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Sanctions Guidance, Public Notices and Updates

  1. BVI FSC Newsletter Issue No. 7 - December 2020 - Vol. 2
     
  2. Global Human Rights Sanctions Guidance - As required by Section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Secretary of State for Foreign and Commonwealth Affairs has provided the following guidance to assist in the implementation of and compliance with the Global Human Rights Sanctions Regulations 2020, which may be found here.
     
  3. The Office of Financial Sanctions Implementation provides information on the approach it takes to financial sanctions including sector and regime specific guidance, which may be found here.
     
  4. The Office of Financial Sanctions Implementation published the Afghanistan Guidance, which may be found here.
     
  5. The Office of Financial Sanctions Implementation published a penalty notice issued against Clear Junction Limited, which may be found here.
     
  6. The Office of Financial Sanctions Implementation published a Notice regarding the new version of the Consolidated List and list of persons, which may be found here.
     
  7. The Office of Financial Sanctions Implementation published a Notice regarding the issuing of three (3) General Licences INT/2022/1277777, INT/20221277778, and INT/2022/1277877 under the Russia (Sanctions) (EU Exit) Regulations 2019, which may be found here.
     
  8. The Office of Financial Sanctions Implementation published a Notice regarding the issuing of two (2) General Licences INT/2022/1280876 and INT/2022/1280976 under the Russia (Sanctions) (EU Exit) Regulations 2019, which may be found here.
     
  9. The Office of Financial Sanctions Implementation published a Notice regarding new regulations implemented under the Russian Sanctions Regime, which set out new restrictions on the provision of financial services for the purpose of foreign exchange reserve and asset management, which may be found here.
     
  10. The Live UK Sanctions Tracker has listed sanction designations under the Russia regulations since 22 February 2022, which may be found here.
     
  11. The Foreign Commonwealth and Development Office published a press release in relation to UK introducing new sanctions against Russia including ban on ships and fresh financial measures, which may be found here.
     
  12. The Foreign Commonwealth and Development Office published a travel alert, which may be found here.
     
  13. The Office of Financial Sanctions Implementation published updated Russia Guidance, which may be found here.
     

  14. The Foreign, Commonwealth & Development Office published a press release regarding UK imposing sanctions on Belarus for its role in the Russian invasion of Ukraine, which may be found here.
     

  15. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1298776 regarding the wind down of Positions with Sberbank, which may be found here.
     

  16. The Office of Financial Sanctions Implementation has amended General Licence INT/2022/1272278 relating to the wind down of positions with VTB Bank, which may be found here.
     

  17. The Office of Financial Sanctions Implementation has amended General Licence INT/2022/1277778 regarding correspondent banking relationships & processing sterling payments with Sberbank, which may be found here.
     

  18. The Foreign Commonwealth and Development Office published Russia Sanctions Guidance as of 8 March, 2022, which may be found here.
     

  19. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1381276 in relation to Central Bank of the Russian Federation (CBR), National Wealth Fund of the Russian Federation (NWF) and Ministry of Finance of the Russian Federation (MF) whereby a person may provide financial services for the purposes of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 1st March 2022 with the CBR, the NWF or the MF. The said General Licence may be found here.
     

  20. The Office of Financial Sanctions Implementation issued two (2) General Licences today, namely INT/2022/1424276 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 and INT/2022/1424277 under Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, which may be found here.
     

  21. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1438977 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  22. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1469378 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  23. The Office of Financial Sanctions Implementation issued a General Licence today, namely INT/2022/1495176 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, which may be found here.
     

  24. On 1 April 2022, OFSI amended General Licence INT/2022/1280876 (under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations ) to allow any payments in connection with the Insolvency Proceedings of the UK subsidiary of VTB. The General Licence can be found here.
     

  25. On 4 April 2022, General Licence INT/2022/1438977 was amended to permit persons or a relevant institution to process payments or transactions related to the sale and transfer of the Joint Venture’s shares by the DP. The General Licence can be found here.
     

  26. On 6 April 2022, OFSI issued General Licence INT/2022/1544176 which allows for a 30 day wind down period of positions involving Credit Bank of Moscow. Under General Licence INT/2022/1544176 a Person (other than the Designated Person (DP) or a Subsidiary) may wind down any transactions to which it is a party, involving the DPs or a Subsidiary including the closing out of any positions, and a Person, Relevant Institution, or the DPs or a Subsidiary can carry out any activity reasonably necessary to effect this. The General Licence can be found here.
     

  27. On 6 April 2022, General Licence INT/2022/1277877 was amended. Now that Sberbank is subject to an asset freeze under the Russia (Sanctions) (EU Exit) Regulations 2019, this amendment ensures that the General Licence in respect of energy related payments may continue to be used. The General Licence can be found here.
     

  28. On 12 April 2022, General Licence INT/2022/1438977 was revoked. This is following the sale of Russian Railways' stake in GEFCO to non-designated persons, meaning GEFCO is no longer impacted by UK sanctions. The sale was completed on 8 April 2022. See further details here.
     

