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Sanctions update: Automatic implementation in Jersey

jersey has implemented the sanctions and asset-freezing (automatic implementation of uk sanctions) (jersey) amendment order 2025 (the amendment order), which came into effect on 5 december 2025. this change ensures that prohibitions and obligations under uk sanctions listed in the sanctions order schedule 1 are automatically applied in jersey, streamlining the process and removing the need for future amendments. the minister for external relations retains the authority to modify or disapply specific sanctions. additionally, annual frozen asset reporting dates now align with jersey's financial year. this amendment ensures that jersey's sanctions framework remains aligned with the uk, reducing administrative delays, and ensuring swift compliance with international obligations. by adopting this automatic implementation approach, jersey demonstrates its commitment to maintaining an efficient and robust sanctions regime while preserving the flexibility to address local legislative needs. the sanctions legislation update can be found here and the sanctions and asset-freezing (automatic implementation of uk sanctions) (jersey) amendment order 2025 here

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FATF and CFATF October 2025: Jurisdiction updates and BVI's progress

the financial action task force (fatf) recently published its updated lists of jurisdictions with strategic deficiencies in anti-money laundering and counter-terrorism financing (aml/cft) measures. the "black list" identifies high-risk jurisdictions, including north korea, iran, and myanmar, which face enhanced due diligence and, in severe cases, countermeasures to safeguard the global financial system. the "grey list" includes countries under increased monitoring, such as algeria, kenya, and vietnam, which are actively working to address their aml/cft shortcomings. notably, burkina faso, mozambique, nigeria, and south africa have been removed from this list, reflecting their significant progress in implementing reforms. the bvi remains on the grey list; however, the caribbean financial action task force (cfatf), in its follow-up report, confirmed that the bvi is now rated as "compliant" or "largely compliant" with all 40 fatf recommendations. key improvements in the bvi the cfatf report highlights several key advancements made by the bvi to strengthen its aml/cft framework. these include: enhanced monitoring and risk-based supervision: improved oversight of financial institutions and designated non-financial businesses and professions (dnfbps) to ensure compliance with aml/cft standards. beneficial ownership transparency: better collection and maintenance of accurate and up-to-date beneficial ownership information to prevent misuse of legal entities. increased enforcement powers: the financial investigation agency (fia) has been granted greater authority to enforce sanctions effectively. in a press release, the bvi government welcomed the cfatf's findings, emphasising its commitment to maintaining a transparent and trusted financial services environment. for more details, explore the fatf’s official publication here, the cfatf’s follow-up report here, and the bvi government’s press release here.

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Cayman: CRS and CARF consultation updates

on 13 november 2025, the cayman islands ministry of financial services and commerce, following recent consultations on the amended common reporting standard (crs) and the new crypto-asset reporting framework (carf), published and acknowledged the valuable and constructive feedback provided by industry stakeholders. stakeholder input has been carefully considered in shaping the updated draft regulations for both frameworks. detailed consultation response documents have been published, summarising the key comments received, identifying a number of important deadlines that will take effect in 2026, and outlining the ministry’s position. cabinet approval will be sought to enact the finalised regulations. the crs consultation responses can be accessed here. the carf consultation responses can be accessed here.

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CSSF announces 2025 AML/CFT questionnaire and upcoming AMLA preparation

on 1 december 2025, the commission de surveillance du secteur financier (cssf) announced the launch of its 2025 annual aml/cft questionnaire on 23 february 2026. this initiative aims to gather standardised information on money laundering and terrorism financing risks faced by entities under cssf supervision, as well as the measures implemented to mitigate these risks. the questionnaire is a key component of the cssf's risk-based supervision approach for combating financial crime. key details: submission deadline: responses must be submitted via the cssf edesk platform by 3 april 2026. changes in 2025 questionnaire: updates and new questions have been incorporated, with changes clearly marked. responsibility for completion: the compliance officer in charge of the day-to-day compliance (rc) or the person responsible for overall compliance (rr) must ensure the questionnaire is completed. delegation to another employee or third party is permitted, but ultimate responsibility remains with the rc or rr. all involved must have an edesk account authenticated via luxtrust. api solution: the application programming interface (api) remains available for submissions, with a user guide accessible on the cssf website. additional ad hoc questionnaire: in the first half of 2026, the cssf will release an additional questionnaire targeting credit and financial institutions. this will collect data to assist the european anti-money laundering authority (amla) in selecting entities for direct supervision starting 1 january 2028. amla plans to directly oversee 40 entities, with the selection process occurring in 2027. entities are encouraged to ensure their edesk accounts are active to avoid connectivity issues. cssf’s press release can be found here

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Update to UK Sanctions on Russia-Ukraine-Belarus (up to 28 November 2025)

further to our blog post on uk russia sanctions, please find below an updated table of sanctions. table.instrument-table { table-layout: auto; border-collapse: collapse; width: 100%; max-width: 100%; margin-left: auto; margin-right: auto; margin-bottom: 10px; border: 1px solid #000000; overflow-x: auto; } table.instrument-table th, table.instrument-table td { border: 1px solid #000000; padding: 5px; vertical-align: top; } table.instrument-table thead tr { color: #ffffff; background-color: #3a5dae; } table.instrument-table tbody tr:nth-child(even) { background-color: #f1f1f1; /* light grey */ } table.instrument-table h5 { font-size: 1.15em; margin: 0; } table.instrument-table p { font-size: 14px; color: #000000; margin: 0; line-height: 1.6; } table.instrument-table a { color: inherit; text-decoration: underline; } table.instrument-table li { font-size: 14px; color: #000000; padding-top: 2px; line-height: 1.6; } table.instrument-table ul { list-style-type: square; } # name of instrument date published amends or implements? comes into force summary of key provisions 1 the russia (sanctions) (eu exit) (amendment) regulations 2022 10 february 2022 amends the russia (sanctions) (eu exit) regulations 2019 (2019 uk-russia regulations) 10 february 2022 the amendments broaden the categories of people and entities which are capable of being designated under the sanctions regime in the 2019 regulations. no new designations have actually occurred and the motivation for the amendments is of course the current threat of invasion by russia into ukraine’s sovereign territory. see further our blog post here. 2 financial sanctions notice 22 february 2022 implemented under the 2019 uk-russia regulations 22 february 2022 the following are added to the uk consolidated list and are subject to an asset freeze: gennadiy timchenko boris romanovich rotenberg igor arkadyevich rotenberg bank rossiya black sea bank for development and reconstruction jsc genbank is bank pjsc promsvyazbank as a result, uk and bots individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and 2individuals. additionally, the designated individuals are banned from entering the uk. 3 financial sanctions notice 24 february 2022 implemented under the 2019 uk-russia regulations 24 february 2022 the following are added to the uk consolidated list and are subject to an asset freeze: kirill shamalov petr fradkov denis bortnikov yury slyusar elena aleksandrovna georgieva rostec uralvagonzavod tactile missile corporation united aircraft corporation united shipbuilding corporation as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. additionally, the designated individuals are banned from entering the uk. 4 financial sanctions notice (2) 24 february 2022 implemented under the 2019 uk-russia regulations 24 february 2022 additionally makes the following entities, which were subject to sectoral sanctions, additionally subject to asset freeze: vtb bank (but subject to a general licence (gl) for wind down) uralvagonzavod united aircraft corporation 5 uk government announcement 24 february 2022 [to be implemented via amendments to 2019 uk-russia regulations] on-going the following further sanctions and measures announced by the uk government include: new legislation that aims to exclude all major russian banks from the uk banking system. this means they will not be able to clear payments through the uk nor will they be able to access gbp new legislation also seeks to freeze the assets of all major russian banks, including vtb bank obstructing major russian companies and the state from the uk markets (financing), also through the introduction of new legislation 100 new individuals or entities will be added to the uk’s sanctions list aeroflot will be banned from landing in the uk all dual use export licences to cover components which can be used for military purposes have been suspended with immediate effect the uk will stop exports of high-tech items and oil refinery equipment in the next few days there will be a limit of £50,000 on deposits russians can make into a uk bank account removing russia out of the swift international payment system, which has been supported by the european union and the us similar financial sanctions will be extended to belarus for its role in the assault on ukraine. 