Sanctions Tracker ' Latest UK Sanctions Imposed On Russia

Published date03 March 2022
Subject MatterFinance and Banking, International Law, Financial Services, Export Controls & Trade & Investment Sanctions
Law FirmHerbert Smith Freehills
AuthorMs Susannah Cogman, Daniel Hudson and Elizabeth Head

Further to our post yesterday, we set out below the latest UK developments in response to the conflict in Ukraine. As ever, the position continues to change rapidly and we will continue to provide updates via this blog.

Further designations

On 1 March, the UK's Office of Financial Sanctions Implementation ("OFSI") announced two further designations: Russian Direct Investment Fund and its CEO. Both are now subject to the UK's existing asset freeze measures.

New General Licences

On the same day, OFSI published two further General Licences ("GLs"), both of which relate to VTB Capital and its UK subsidiaries.

  • GL INT/2022/1280976 applies to "relevant authorities", namely those involved in the UK regulation of financial services, including the Financial Conduct Authority, the Financial Services Compensation Scheme, the Prudential Regulation Authority, and the Bank of England. The GL provides that anything may be done by a relevant authority in respect of VTB Capital or its UK subsidiaries for the purposes of the functions of that authority. This includes prudential supervision or protecting, maintaining or enhancing the stability of the UK's financial system. The GL expires on 1 March 2023 OFSI has also issued a publication notice in connection with this GL.
  • GL INT/2022/1280876 provides that VTB Capital and its UK subsidiaries (defined as the "UK Subsidiaries") may, until 1 March 2023, make certain payments namely in respect of
    • basic needs including payment of insurance premiums, fees for property management services, remuneration/allowances/pensions of employees, tax, rent/mortgage payments and utility payments;
    • reasonable fees or service charges arising from the routine holding and maintenance of their frozen funds or economic resources; and
    • reasonable professional fees for the provision of legal services or reasonable expenses associated with the provision of legal services.

The GL authorises any person to receive payments in respect of the above, and "relevant institutions" (financial institutions, clearing houses, counterparties, or payment systems operators) to process such payments. When making a payment under the GL, the UK Subsidiary is required to provide written notice to OFSI and to retain accurate, complete and readable records for a minimum of six years. The publication notice relating to this GL is available here.

New sanctions legislation (in force from 1 March)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022 were...

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