  29. The Office of Financial Sanctions Implementation has amended General Licence INT/2022/1424276 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  30. The Office of Financial Sanctions Implementation has amended General Licence INT/2022/1630477 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  31. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1280876 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  32. OFSI has issued General Licence INT/2022/1679676 under Regulation 21 of the Global Anti-Corruption Sanctions Regulations 2021 and Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019.

    Under General Licence INT/2022/1679676, subject to the conditions set out in that licence, an officer of a Non-Crown Relevant Organisation is permitted to carry out their duties including through making use of powers available to them under UK legislation or common law for Asset Recovery Purposes. The licence can be viewed here.
     

  33. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1710676 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  34. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1678476 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  35. The Office of Financial Sanctions Implementation has amended General Licence INT/2022/1469378 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  36. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1839676 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  37. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1875276 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, which may be found here.
     

  38. General Licence INT/2022/1327076 issued by the Office of Financial Sanctions Implementation under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019, has expired. The update may be found here.
     

  39. The Office of Financial Sanctions Implementation has published an updated version of its enforcement and monetary penalty guidance, which may be found here.
     

  40. The Office of Financial Sanctions Implementation imposed a monetary penalty of £15,000 against Tracerco Limited, which may be found here.
     

  41. General Licence INT/2022/1968500 has been issued by the Office of Financial Sanctions Implementation under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulations, 2019. The update may be found here.
     

  42. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1976232 under the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022, which may be found here.
     

  43. The Office of Financial Sanctions Implementation has issued General Licence INT/2022/1976332 under the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022, which may be found here.
     

  44. The Office of Financial Sanctions Implementation issued General Licence INT/2022/1947936 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, which may be found here.
     
  45. In conjunction with OFSI, the JMLIT+ Sanctions Facilitators Cell, law enforcement, private industry and regulators, the National Crime Agency (NCA) have issued a 'Red Alert' on financial sanctions evasion typologies by Russian elites and enablers, which may be found here.
     
  46. On 20 July 2022, the Office of Financial Sanctions Implementation issued General Licence INT/2022/2002560 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, which may be found here.
     
  47. On 20 July 2022, to coincides with the Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 (the Amendment 12 Regulations) coming into force, the Office of Financial Sanctions Implementation update its Russia Guidance, which can be found here.
     
  48. On 22 July 2022, the Office of Financial Sanctions Implementation issued OFSI has issued General Licence INT/2022/2009156 - Payment to UK Insurance Companies for Building and Engineering Insurance, which can be found here.
     

  49. On 29 July 2022, the Office of Financial Sanctions Implementation extended general licence INT/2022/1968500 for a period of 2 months to the 30 September, allowing for the winding down of positions involving Rosbank, which may be found here.
     

  50. On 15 August 2022, the Office of Financial Sanctions Implementation issued General Licence INT/2022/2085212 under the Russia sanctions regulations allowing payments to sanctioned Russia banks for the purpose of making energy available for use in Mongolia, which may be found here.
     
  51. On 18 August 2022, the Office of Financial Sanctions Implementation amended General Licence INT/2022/2009156. This licence allows UK designated persons to make certain permitted payments to UK insurers from a frozen bank account, and allows UK insurers to receive these payments. The licence applies to all UK autonomous sanctions regimes, and can be found here. 
     
  52. On 18 August 2022, the Office of Financial Sanctions Implementation extended General Licence INT/2022/1710676 under regulation 64 of the Russia (Sanctions) (EU Exit) regulations 2019. This allows the continued business operations of Evraz' North American subsidiaries. This licence has now been extended until 31 March 2023 and can be found here.
     
  53. On 22 August 2022, the Office of Financial Sanctions Implementation issued General Licence INT/2022/1845976 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019. Under General Licence INT/2022/1845976, Crown Servants, Contractors, Family Members or Visiting Family Members may carry out activities in their personal capacity in Russia which would otherwise be prohibited by regulations 11-15 and 17A of the Russia Regulations. The licence can be found here.
     
  54. On 22 August 2022, the Office of Financial Sanctions Implementation a OFSI has issued General Licence INT/2022/2104808 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019. Under General Licence INT/2022/2104808, a bank is allowed to take payment of bank fees from frozen accounts. The licence can be found here.
     
  55. On 22 August 2022, the Office of Financial Sanctions Implementation amended General Licence INT/2022/1280876. This licence allows basic needs and other payments related to subsidiaries of designated Russian banks. It has been amended to include Guernsey subsidiary VTBC Asset Management International Limited and EU subsidiary VTB Bank (Europe) SE (VTBE) and any entity owned or controlled by VTBE incorporated in Germany, and can be found here.


Any person that fails or refuses to provide information to the Agency that it considers relevant to the performance of its functions commits an offence and is liable on summary conviction to a fine not exceeding twenty thousand dollars or to imprisonment for a term not exceeding two years or to both.

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