6 financial sanctions notice 25 february 2022 implemented under 2019 uk-russia regulations 25 february 2022 the following are added to the consolidated list and are now subject to an asset freeze: vladimir putin sergei lavrov as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. additionally, the designated individuals are banned from entering the uk. 7 general licence int/2022/1272278 (vtb) 25 february 2022 issued under regulation 64 of 2019 uk-russia regulations takes effect from 25 february 2022 expires on 27 march 2022 importantly, on 25 february 2022, the uk’s office of financial sanctions implementation announced the publication of a new russia-related general licence allowing for a 30 day wind down of positions involving vtb bank. general licence int/2022/1272278 provides that any person may wind down any transaction to which it is a party which involve vtb bank or vtb capital plc (and any entity owned or controlled by vtb capital plc incorporated in the uk) , including the closing out of any positions. the gl does not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting will result in funds or economic resources being dealt with or made available in breach of the 2019 uk-russia regulations, save for the specific permission mentioned above. the gl will expire on 27 march 2022. 8 russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2022 28 february 2022 amends the 2019 uk-russia regulations 1 march 2022 existing restrictions on dealing with certain financial instruments and providing loans and credit are amended to extend the sanctions prohibitions to a broader range of transferable securities and money market instruments and loans and credit. further restrictions on correspondence banking relationships and processing of sterling payments are also introduced. introduction of power for the secretary of state to designate persons for the purpose of that provision. the regulations provide for exceptions to, and for licensing powers in relation to, those prohibitions. in particular, there is provision to make clear that a licence may authorise acts which would otherwise be prohibited by any of the regulations for a particular period beginning with the coming into force of the prohibition, or the date of any designation made for the purposes of those provisions. this would allow a period for persons affected to arrange their affairs to comply. 9 russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2022 28 february 2022 amends the 2019 uk-russia regulations 1 march 2022 these regulations provide for significantly enhanced trade sanctions measures in relation to russia: prohibitions on the export, supply and delivery and making available of military goods are extended to include dual use goods and"critical industry" goods prohibitions on the making available and transfer of military technology are extended to include dual use technology and critical industry technology related prohibitions on the provision of technical assistance, financial services, funds and brokering services are also extended in relation to dual use goods and technology and critical industry goods and technology a number of exceptions from the trade prohibitions on critical-industry goods and technology are provided for as well as licensing arrangements. 10 uk statement on further economic sanctions targeted at the central bank of the russian federation 28 february 2022 [to be implemented via amendments to 2019 uk-russia regulations] on-going additional measures were announced on 28 february 2022 which will introduce a prohibition on uk persons undertaking financial transactions involving the central bank of russia, the russian national wealth fund and the ministry of finance of the russian federation and the uk government announced that it will immediately take all necessary steps to bring into effect restrictions. other points to note include: restrictions on russian financial institutions – vtb bank was designated by the uk last week, along with five other russian banks and it is not yet known what additional financial institutions may be subjected to restrictions restrictions to prevent russian companies from issuing transferable securities and money market instruments in the uk, in addition to the restrictions on the russian state raising sovereign debt powers to prevent designated banks from accessing sterling and clearing payments through the uk additional trade restrictions, including a prohibition on the export of certain high-end critical technical equipment and components in sectors including electronics, telecommunications and aerospace. the announcement reiterated that trade restrictions applicable to crimea will be extended to apply to donetsk and luhansk. 11 financial sanctions notice 28 february 2022 implemented under 2019 uk-russia regulations 28 february 2022 the following persons have been added to the uk asset freeze list: veb.rf bank otkritie financial corporation pjsc pjsc sovcombank as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. 12 the russia (sanctions) (eu exit) (amendment) (no. 4) regulations 2022 1 march 2022 amends 2019 uk-russia regulations 1 march 2022 the regulations prohibit russian ships, and other ships specified by the secretary of state, from entering ports in the uk there is a notification and publicity requirement where the specification power is used. the regulations provide the secretary of state with a power to control the movement of russian ships or specified ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are. the regulations also confer powers on the secretary of state and harbour authorities to detain russian ships or specified ships at ports or anchorages. the registration of ships on the uk ship register is prohibited where they are owned, controlled, chartered or operated by a designated person or persons connected with russia, or where they are a specified ship. 13 financial sanctions notice 1 march 2022 implemented under 2019 uk-russia regulations 1 march 2022 the following entity is subject to enhanced restrictive measures: pjsc sberbank whilst not subject to an asset freeze, it is subject to a prohibition on correspondent banking and sterling clearing. 14 financial sanctions notice 1 march 2022 implemented under 2019 uk-russia regulations 1 march 2022 the following persons have been added to the uk asset freeze list: andrei burdyko victor vladimirovich gulevich sergei simonenko andrey zhuk jsc 558 aircraft repair plant jsc integral as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. additionally, the designated individuals are banned from entering the uk. 15 the russia (sanctions) (eu exit) (amendment) (no. 5) regulations 2022 1 march 2022 amends 2019 uk-russia regulations 1 march 2022 prohibits the provision of financial services for the purpose of foreign exchange reserve and asset management to: the central bank of the russian federation the national wealth fund of the russian federation the ministry of finance of the russian federation an entity owned or controlled by, or acting on behalf/at the direction of, the above 3 entities 16 russia: regulatory authorities – prudential supervision or financial stability (notice) general license int/2022/1280976 1 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 1 march 2022 the licence pertains to vtb capital plc and any entity owned or controlled by vtb capital plc incorporated in the united kingdom. the licence relates to prudential supervision or protecting, maintaining or enhancing the stability of the financial system of the united kingdom. the licence takes effect from 1 march 2022 and expires on 1 march 2023. 