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.

Continue Reading Round Up of New UK Sanctions and Export Controls on Russia and Belarus

On March 4, 2022, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published an updated version of its Russia guidance and issued two new general licences permitting the wind down of positions with Sberbank and involving Bank Otkritie, Promsvyazbank, Bank Rossiya, Sovcombank, and VEB.  The UK government also put forward a series of amendments to the Economic Crime (Transparency and Enforcement) Bill proponents say is needed to crack down on corrupt elites and ramp up pressure on President Putin’s regime.

Continue Reading Update: OFSI Publishes Updated Russia Guidance; Issues New General Licences; and UK Amends Draft Economic Crime Legislation to Move “Harder and Faster” with Sanctions

On March 1, 2022, four new amendments to The Russia (Sanctions) (EU Exit) Regulations 2019 (Russia Regulations) were laid before parliament and came into immediate effect.  The amendments revise the financial and investment restrictions provisions contained in Part 3, Chapter 2 and the trade sanctions provisions set out in Part 5.  New restrictions also have been introduced banning Russian ships from UK ports under Part 6 and introducing restrictions on the provision of financial services for the purpose of foreign exchange reserve and asset management.

Continue Reading Update: New UK Russia Sanctions Legislation Comes into Effect, Suspension of Export Licences for Dual-Use Items to Russia, Additional Designations and New General Licences

On February 28, 2022, the UK government announced the designation of a further three Russian banks under the Russia (Sanctions) (EU Exit) Regulations 2019 (Russia Regulations) determined to be involved in obtaining a benefit from, or supporting, the Government of Russia.  Two of the three banks already were sanctioned by the United States.  Additional banks,

The United States government has continued to impose numerous economic sanctions and export controls measures following Russia’s invasion of Ukraine.  On February 24, 2022, the US Commerce Department’s Bureau of Industry and Security (BIS) significantly expanded export controls applicable to Russia.  On February 25, 2022, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added Russian President Vladimir Putin and others to the Specially Designated Nationals (SDN) List.  It also imposed significant economic sanctions measures targeting Russia’s financial system — including by imposing sanctions on Russia’s largest financial institutions and limiting the ability of certain Russian state-owned and private entities to raise capital.  Together, OFAC’s actions, which were taken pursuant to Executive Order (EO) 14024 following Russia’s invasion of Ukraine, are estimated to affect nearly 80 percent of all banking assets in Russia.

Finally, on February 26, 2022, the United States and European Union countries, together with the United Kingdom and Canada, announced an agreement to block certain Russian banks from access to SWIFT (with Japan also agreeing the following day), to impose sanctions on Russia’s Central Bank, and to limit the ability of certain Russian nationals connected to the Russian government to obtain citizenship in their countries. They further agreed to ensure effective transatlantic coordination in implementing sanctions, including by sanctioning additional Russian entities and persons, and by working together and with other governments around the world to identify and freeze sanctioned Russian assets.

Continue Reading Biden Administration Imposes Sweeping Financial Sanctions, Export Controls after Russian Invasion of Ukraine

On February 24, 2022, the UK government announced the designation of a further five individuals and six entities under the Russia (Sanctions) (EU Exit) Regulations 2019, following Russia’s invasion of Ukraine.

The sanctions target companies and senior executives operating in Russia’s banking and defence sectors involved in the destabilization of Ukraine or in obtaining a benefit from, or supporting, the Government of Russia.  Three of the five individuals and three of the six companies already were sanctioned by the United States.

Continue Reading Ukraine Crisis: UK Announces Further Tranche of Sanctions Following Russian Invasion

On February 22, 2022, UK Prime Minister Boris Johnson announced the designation of five Russian banks and three high net worth individuals under the recently expanded Russia (Sanctions) (EU Exit) Regulations 2019 (see our previous blog post on the UK’s expanded sanctions powers here). The announcement follows the Russian government’s recognition of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) and placement of Russian military forces in those territories for purported peacekeeping operations.

The sanctions target Russian banks and high net worth individuals involved in the destabilization of Ukraine or in obtaining a benefit from, or supporting, the Government of Russia.  All three individuals and four of the five banks (with the exception of PJSC Promsvyazbank) already were sanctioned by the United States.

Continue Reading UK Announces First Sanctions Targeting Russian Banks and Oligarchs after Russia Enters Ukraine’s Donetsk and Luhansk Regions

On February 2, 2022, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) announced a GBP 36,393.45 monetary penalty against Clear Junction Limited (Clear Junction) for multiple breaches of The Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 (the UK Regulations).

According to OFSI’s penalty report, Clear Junction, a fintech company, transferred funds to

On February 10, 2022, the UK government laid before parliament The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022 (SI 2022/123) (Amended Regulations).  The Amended Regulations, which came into force on the same day, expand the scope of the UK’s Russia sanctions regime by significantly broadening the range of individuals, businesses and other entities that the UK can sanction in the event of further Russian aggression against Ukraine.  The Amended Regulations include an innovative designation criterion designed to target individuals and entities of significance to the Kremlin.  Companies that are subject to UK sanctions jurisdiction and have exposure to Russia should familiarize themselves with the expanded scope of the UK’s Russia sanctions regime as part of their efforts to assess and mitigate the risks associated with possible sanctions against Russia.

For more information on potential Russia-related UK, EU, and US sanctions, see our earlier blog posts here and here. Visit this link to sign up to receive a recording of Steptoe’s recent webinar “Possible Sanctions Against Russia: What You Need to Know.”

Continue Reading New Regulations Expand UK’s Russia Sanctions Powers

HM Treasury’s Office of Financial Sanctions Implementation (OFSI) has published a revised version of its Monetary penalties for breaches of financial sanctions guidance (Guidance), which came into force on January 28, 2022.  The new Guidance will be used to assess any potential financial sanctions breaches of which OFSI becomes aware on or after that date.