UK Sanctions and Export Controls

Financial Sanctions Notices

Her Majesty’s Treasury (“HMT”) issued two Financial Sanctions Notices, one prior to the invasion and one following, in which it designated five Russian banks, six Russian entities and 10 individuals described by the UK Foreign Secretary as “oligarchs at the heart of Putin’s inner circle and banks which have bankrolled the Russian occupation of Crimea.”[1] The listed individuals, banks and entities are now subject to asset freezes in accordance with the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855)[2] effective as at February 22, 2022. Included in these designations are:

VTB Bank PJSC, a Russian state-owned bank, and Denis Alexandrovich Bortnikov, whom HMT describes as Chairman of the Management Board of VTB Bank.
Bank Rossiya and Gennadiy Nikolayevich Timcenko, whom HMT describes as a major shareholder in Bank Rossiya.
Igor Arkadyevich Rotenberg, whom HMT describes as the Chairman of the Board of Directors of National Telematic Systems, which conducts business in the transport sector.
PJSC United Aircraft Corporation and Yury Borisovich Slyusar, whom HMT describes as the General Director of PJSC United Aircraft Corporation, which is alleged to contain all of Russia’s aircraft manufacturing companies.
Black Sea Bank for Development and Reconstruction and Joint Stock Company Genbank, which both operate in Crimea.
Public Joint Stock Company United Shipbuilding Company, which is described as the largest shipbuilder in Russia.
Russian President Putin and Russian Foreign Minister Sergei Lavrov.

Additional UK Sanctions

Following the invasion, the UK response was quickly scaled up with measures which Prime Minister Boris Johnson described as “the largest and most severe package of economic sanctions that Russia has ever seen.”[3] As announced, such measures are expected to include: (a) asset freezes on over 100 Russian individuals and entities, including major manufacturers and Russian banks, (b) the introduction of legislation to prevent Russian companies from raising funds in the UK, (c) limiting the amount of money that Russian nationals can deposit into bank accounts in the UK, (d) the development of a “Kleptocracy Unit” to target sanctions evasion, and (e) expediting plans to review Unexplained Wealth Orders under the Economic Crime Bill to identify Russian assets hidden in the UK.

It was also announced that sanctions would be ramped up against Belarus in relation to its role in facilitating the invasion, although further details are yet to be released.

The UK has begun the process of implementing these deterrents and measures; however, at the time of this writing, further details are anticipated within the coming days.

3. UK Export Controls

UK export controls were also ramped up with planned measures to: (a) suspend all dual-use export licenses to Russia, and (b) introduce new legislation to ban exports of all dual-use items to Russia in strategic industries, including electronics, telecommunications and aerospace, in an attempt to limit Russia’s ability to advance its military and aerospace sectors.

4. Aeroflot Foreign Carrier Permit

In other developments, the UK Civil Aviation Authority released a statement on February 24 that it has suspended the foreign carrier permit held by Aeroflot Russia Airlines (Aeroflot) until further notice.[4] No other Russian air carriers have received similar suspensions at the moment.

5. Wind-Down of Positions Involving VTB

Further to the designation of VTB Bank PJSC (see above), HMT has published a general license in relation to the winding down of any transactions involving VTB or its subsidiaries. The license provides a grace period until March 27, 2022 to close out any positions, including activities required to effect this.[5]

[1] See press release: U.S. Sanctions Against Belarus | Publications | Vedder Thinking | Vedder Price (onenorth.com)

[2] The Russia (Sanctions) (EU Exit) Regulations 2019 (legislation.gov.uk)

[3] See PM statement to the House of Commons on Ukraine: 24 February 2022: PM statement to the House of Commons on Ukraine: 24 February 2022 - GOV.UK (www.gov.uk)

[4] In retaliation, Russian civil aviation authorities have banned British carriers from Russian airspace.

[5] A copy of the license can be found here.