17 russian banks – uk subsidiaries – basic needs, routine holding and maintenance and the payment of legal fees" (notice) general license int/2022/1280876 1 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 1 march 2022 the licence pertains to vtb capital plc and any entity owned or controlled by vtb capital plc incorporated in the united kingdom. the licence allows for the basic needs of uk subsidiaries and routine holding and maintenance of uk subsidiaries frozen funds or economic resources and the payment of legal fees. notifications requirements will need to be complied with. record keeping requirements will also need to be complied with. the licence took effect from 1 march 2022 and expires on 1 march 2023. 18 financial sanctions notice 3 march 2022 implemented under 2019 uk-russia regulations 3 march 2022 the following persons have been added to the asset freeze and travel ban list: alisher usmanov igor shuvalov 19 wind down of positions involving various designated banks general license int/2022/1295476 4 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 4 march 2022 the designated persons under the licence are: bank otkritie promsvyazbank bank rossiya sovcombank vnesheconombank (veb) subsidiaries (entities owned or controlled) of any of the above are also within scope of the licence. the licence allows persons to wind down any transactions to which the person is a party involving any of the designated persons (including jscb novikombank) and their subsidiaries. the licence takes effect from 4 march and expires on 3 april 2022. 20 general licence – wind down of positions sberbank general license int/2022/1298776 4 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 4 march 2022 the designated person under the licence is pjsc sberbank, including any subsidiary (an entity owned or controlled by pjsc sberbank). the licence allows that a person may provide financial services to sberbank for the purposes of winding down that activity. the licence takes effect from 4 march and expires on 3 april 2022. 21 financial sanctions notice 4 march 2022 implemented under 2019 uk-russia regulations 4 march 2022 the notice is to issue a correction to an entry on the consolidated list brining the entry into line with the uk sanctions list. igor ivanovich shuvalov (group id: 14209) is still subject to an asset freeze. 22 updated russia guidance 4 march 2022 guidance for the financial and investment restrictions in russia (sanctions) (eu exit) regulations 2019 4 march 2022 the office of financial sanctions is the competent authority responsible for improving the understanding, implementation and enforcement of financial sanctions in the uk. this guidance sets out an overview of the sanctions regime on russia to date. 23 general licence – wind down of positions involving vtb general license int/2022/1272278 7 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 7 march 2022 the designated person under the licence is vtb bank and subsidiary entity owned or controlled by vtb bank. the licence allows that a person may provide financial services to vtb bank for the purposes of winding down that activity. the licence took effect from 25 february and expires on 27 march 2022. 24 the russia (sanctions) (eu exit) (amendment) (no. 6) regulations 2022 8 march 2022 amends 2019 uk-russia regulations 8 march 2022 these regulations provide for new aviation and trade sanctions measures in relation to russia. the regulations confer powers on the secretary of state, air traffic control and airport operators to prevent russian aircraft from entering the airspace, landing in or requiring aircraft to leave the airspace of the united kingdom. an exception from the prohibitions is when the lives of persons and the safety of the aircraft are in danger. 25 general licence: provision of navigational data to civilian aircrafts for flight safety general licence int/2022/1322576 9 march 2022 this licence is granted under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 (the belarus regulations). 9 march 2022 this licence pertains to provision of navigational data to civilian aircrafts for flight safety. records must be kept by flight data providers for up to 6 years. the licence takes effect on 9 march 2022 and is of indefinite duration. 26 financial sanctions notice 10 march 2022 implemented under 2019 uk-russia regulations 10 march 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: roman arkadyevich abramovich igor ivanovich sechin oleg vladimirovich deripaska dmitri alekseevich lebedev alexei borisovich miller andrei leonidovich kostin nikolai petrovich tokarev 27 general licence – football matches general licence int/2022/1327076 10 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 10 march 2022 this licence pertains to football matches and covers, who can be paid by the clubs and for what purposes. persons will be required under this licence to keep accurate, complete and readable records of any activity purporting to have been permitted under the licence with a value exceeding £5,000 for a minimum of 6 years. the licence takes effect from 10 march 2022 and expires on 31 may 2022. 28 financial sanctions notice 11 march 2022 implemented under 2019 uk-russia regulations 11 march 2022 386 individuals have been designated on the uk sanctions list and are now subject to an asset freeze. 29 financial sanctions notice 15 march 2022 implemented under 2019 uk-russia regulations 15 march 2022 350 individuals have been designated on the uk sanctions list and are now subject to an asset freeze. the following entries have been amended and are still subject to an asset freeze: anatoly borisovich vyborny aleksei mikhailovich chaliy 30 financial sanctions notice 15 march 2022 implemented under 2019 uk-russia regulations 15 march 2022 the following entries have been designated on the uk sanctions list and are now subject to an asset freeze: armen sumbatovich gasparyan suleyman abusaidovich kerimov tigray organesovich khudaverdyan dmitry yevgenevich kulikov alexey viktorovich kuzmichev alexander alexandrovich mikheev vladimir valerievich rashevsky viktor filippovich rashnikov andrey valerievich ryumin marina vladimirovna sechina artyom grigoryevich sheynin alexander nikolayevich shokhin rosneft aero jsc zelenodolsk shipyard the following entries have been amended and are still subject to an asset freeze: yulia vasilievna ogloblina anatoly vladimirovich voronovsky mikhail nikolaevich berulava oleg dmitrievich dimov sergei mikhailovich sokol tatyana ivanovna dyakonova dmitri alekseevich lebedev anatoly alexandrovich wasserman 31 financial sanctions notice 18 march 2021 implemented under 2019 uk-russia regulations 18 march 2021 the following entries have been corrected and are still subject to an asset freeze: fridman mikhail maratovic aven petr olegovich khan german borisovich tatarchenko denis sergeyevich nezhdanova yevgeniya vitalyevna ignatova ekaterina sergeevna shuvalova maria igorevna kolokoltsev vladimir puchkov andrey sergeevich shchegolev igor olegovich enberg liliya arkadyevna rotenberg roman borisovich shuvalov evgeny igorevich prigozhin pavel evgenyevich krans maksim iosifovich solovyov yuri alekseyevich rotenberg pavel arkedyevich rashnikov viktor filippovich kravchenko vladimir kasimirovich lobach tatyana kiriyenko vladimir sergeevich ulyutina galina volfovich aleksandr grigorievich bolotova maiya nikolaevna 32 general licence – wind down of derivatives, repurchase, and reverse repurchase transactions general licence int/2022/1381276 22 march 2022 implemented under 2019 uk-russia regulations 22 march 2021 for the purposes of this general licence the entities referred to consist of the: central bank of the russian federation (cbr) national wealth fund of the russian federation (nwf) ministry of finance of the russian federation (mf) under general licence int/2022/1381276 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. a person or relevant institution, can carry out any activity reasonably necessary to effect this. 33 updated financial sanctions general guidance 22 march 2022 22 march 2022 new paragraph (4.14) added to the ownership and control subject and clarifies ofsi's position on aggregation and reads as follows: "when making an assessment on ownership and control, ofsi would not simply aggregate different designated persons’ holdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated parties or one party controls the rights of another. consequently, if each of the designated person's holdings falls below the 50% threshold in respect of share ownership and there is no evidence of a joint arrangement or that the shares are held jointly, the company would not be directly or indirectly owned by a designated person. it should be noted that ownership and control also relates to holding more than 50% of voting rights, the right to appoint or remove a majority of the board of directors and it being reasonable to expect that a designated person would be able in significant respects to ensure that the affairs of a company are conducted in accordance with their wishes. if any of these apply, the company could be controlled by a designated person." 