Since March 8, 2022, the United Kingdom has continued to introduce and announce new sanctions and export controls measures in response to Russia’s invasion of Ukraine. The new UK measures include the designation of hundreds of individuals, the introduction of new sanctions measures under the sixth amendment to The Russia (EU Exit) (Sanctions) Regulations 2019 (Russia Regulations), amendments to VTB Bank general licence INT/2022/1272278, removal of Belarus from nine open general export licences (OGELs), and the announcement of the UK’s intention to phase out Russian oil imports by the end of 2022.
For a summary of new Ukraine-related US sanctions and export controls on Russia and Belarus, see this Steptoe blog post.
For additional resources can be found on Steptoe’s “Sanctions against Russia: Implications for Business and International Trade” page.
New Designations of Individuals
On March 10, 2022, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) designated a further seven Russian individuals, who are now subject to asset freezes and UK travel banks. The designated individuals are:
- Roman Arkadyevich Abramovich;
- Igor Ivanovich Sechin;
- Oleg Vladimirovich Deripaska;
- Dmitri Alekseevich Lebedev;
- Alexei Borisovich Miller;
- Andrei Leonidovich Kostin; and
- Nikolai Petrovich Tokarev.
As a result of the designation of Mr. Abramovich, Chelsea Football Club is also now subject to an asset freeze. OFSI has published a blog post regarding the measure and a general licence has been issued in relation to the club to permit certain payments to be made until May 31, 2022.
On March 11, 2022, OFSI also designated 386 members of the State Duma of the Russian Federation, who endorsed President Putin’s decision to recognize the Donetsk People’s Republic and the Luhansk People’s Republic as independent states, mirroring measure previously taken by the European Union and the United States. These individuals are now subject to an asset freeze and UK travel ban.
New Amendments to the UK Russia Regulations
On March 8, 2022, the UK government introduced a new amendment to the Russia Regulations. Amendment (no. 6) introduced:
- new prohibitions on the provision of insurance and reinsurance services relating to aviation and space goods and technology;
- an extension to the prohibition on the detention of ships to include “a ship registered in Russia”;
- restrictions on UK airspace for Russian aircraft; and
- an extension to the exceptions to trade prohibitions to grant exceptions in emergencies.
The Department for International Trade also issued a General Trade Licence relating to aviation/space goods and technology insurance. The licence permits certain insurance/reinsurance services relating to aviation and space goods and technology otherwise prohibited under Regulation 28 (Financial services and funds relating to restricted goods and restricted Technology) and Regulation 29A (Insurance and reinsurance services relating to aviation and space goods and aviation and space technology). The licence runs until March 28, 2022 and is only applicable to services provided under contracts concluded before March 8, 2022.
OFSI Amends General Licence INT/2022/1272278
OFSI has amended the Notice for General Licence INT/2022/1272278, which relates to the wind down of positions with VTB Bank , to clarify that funds becoming payable to VTB Bank as a necessary part of a person winding down any transactions they have with VTB Bank are not required to be paid into a frozen account. OFSI also has amended General Licence INT/2022/1272278, to update references to UK legislation and expand the definition of a subsidiary in the licence, which expires on March 27, 2022.
Removal of Belarus from Nine OGELs
Following Belarus’s involvement in Russia’s aggression against Ukraine, the UK’s Export Control Joint Unit has re-assessed a number of relevant OGELs against the UK’s Strategic Export Licensing Criteria. Having concluded the foregoing review, Belarus was removed as a permitted destination from 9 OGELs on March 10, 2022. The affected licences are:
- OGEL (chemicals);
- OGEL (chemicals) from December 2019;
- OGEL (cryptographic development);
- OGEL (cryptographic development) from December 2019;
- OGEL (export after exhibition: dual-use items);
- OGEL (export for repair/replacement under warranty: dual-use items);
- OGEL (export for repair/replacement under warranty: dual-use items) from December 2019);
- OGEL (X); and
- OGEL (X) – from December 2019.
UK Announces the Phasing Out of Russian Oil Imports
On March 8, 2022, Business Secretary Kwasi Kwarteng announced that the UK would phase out imports of Russian oil by the end of 2022. The UK government will work with companies through a new Taskforce on Oil to support them to make use of the phase out period to find alternative supplies. Commenting on the announcement, Business Secretary Kwarteng stated “[w]e have more than enough time for the market and our supply chains to adjust to these essential changes. Businesses should use this year to ensure a smooth transition so that consumers will not be affected.”