Newsflash: UK imposes Russia sanctions

22nd February 2022

The Prime Minister announced in Parliament today that the UK has imposed sanctions against five Russian banks and three high net worth individuals in response to the Ukraine crisis. The Prime Minister said that the sanctions would be extended if the situation escalated further. Sanctions from other Western nations and the EU are expected.

The listed banks and individuals have been added to the consolidated list of sanctioned individuals and organisations by HM Treasury’s Office of Financial Sanctions Implementation (OFSI) and are now subject to an asset freeze.

UK financial sanctions apply to all individuals and entities in the UK or who undertake activities here, and to all UK nationals and entities (including branches) wherever they are in the world. Breaching financial sanctions is a criminal offence.

Steps to take now

You must:

• Check whether you maintain any accounts or hold any funds or economic resources for the banks and individuals set out in the Annex to the Notice;

• Freeze such accounts, and other funds or economic resources and any funds which are owned or controlled by persons set out in the Annex;

• Refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by OFSI;

• Report any findings to OFSI, together with any additional information that would facilitate compliance with the Regulations [1];

• Provide any information concerning the frozen assets of designated persons that OFSI may request (information reported to OFSI may be passed on to other regulatory authorities or law enforcement).

See our earlier briefing on managing sanctions and supply chain risk for practical advice on controls procedures and other protections that can be put in place.

Please contact Andrew if you have any queries or require any assistance.

[1] The Russia (Sanctions) (EU Exit) Regulations 2019 were made under the Sanctions and Anti-Money Laundering Act 2018 and provide for the freezing of funds and economic resources of certain persons, entities or bodies involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, or obtaining a benefit from or supporting the Government of Russia.