34 financial sanctions notice belarus 24 march 2021 implemented under 2019 belarus (sanctions) (eu exit) regulations 24 march 2022 the following entries have been added to the consolidated list and are subject to an asset freeze: bank dabrabyt joint stock company cjsc belbizneslizing ( industrial-commercial private unitary enterprise minotor-service jsc transviaexport airlines limited liability company belinvest-engineering ojsc kb radar-managing company holding radar system 35 financial sanctions notice russia 24 march 2022 implemented under 2019 uk-russia regulations 24 march 2022 33 individuals and 26 entities have been designated on the uk sanctions list and are now subject to an asset freeze. 36 general licence – wind down of positions involving various designated banks general license int/2022/1424276 24 march 2022 implemented under 2019 uk-russia regulations 24 march 2022 under this license, the designated persons (dps) are: alfa bank jsc gazprombank rosselkhozbank smp bank ural bank for reconstruction and development subsidiaries of the dps the gl permits a person (other than the dps or a subsidiary) to wind down any transactions to which it is party including the closing out of positions. a person, relevant institution, or the dps or a subsidiary, can carry out any activity reasonably necessary to effect this. 37 general licence – wind down of positions involving bank dabrabyt general license int/2022/1424277 24 march 2022 implemented under 2019 belarus (sanctions) (eu exit) regulations 24 march 2022 this license allows a person to wind down any transactions to which it is party including the closing out of positions with bank dabrabyt joint stock company or its subsidiaries. 38 amended general licence - wind down of derivatives, repurchase, and reverse repurchase transactions with the central bank of the russian federation, national wealth fund of the russian federation and ministry of finance of the russian federation general license int/2022/1381276 24 march 2022 implemented under 2019 uk-russia regulations 24 march 2022 the amendment clarifies that: "under general licence int/2022/1381276 a person may provide financial services for the purposes of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 1 march 2022 with the cbr, the nwf or the mf or those persons set out in regulation 18a d to e of the russia regulations. a person or relevant institution can carry out any activity reasonably necessary to effect this." 39 financial sanctions notice 25 march 2022 implemented under 2019 uk-russia regulations 25 march 2022 the following entry has been amended and is still subject to an asset freeze: sovcomflot also the following entries have been corrected: oleg yurievich tinkov eugene markovich shvidler 40 general licence – continuation of business and basic needs of gefco uk subsidiaries general license int/2022/1438977 note: this has since been revoked, see row 54 below for more details. 25 march 2022 implemented under 2019 uk-russia regulations 25 march 2022 under this license the designated entity is russian railways. the joint venture is gefco, a joint venture owned by russian railways and stellantis, gefco s.a rue jean jaures, 20-22, 92800 puteaux, france. a subsidiary is any entity owned or controlled by the designated entity, including: gefco uk ltd gefco forwarding uk auto xp limited xp tech limited under this licence a person may continue business operations involving the joint venture or its subsidiaries including, but not limited to: payments to or from the joint venture or its subsidiaries under any obligations or contracts; payments to or from any third party necessary to the continuation of any obligations or contracts. 41 general licence – wind down of positions involving sovcomflot general license int/2022/1469378 29 march 2022 implemented under 2019 uk-russia regulations 29 march 2022 under this license the designated entity is sovcomflot. a subsidiary is any entity owned or controlled by the designated entity. this licence allows a person (other than the designated entity or a subsidiary) to wind down any transactions to which it is party involving the designated entity or a subsidiary including the closing out of any positions. 42 the russia (sanctions) (eu exit) (amendment) (no. 7) regulations 2022 30 march 2022 amends 2019 uk-russia regulations 30 march 2022 these amendments introduce a power to designate persons by description, extend existing finance, trade and shipping sanctions measures in relation to crimea and sevastopol to the non-government controlled areas of the donetsk and luhansk oblasts of ukraine. the amendments introduce prohibitions on technical assistance relating to aircraft and ships, for the purposes set out in regulation 4 of the 2019 regulations. 43 updated russia guidance 31 march 2022 amends 2019 uk-russia regulations 31 march 2022 this guidance has been updated to reflect extending the financial restrictions in place to all non-government controlled ukrainian territory. 44 financial sanctions notice 31 march 2022 implemented under 2019 uk-russia regulations 31 march 2022 14 entries (12 individuals and 2 entities) have been added to the consolidated list and are now subject to an asset freeze. 45 financial sanctions notice 31 march 2022 implemented under 2019 uk-russia regulations 31 march 2022 under this license, the following entities have been added to the consolidated list and are now subject to an asset freeze. photon pro llp majory llp djeco group lp 46 general licence – payments by the central bank of the russian federation, the national wealth fund of the russian federation, or the ministry of finance of the russian federation related to debt issued by them before 1 march 2022. general license int/2022/1495176 1 april 2022 implemented under 2019 uk-russia regulations 1 april 2022 under this licence, a person may provide financial services for the purposes of the receipt and onward transfer of non-rouble denominated interest/coupon or maturity/principal payments from the central bank of the russian federation, the national wealth fund of the russian federation, or the ministry of finance of the russian federation (or those persons set out in regulation 18a (2) (d) - (e) of the russia regulations) in connection with debt issued by them before 1 march 2022. a person or relevant institution can carry out any activity reasonably necessary to effect this. 47 financial sanctions notice 4 april 2022 implemented under 2019 uk-russia regulations 4 april 2022 this entry has been amended and is still subject to an asset freeze: andrey anatolyevich turchak 48 financial sanctions notice 5 april 2022 implemented under 2019 uk-russia regulations 5 april 2022 this entry has been amended and is still subject to an asset freeze: wagner group 49 financial sanctions notice 6 april 2022 implemented under 2019 uk-russia regulations 6 april 2022 10 entries have been added to the consolidated list and are now subject to an asset freeze: individuals listed: ivanov sergei sergeivich rotenberg, boris borisovich akimov, andrey igorevich dyukov, alexander valeryevich kogogin, sergey anatolyevich guryev, andrey grigoryevich mikhelson, leonid viktorovich kantor, viatcheslav entities listed: credit bank of moscow pjsc sberbank (public joint-stock company sberbank) the following entries have been amended and are still subject to an asset freeze: gazprombank russian agricultural bank public joint stock company"united aircraft corporation jsc research and production corporation uralvagonzavod veb.rf vtb bank (public joint-stock company) 50 general licence –wind down of positions involving credit bank of moscow general license int/2022/1544176 6 april 2022 implemented under 2019 uk-russia regulations 6 april 2022 under this general licence 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. 51 general licence: asset freeze, correspondent banking relationships & processing amended general license int/2022/1277877 6 april 2022 implemented under 2019 uk-russia regulations 6 april 2022 this general licence has been 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. 52 financial sanctions notice 8 april 2022 implemented under 2019 uk-russia regulations 8 april 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: katerina vladimirovna tikhonova maria vladimirovna vorontsova yekaterina sergeyevna vinokurova further, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: evgeny alekseevich fedorov 53 financial sanctions notice 11 april 2022 implemented under 2019 uk-russia regulations 11 april 2022 the following entries have been amended and are still subject to an asset freeze: evgeny alekseevich fedorov tigran organesovich khudaverdyan katerina vladimirovna tikhonova 54 general licence – continuation of business and basic needs of gefco uk subsidiaries revoked general license int/2022/1438977 12 april 2022 implemented under 2019 uk-russia regulations 12 april 2022 this general license has been 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. 55 financial sanctions notice russia 13 april 2022 implemented under 2019 uk-russia regulations 13 april 2022 206 entries have been added to the consolidated list and are now subject to an asset freeze. 