Britain imposes sanctions in response to Russian invasion of Ukraine

The UK government has announced in addition to the sanctions and export controls imposed on Russia on February 22, 2022. This escalation in sanctions comes in response to Russia’s military advance into Ukraine on multiple fronts. The following is a high-level general summary of these measures, some of which involve lengthy and complex rules. Please contact Michael Ruck in our London office for UK sanctions, Philip Torbøl or Alessandro Di Mario in our Brussels office for EU sanctions, and Jeffrey Orenstein, Steven Hill or any member of the Washington-based international trade group , DC if you have specific questions about the US sanctions regime.

SANCTIONS EFFECTIVE ON FEBRUARY 22, 2022

On February 22, 2022, the British government announced sanctions against five Russian banks (Bank Rossiya, Black Sea Bank for Development and Reconstruction, Joint Stock Company Genbank, IS Bank and Promsvyazbank (PSB)) and three individuals (Gennadiy Nikolayevich Timchenko, Boris Romanovich Rotenberg). ) to , and Igor Arkadyevich Rotenberg). These sanctions mark the first use by the United Kingdom of its expanded powers to impose sanctions on Russia that are more akin to the United States’ sanctioning authority.

As a result, UK individuals and entities are now prohibited from dealing directly or indirectly with Russian banks or individuals or providing funds to or for the benefit of Russian banks or individuals. In addition, the nominated persons are prohibited from entering the United Kingdom.

These UK sanctioning powers are already included in the UK Russia Regulations, leaving all other provisions of the existing legal framework – such as those relating to licences, reporting requirements, exclusions and other types of trading, as well as financial and investment restrictions – unchanged.

ANNOUNCEMENT BY THE UK GOVERNMENT OF 24 FEBRUARY 2022

Boris Johnson announced the “biggest and toughest package of economic sanctions Russia has ever faced” after invading Ukraine. The Prime Minister told the UK Parliament that more oligarchs and all major Russian banks would freeze their assets, targeting 100 individuals and organizations.

This resulted in the following first tranche of Russian banks, companies and individuals being added to the UK sanctions list on 24 February 2022:

  • Kirill Shamalov

  • Peter Fradkow

  • Denis Bortnikov

  • Yuri Slyusar

  • Elena Aleksandrovna Georgieva

  • Rostek

  • Uralvagonzavod

  • Tactile Missile Corporation

  • United Aircraft Corp

  • United Shipbuilding Society

In addition, the following other sanctions and measures announced by the UK Government include:

  • New legislation will ensure all major Russian banks have their assets frozen and locked out of the UK financial system. This will prevent them from accessing sterling and making payments through the UK. This included the imposition of a full and immediate freeze on VTB Bank’s assets.

  • Laws will be passed early next week to prevent major Russian companies and the state from borrowing or borrowing money in the UK markets.

  • 100 new individuals or entities are added to the UK sanctions list.

  • Aeroflot will be banned from landing in the UK.

  • All dual-use export licenses for military-grade components have been suspended with immediate effect.

  • The UK will halt exports of high-tech items and oil refining equipment in the next few days.

  • There will be a £50,000 limit on deposits that Russians can make into UK bank accounts.

  • There is a possibility of excluding Russia from the international Swift payment system, but at this point it seems unlikely that the European Union will support this proposal.

  • Similar financial sanctions are being imposed on Belarus for its role in attacking Ukraine.

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