implemented under 2019 UK-Russia Regulations

20 July 2022

The following entries have been amended under the Russia regime and remain subject to an asset freeze:

  • Irina Sergeyevna Bubnova
  • Sergei Sergeivich Ivanov
  • Natalya Petrovna Skorokhodova
  • Djeco Group LP
  • Majory LLP
  • Photon Pro LLP

105

The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022

21 July 2022

Amends 2019 UK-Russia Regulations

21 July 2022

These Regulations amend Part 5 of the 2019 Regulations, on trade, and insert related Schedules. New restrictions are imposed in relation to trade in:

  • Professional and business services (as specified in new regulation 54B)
  • Miscellaneous essential goods required for the functioning of the Russian economy (as specified in new Schedule 3E)
  • Oil and oil products means (as specified in new Schedule 3F)
  • Gold (as specified in new Schedule 3G)
  • Coal and coal products (as specified in new Schedule 3H)

The goods specified in new Schedules 3E, 3F, 3G and 3H are specified by reference to commodity codes which are set out in the Tariff of the United Kingdom.

Provision in also made in relation to energy related goods, supplementing existing provision in Chapter 4 of Part 5.

Provision is also made in relation to the giving of technical assistance to certain aircraft situated at UK airports.

The remainder of the provisions in these Regulations relate to trade exceptions and enforcement.

106

GENERAL LICENCE: Payment to UK Insurance Companies for Building and Engineering Insurance

22 July 2022

Russia (Sanctions) (EU Exit) Regulations 2019

Regulations 11 to 15

22 July 2022

Under the General Licence, individuals or entities designated under the UK Sanctions Regimes are permitted to make payments to UK insurers for insurance premiums and broker commissions relating to the provision of building and engineering insurance cover provided to UK properties.

The licence also permits UK insurers to make payments to UK Designated Persons due as a result of a successful claim made against an insurance policy provided by the UK Insurer or refunds due as a result of any over payments made pursuant to this licence.

The General Licence is applicable across multiple regimes. These are detailed in Annex 1.

107

Financial Sanctions Notice

26 July 2022

Implemented under 2019 UK-Russia Regulations

26 July 2022

42 entries have been added to the consolidated list and are now subject to an asset freeze. Further information can be found in the annex to this Notice.

The following entry has been corrected on the consolidated list and remains subject to an asset freeze: Vadim Anatolyevich LUKASHEVICH.

108

GENERAL LICENCE – Wind Down of Positions Involving Rosbank

INT/2022/1968500

30 July 2022

Implemented under regulation 64 of 2019 UK-Russia Regulations

30 July 2022


General licence INT/2022/1968500 extended for a period of 2 months to the 30 September, allowing for the winding down of positions involving Rosbank.

109

Financial Sanctions Notice

2 August 2022

Implemented under 2019 UK-Russia Regulations

2 August 2022

The following entries have been added to the Russia regime and are now subject to an asset freeze:

  • Didier Casimiro
  • Zeljko Runje

The following entry has been removed under the Russia regime and is no longer subject to an asset freeze:

  • Olga Ayziman

18 entries have been amended and are still subject to an asset freeze. Further information can be found in the annex to this Notice.

110

Financial Sanctions Notice

9 August 2022

Implemented under 2019 UK-Russia Regulations

9 August 2022

27 entries have been amended under the Russia financial sanctions regime and remain subject to an asset freeze. Further information can be found in the annex to this Notice.

Authors

Aki Corsoni Husain Harneys front portrait image on a grey background
Mirza Manraj Harneys front portrait image on a grey background
Peter Tarn Harneys front portrait image on a grey background
Kimberly Seagojo Harneys front portrait image on a grey background

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