56 financial sanctions notice belarus 13 april 2022 implemented under 2019 belarus (sanctions) (eu exit) regulations 13 april 2022 9 individuals have been corrected to the consolidated list and are still subject to an asset freeze: azarenok grigoriy yurievich eismont natalia nikolayevna ipatau vadzim dzmitryevich hustyr yulia chaslavauna kalinousky siarhei aliakseevich kasyanchyk alina sergeevna lukashenko viktor aliaksandravich sakalouski ivan yurievich yarmoshina lidzia mihailauna 57 financial sanctions notice 14 april 2022 implemented under 2019 uk-russia regulations 14 april 2022 the following individuals have been added to the consolidated list and are now subject to an asset freeze: eugene tenenbaum david davidovich 58 the russia (sanctions) (eu exit) (amendment) (no. 8) regulations 2022 14 april 2022 amends 2019 uk-russia regulations 14 april 2022 this instrument provides for a number of trade restrictions. these include: to prohibit the export, supply and delivery, making available and transfer of quantum computing and advanced materials-related goods and technology to, or for the use in, russia, or to a person connected with russia (as well as related technical assistance, financial services, funds and brokering services); to prohibit the export, supply and delivery, making available and transfer of oil refining goods and technology (including oil catalysts) to, or for use in, russia, or to a person connected with russia (as well as, where appropriate, related technical assistance, financial services, funds and brokering services). to prohibit the export of export, supply, delivery, making available and transfer of certain luxury goods, to, or for use in, russia, or to a person connected with russia. 3 7.7 this instrument also amends the 2019 regulations to introduce a new prohibition on the import, acquisition, supply and delivery of certain iron and steel products originating in or consigned from russia. the purpose of this measure is to limit russia’s exporting capability in a major market. 7.8 the instrument also makes amendments to the 2019 regulations to provide for exceptions from these measures, licensing and enforcement, including the expansion of criminal offences. 59 notice nte 2022/14: introduction of additional sanctions against russia 14 april 2022 implemented under 2019 uk-russia regulations 14 april 2022 this notice is giving guidance on the new trade sanctions on russia by the newly issued russia (sanctions) (eu exit) (amendment) (no. 8) regulations 2022. see line 58. 60 notice 2953: russia import sanctions 14 april 2022 implemented under 2019 uk-russia regulations 14 april 2022 updated notice to provide an overview of the import prohibitions on certain goods imported into the uk and sets out the licensing process for traders looking to import goods subject to prohibitions 61 financial sanctions notice russia 21 april 2022 implemented under 2019 uk-russia regulations 21 april 2022 26 entries have been added to the consolidated list and are now subject to an asset freeze and 30 entries have been amended and are still subject to an asset freeze. 62 general licence: gazprombank energy payments general license int/2022/1630477 21 april 2022 implemented under 2019 uk-russia regulations 21 april 2022 under this general licence a person may continue to make payments to gazprombank or a subsidiary under a contract entered into prior to the date of this licence for the purpose of making gas available for use in the european union and a person, relevant institution, or gazprombank, or a subsidiary can carry out any activity reasonably necessary to effect this including the opening and closing of bank accounts. a person making payments under this licence must keep accurate, complete and readable records,on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years. 63 general licence - russian banks – uk subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments amended general license int/2022/1280876 22 april 2022 implemented under 2019 uk-russia regulations 22 april 2022 this general licence has been amended to also include sberbank cib (uk) ltd. 64 financial sanctions notice 26 april 2022 implemented under 2019 uk-russia regulations 22 april 2022 195 entries have been amended and 2 entries corrected under the russia financial sanctions regime and remain subject to an asset freeze. 65 general licence: law enforcement and regulatory authorities asset recovery general licence - int/2022/1679676 27 april 2022 implemented under 2019 uk-russia regulations 27 april 2022 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. 66 the russia (sanctions) (eu exit) (amendment) (no. 9) regulations 2022 29 april 2022 amends 2019 uk-russia regulations 29 april 2022 this instrument is made under the sanctions and anti-money laundering act 2018 (‘the sanctions act’) to make amendments to the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (‘the 2019 regulations’). these amendments will introduce new trade sanctions measures relating to internet services and online media services, for the purposes set out in regulation 4 of the 2019 regulations. this instrument amends part 5 (trade) of the 2019 regulations, which contains trade sanctions measures, and makes related consequential amendments. this instrument provides for a number of restrictions in the form of trade in services sanctions. it introduces requirements that: social media services, including video sharing platforms, must take reasonable steps to prevent content that is generated directly on the service, or uploaded to or shared on the service, by a designated person being encountered by a user of the service in the united kingdom. internet access services, including fixed and wireless broadband providers, must take reasonable steps to prevent users of the service in the united kingdom from accessing websites provided by a designated person. this will likely take the form of url blocking. application stores, including those on smartphones, must take reasonable steps to prevent users of the application store in the united kingdom from downloading or otherwise accessing an application provided by a designated person. the instrument confers powers on the secretary of state to designate persons to whom these online restrictions will apply. the instrument also confers on the office of communications (ofcom) the power to impose civil monetary penalties on a person who fails to comply with the new trade sanctions. failing to comply with the new sanctions is also a criminal offence. 67 financial sanctions notice 04 may 2022 implemented under 2019 uk-russia regulations 04 may 2022 63 entries have been added to the consolidated list and are now subject to an asset freeze. the following 2 entries have been amended and are still subject to an asset freeze: rossiya segodnya tv-novosti 68 general licence – continuation of business of evraz plc’s north american subsidiaries general licence - int/2022/1710676 05 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 05 may 2022 under general licence int/2022/1710676, a person may continue business operations involving the north american subsidiaries of evraz including but not limited to payments to or from the north american subsidiaries under any obligations or contracts; payments to or from any third party under any obligations or contracts; and receipt of payments made by the north american subsidiaries for audit services. evraz north america plc is also permitted to pay for the audit services referred to in the previous sentence. 69 financial sanctions notice 05 may 2022 implemented under 2019 uk-russia regulations 05 may 2022 the following entry has been added to the consolidated list and is now subject to an asset freeze: evraz plc 70 financial sanctions notice 09 may 2022 implemented under 2019 uk-russia regulations 09 may 2022 88 entries have been amended on the consolidated list and still subject to an asset freeze. 71 general licence – amsterdam trade bank n.v – winding down, basic needs and insolvency related payments general licence - int/2022/1678476 12 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 12 may 2022 under general licence int/2022/1678476, there are provisions relating to winding down, basic needs and insolvency related payments in connection with amsterdam trade bank n.v 72 financial sanctions notice 13 may 2022 implemented under 2019 uk-russia regulations 13 may 2022 12 entries have been added to the consolidated list and are now subject to an asset freeze. furthermore, 10 entries have been amended and remain subject to an asset freeze. 73 financial sanctions notice 19 may 2022 implemented under 2019 uk-russia regulations 19 may 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: jsc rossiya airlines jsc ural airlines pjsc aeroflot 74 general licence – russian travel 23 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 23 may 2022 under this licence, subject to the conditions below: a united kingdom person may purchase tickets from a designated person or any subsidiary for flights or rail journeys originating in, or within, russia. a united kingdom person, relevant institution or designated person may carry out any activity reasonably necessary to effect the purchase of tickets for flights or rail journeys in accordance with paragraph above. 75 financial sanctions notice 24 may 2022 implemented under 2019 uk-russia regulations 24 may 2022 63 entries have been amended and are still subject to an asset freeze. 76 financial sanctions notice belarus 27 may 2022 implemented under 2019 belarus (sanctions) (eu exit) regulations 27 may 2022 6 entries have been amended under the belarus regime and are still subject to an asset freeze. 77 financial sanctions notice russia 27 may 2022 implemented under 2019 uk-russia regulations 27 may 2022 299 entries have been amended under the russia regime and are still subject to an asset freeze. 78 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 may 2022 under general licence int/2022/1875276, business operations involving the provision of civilian telecommunication services that include zao transtelecom company, can continue subject to the conditions contained in the licence. the licence also permits business operations related to news media services to continue subject to certain conditions. 79 general licence – russia designated persons – charities and interim managers and trustees general licence - int/2022/1834876 30 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 may 2022 general licence – int/2022/1834876, allows for interim managers and trustees to act as receiver(s) and manager(s) in respect of the property and affairs of a charity, as specified in this general licence. the full details of the permissions and usage requirements can be found within the general licence, here and the publication notice here. 80 guidance trading under sanctions with russia 08 june 2022 implemented under 2019 uk-russia regulations 08 june 2022 this guidance is issued to advise what import and export restrictions apply due to sanctions for uk companies when trading with russia. 81 general licence – funds of non-designated third parties involving designated credit or financial institutions general licence - int/2022/1919908 10 june 2022 implemented under regulation 64 of 2019 uk-russia regulations 10 june 2022 under general licence int/2022/1919908: subject to the conditions set out in the licence a person may make use of the retail banking services of a designated credit or financial institution provided that the payments made or received are intended for the personal use of a person; during the period from the date of issue to the date of expiry (inclusive), a person may only make payments in accordance with paragraph 4.1 of the licence provided that the total value of such payments made by the person does not exceed £50,000; and a relevant institution may process payments made in accordance with the permissions above provided that the total value of such payments processed by that relevant institution during the period from the date of issue to the date of expiry (inclusive) in respect of a person does not exceed £50,000. reporting requirement - general licence int/2022/1919908 includes a reporting requirement that within 14 days of processing a payment in accordance with paragraphs 4.1 and 4.3 of the licence, a relevant institution must report to hm treasury, with details and supporting evidence of: the amount(s) processed; the payment route used; and the date on which the funds were processed. 82 guidance russia sanctions: notes on designations data 10 june 2022 implemented under 2019 uk-russia regulations 10 june 2022 this guidance note is published to explain how the uk government collates this data on designations and what it means. 83 financial sanctions notice 14 june 2022 implemented under 2019 uk-russia regulations 14 june 2022 39 entries have been amended to the consolidated list and are still subject to an asset freeze. further information can be found in the annex of the notice. 84 financial sanctions notice 16 june 2022 implemented under 2019 uk-russia regulations 16 june 2022 12 entries have been added to the consolidated list and are now subject to an asset freeze. further information can be found in the annex of the notice. 85 the russia (sanctions) (eu exit) (amendment) (no.10) regulations 2022 22 june 2022 amends 2019 uk-russia regulations 23 june 2022 the regulations and the notice 2022/18 adopted further trade sanctions, that include; prohibitions on the export, supply and delivery, making available and transfer (as well as related technical assistance, financial services, funds and brokering services) of: internal repression goods and technology goods and technology relating to chemical and biological weapons maritime goods and technology additional oil refining goods and technology additional critical industry goods and technology prohibitions on the export to, or for use in russia of jet fuel and fuel additives, as well as prohibitions on the making available, export, and supply, directly or indirectly, of such products to russia or for use in russia (as well as related technical assistance, financial services, funds, and brokering services). prohibitions on the export to, or for use in, russia, of sterling or eu denominated banknotes; as well as prohibitions on the making available, supply, or delivery of such banknotes to a person connected with russia; and on the making available of such banknotes for use in russia. some of the above prohibitions will relate to russia, and the non-government controlled ukraine territories. prohibitions on the import, acquisition or supply and delivery of revenue generating goods that originate in or are consigned from russia (as well as related technical assistance, financial services, funds, and brokering services. prohibitions on the provision of technical assistance, and financial services, funds, and brokering services relating to iron and steel imports. 86 financial sanctions notice 24 june 2022 implemented under 2019 uk-russia regulations 24 june 2022 58 entries have been amended and 1 entry corrected and remain subject to an asset freeze. further information can be found in the annex of the notice. 87 financial sanctions notice 29 june 2022 implemented under 2019 uk-russia regulations 29 june 2022 13 entries have been added and are now subject to an asset freeze. 1 entry has also been corrected under and remains subject to an asset freeze. 88 general licence – wind down of positions involving rosbank general licence - int/2022/1968500 30 june 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 june 2022 general licence int/2022/1968500 allows for a 30 day wind down period of positions involving rosbank pjsc (rosbank) or any entity owned or controlled by rosbank. 89 financial sanctions notice 4 july 2022 implemented under 2019 uk-russia regulations 4 july 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: aleyona anatolyevna chuguleva yuriy sergeyevich fedin darya aleksandrovna dugina yevgeniy eduardovich glotov aelita leonidovna mamakova mikhail anatolyevich sinelin united world international furthermore, 45 entries have been amended and 1 entry corrected under the russia regime. further information can be found in the annex to this notice. 90 general licence – financial services regarding wind down of derivatives, repurchase, and reverse repurchase transactions with the national bank of belarus, and ministry of finance of belarus. general licence - int/2022/1976232 5 july 2022 regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 ("the belarus regulations") 5 july 2022 this general licence allows a period of until 04 august 2022 for a person to provide financial services for the purpose of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 05 july 2022 involving: national bank of belarus (nbb); ministry of finance of belarus (mf); and those persons set out in regulation 15ca c to d of the belarus regulations. 91 general licence: transferable securities, money-market instruments, loans and credit arrangements general licence - int/2022/1976332 5 july 2022 regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 (the belarus regulations) 5 july 2022 this general licence allows for a 7-day wind down period in respect of, category c loans (as defined by regulation 15b (5)) as well as transferable securities and money market instruments (as defined by regulation 15a (2c)). 92 financial sanctions notice 5 july 2022 implemented under 2019 uk-russia regulations 5 july 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: denis yakovlevich gafner valeriya kalabayeva the following entries have been removed from the consolidated list and are no longer subject to an asset freeze: yakov vladimirovich rezantsev galina ulyutina the following entries have been amended and are still subject to an asset freeze: aleksandra aleksandrovna kamyshanova yevgeniya vitalyevna nezhdanova valeriy ivanovich pogrebenkov 93 financial sanctions notice belarus 7 july 2022 implemented under 2019 uk-belarus regulations 7 july 2022 the following entity has been amended under the belarus regime and remains subject to an asset freeze: llc synesis 94 general licence: humanitarian activity general licence - int/2022/1947936 7 july 2022 implemented under regulation 64 of 2019 uk-russia regulations 7 july 2022 under general licence int/2022/1947936 relevant persons seeking to undertake humanitarian activity in relation to the conflict in ukraine do not need to apply for individual licences from ofsi, but instead can rely on the permissions within this general licence. 95 financial sanctions notice 12 july 2022 implemented under 2019 uk-russia regulations 12 july 2022 16 entries have been amended and 2 entries corrected under the russia financial sanctions regime and remain subject to an asset freeze. 96 financial sanctions notice belarus 12 july 2022 implemented under 2019 uk-belarus regulations 12 july 2022 6 entries have been amended under the belarus financial sanctions regime and remain subject to an asset freeze. 97 financial sanctions notice 15 july 2022 implemented under 2019 uk-russia regulations 15 july 2022 the following entries have been removed from the consolidated list and are no longer subject to an asset freeze: didier casimiro zeljko runje the following entries have been amended under the russia regime and remain subject to an asset freeze: sergei ivanovich saenko vladimir leonidovich sivkovich oleg anatolyevich voloshyn alrosa 98 russia (sanctions) (eu exit) (amendment) (no. 11) regulations 2022 15 july 2022 amends 2019 uk-russia regulations 15 july 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) ("the 2019 regulations"). regulations 3 to 8 and 12(2) to (5) and (8) amend part 5 of the 2019 regulations relating to trade, and both amend existing schedules and insert new ones. new restrictions are imposed in relation to trade in: maritime goods and maritime technology in certain circumstances (regulation 5); military goods and technology with non-government controlled ukrainian territory (as specified in new chapter 2a of part 5); defence and security goods and technology (as specified in parts 2 to 4 of new schedule 3c); interception and monitoring services; banknotes; jet fuel and fuel additives (as specified in an addition to part 8 of schedule 2a); and goods which generate significant revenues for russia (as specified in new schedule 3d). as a result of those amendments: regulation 3 amends the definitions of"critical-industry goods","critical-industry technology","restricted goods" and"restricted technology" for the purposes of part 5 of the 2019 regulations; regulation 7 inserts additional prohibitions in chapter 4c of part 5 of the 2019 regulations relating to trade in ancillary services relating to iron and steel goods and makes consequential amendments; regulation 9 extends prohibitions in part 5 of the 2019 regulations in relation to trade in certain items with non-government controlled ukrainian territory; regulation 12(6) adds further things to the list of oil and refining goods and technology in schedule 2d and regulation 12(7) adds further things to the list of energy-related goods in schedule 3 in respect of which trade is prohibited. regulation 10 amends part 7 of the 2019 regulations to create exceptions to some of the new prohibitions. regulation 11 makes consequential amendments in relation to offences. regulation 13 revokes the russia (sanctions) (eu exit) (amendment) (no. 10) regulations 2022 (s.i. 2022/689). 99 the russia (sanctions) (eu exit) (amendment) (no. 12) regulations 2022 19 july 2022 amends 2019 uk-russia regulations 19 july 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) ("the 2019 regulations"). these regulations add new financial sanctions to part 3 (finance) of the 2019 regulations. the amendments insert restrictions regarding investments (and services directly related to those investments) in respect of land located in russia, persons connected with russia, relevant entities, joint ventures, opening a representative office or establishing a branch or subsidiary located in russia. these regulations provide for exceptions to, and licensing powers in relation to, these new provisions. 100 general licence – investments in relation to russia general licence - int/2022/2002560 19 july 2022 implemented under regulation 64 of 2019 uk-russia regulations 19 july 2022 this general licence int/2022/2002560 allows for a 7-day wind down period in respect of the outward investment ban outlined in the amendment 12 regulations. this licence takes effect from 19 july 2022 and expires on 26 july 2022. 101 the russia (sanctions) (eu exit) (amendment) (no. 13) regulations 2022 18 july 2022 amends 2019 uk-russia regulations 18 july 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c.13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) ("the 2019 regulations"). part 2 makes amendments to the designation criteria in regulation 6 of the 2019 regulations: first, to specify additional activities for which a person may be designated; second, to make minor amendments to the definition of"being involved in obtaining a benefit from or supporting the government of russia"; and third, to broaden the interpretation of being"associated with" a designated person. part 3 provides for a new exception from trade sanctions measures for humanitarian assistance activity in non-government controlled areas of the donetsk and luhansk oblasts. part 4 makes provision to correct or resolve a number of issues arising from the 2019 regulations or amendments made to them: first, to expand upon the definition of ownership in relation to ships and aircraft; and second, to correct drafting errors or omissions in regulations 76, 78 and 94. 102 russia guidance updated 19 july 2022 implements under 2019 uk-russia regulations 19 july 2022 the guidance has a new section on investments in russia on page 5 to 6. it also updates the faqs section on page 8 to 11 to reflect the russia financial sanctions that have come into force since the russian invasion of ukraine. 103 the sanctions (eu exit) (miscellaneous amendments) regulations 2022 and the sanctions (eu exit) (miscellaneous amendments) (no.2) regulations 2022 19 july 2022 30 august 2022 these regulations extend the definition of ‘relevant firms’ that have financial sanctions reporting obligations to include cryptoasset exchange providers and custodian wallet providers. there is a requirement for 'relevant firms', as defined in sanctions regulations, to notify ofsi of certain information as soon as practicable when encountering a designated person in the course of their business. this requirement applies to relevant firms in the uk or under uk jurisdiction including people working for them. chapter 5 of ofsi's general guidance covers reporting obligations. for further information on reporting obligations, including how to report to ofsi can be found here. 104 financial sanctions notice 20 july 2022 implemented under 2019 uk-russia regulations 20 july 2022 the following entries have been amended under the russia regime and remain subject to an asset freeze: irina sergeyevna bubnova sergei sergeivich ivanov natalya petrovna skorokhodova djeco group lp majory llp photon pro llp 105 the russia (sanctions) (eu exit) (amendment) (no. 14) regulations 2022 21 july 2022 amends 2019 uk-russia regulations 21 july 2022 these regulations amend part 5 of the 2019 regulations, on trade, and insert related schedules. new restrictions are imposed in relation to trade in: professional and business services (as specified in new regulation 54b); miscellaneous essential goods required for the functioning of the russian economy (as specified in new schedule 3e); oil and oil products means (as specified in new schedule 3f); gold (as specified in new schedule 3g); coal and coal products (as specified in new schedule 3h). the goods specified in new schedules 3e, 3f, 3g and 3h are specified by reference to commodity codes which are set out in the tariff of the united kingdom. provision in also made in relation to energy related goods, supplementing existing provision in chapter 4 of part 5. provision is also made in relation to the giving of technical assistance to certain aircraft situated at uk airports. the remainder of the provisions in these regulations relate to trade exceptions and enforcement. 106 general licence: payment to uk insurance companies for building and engineering insurance 22 july 2022 russia (sanctions) (eu exit) regulations 2019 regulations 11 to 15 22 july 2022 under the general licence, individuals or entities designated under the uk sanctions regimes are permitted to make payments to uk insurers for insurance premiums and broker commissions relating to the provision of building and engineering insurance cover provided to uk properties. the licence also permits uk insurers to make payments to uk designated persons due as a result of a successful claim made against an insurance policy provided by the uk insurer or refunds due as a result of any over payments made pursuant to this licence. the general licence is applicable across multiple regimes. these are detailed in annex 1. 107 financial sanctions notice 26 july 2022 implemented under 2019 uk-russia regulations 26 july 2022 42 entries have been added to the consolidated list and are now subject to an asset freeze. further information can be found in the annex to this notice. the following entry has been corrected on the consolidated list and remains subject to an asset freeze: vadim anatolyevich lukashevich 108 general licence – wind down of positions involving rosbank general licence - int/2022/1968500 30 july 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 july 2022 general licence int/2022/1968500 extended for a period of 2 months to the 30 september, allowing for the winding down of positions involving rosbank. 109 financial sanctions notice 2 august 2022 implemented under 2019 uk-russia regulations 2 august 2022 the following entries have been added to the russia regime and are now subject to an asset freeze: didier casimiro zeljko runje the following entry has been removed under the russia regime and is no longer subject to an asset freeze: olga ayziman 18 entries have been amended and are still subject to an asset freeze. further information can be found in the annex to this notice. 110 financial sanctions notice 9 august 2022 implemented under 2019 uk-russia regulations 9 august 2022 27 entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze. further information can be found in the annex to this notice. 111 general licence – mongolia energy payments general licence - int/2022/2085212 15 august 2022 implemented under regulation 64 of 2019 uk-russia regulations 15 august 2022 general licence int/2022/2085212 issued under the russia sanctions regulations allowing payments to sanctioned russia banks for the purpose of making energy available for use in mongolia. under this general licence a person may continue to make payments to certain sanctioned banks and subsidiaries for the purpose of making energy available for use in mongolia, and a person, relevant institution, sanctioned bank or subsidiary can carry out any activity reasonably necessary to effect this. 112 general licence: permitted payments to uk insurance companies general licence - int/2022/2009156 22 july 2022 amended 17 august 2022 uk autonomous sanctions regulations 22 july 2022 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. general licence int 2022/2009156 has been amended to include within permitted payments: terrorism insurance property owners' liability insurance claims preparation insurance this licence took effect on 22 july 2022, has been amended 17 august 2022 and is of indefinite duration. 113 general licence – continuation of business of evraz plc’s north american subsidiaries 5 may 2022 amended 18 august 2022. implemented under regulation 64 of 2019 uk-russia regulations 5 may 2022 this general license allows the continued business operations of evraz' north american subsidiaries. 114 general licence: crown servants, contractors, & their family members general licence - int/2022/1845976 19 august 2022 implemented under regulation 64 of 2019 uk-russia regulations 19 august 2022 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. 115 general licence – bank fees general licence - int/2022/2104808 22 august 2022 implemented under regulation 64 of 2019 uk-russia regulations 22 august 2022 under general licence int/2022/2104808, a bank is allowed to take payment of bank fees from frozen accounts. this licence takes effect from 22 august 2022 and is of indefinite duration. 116 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments general licence - int/2022/1280876 01 march 2022 amended on 22 august 2022. implemented under regulation 64 of 2019 uk-russia regulations 01 march 2022 ofsi has 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. 117 financial sanctions notice 23 august 2022 implemented under 2019 uk-russia regulations 23 august 2022 42 entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze. . further information can be found in the annex to this notice. the following entry has been removed from the russia regime and is no longer subject to an asset freeze: mikhail vladimirovic razvozhayev 118 financial sanctions notice 16 september 2022 implemented under 2019 uk-russia regulations 16 september 2022 1 entry has been added to and 3 entries removed from the russia financial sanctions regime. further information can be found in the annex to this notice. 119 russia guidance 21 september 2022 russia (sanctions) (eu exit) regulations 2019 21 september 2022 ofsi has updated its russia guidance adding 3 new questions. questions 24 to 26 further clarify how to use the food security licensing provision in the russia (sanctions) (eu exit) regulations 2019, particularly with regard to providing insurance. 120 financial sanctions notice 26 september 2022 implemented under 2019 uk-russia regulations 26 september 2022 92 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. 3 entries have been amended and 1 entry corrected under the russia financial sanctions regime and remain subject to an asset freeze. further information can be found in the annex to this notice. 121 financial sanctions notice 30 september 2022 implemented under 2019 uk-russia regulations 30 september 2022 the following entry has been added to the consolidated list and is now subject to an asset freeze: elvira sakhipzadovna nabiullina the following entries have been corrected and are still subject to an asset freeze: alexey ivanovich isaykin alexander dmitrievich kharichev 122 financial sanctions notice 4 october 2022 implemented under 2019 uk-russia regulations 4 october 2022 the following entry has been added to the russia regime and is now subject to an asset freeze: sergei vladimirovich yeliseyev 123 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments general licence - int/2022/1280876 6 october 2022 implemented under regulation 64 of 2019 uk-russia regulations 6 october 2022 general licence int/2022/1280876 was further amended to include payments related to insolvency proceedings under the german banking act. 124 general licence – london court of international arbitration (lcia) arbitration costs general licence - int/2022/1552576 17 october 2022 implemented under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 and under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 17 october 2022 under general licence int/2022/1552576, designated persons (dps), companies controlled by dps or their legal representatives are allowed to make payments to the london court of international arbitration (lcia) to cover their arbitration costs. general licence int/2022/1552576 also permits the lcia to direct and receive such payments to use them to pay for arbitration costs and relevant institutions to process those payments. this licence takes effect from 17 october 2022 and is of indefinite duration. 125 financial sanctions notice 20 october 2022 implemented under 2019 uk-russia regulations 20 october 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: saeed aghajani mohammad bagheri seyed hojjatollah qureishi shahed aviation industries the following entry has been amended on the consolidated list and remains subject to an asset freeze: oleksandr saulenko 126 general licence: loans and securities amendment general licence - int/2022/2307324 28 october 2022 implemented under regulation 64 of 2019 uk-russia regulations 28 october 2022 general licence int/2022/2307324 is a 7-day wind down licence, which will allow the granting of category 5 loans until 23:59 on 5 november. 127 general licence: securing energy for europe general licence - int/2022/ 2305324 28 october 2022 implemented under regulation 64 of 2019 uk-russia regulations 28 october 2022 under general licence int/2022/2305324, persons may grant category 5 loans to saving energy for europe gmbh, otherwise known as gazprom germania, and its subsidiaries, including sefe marketing & trading limited and sefe energy limited. this licence takes effect from 23:59 on 28 october 2022 and expires on 29 october 2023. when assessing the potential for renewal of general licence int/2022/2305324 ofsi will consider the potential implications of this decision for the uk’s energy security. 128 ofsi issues a legal fees general licence general licence - int/2022/2252300 28 october 2022 implemented under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 and under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 28 october 2022 under general licence int/2022/2252300, provided that one of the sets of conditions in one of parts a or b of the general licence are complied with in full, any person or relevant institution may receive payments from a dp; make payments (directly or indirectly) for or on behalf of a dp; make payments for the benefit of a dp; process payments which relate to a dp; and any person or relevant institution may carry out any other act which is reasonably necessary to give effect to this. any activity conducted under general licence int/2022/2252300 must be reported to hm treasury within 7 days, with the details and supporting evidence requested in part a or part b. the reporting forms referenced at 9.4 of part a and 11.5 of part b of general licence int/2022/2252300 may be downloaded from the ofsi website here. 129 the russia (sanctions) (eu exit) (amendment) (no. 15) regulations 2022 russia sanctions - guidance 28 october 2022 amends 2019 uk-russia regulations 28 october 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855). regulation 3 prohibits the making of a new category of loan to certain persons and regulation 7 makes a consequential amendment enabling an exception from that prohibition. regulation 4 inserts and amends definitions relating to the new and revised trade prohibitions. regulation 5 creates new trade prohibitions in the 2019 regulations relating to gold jewellery and to certain processed gold. regulation 8(2) and (3) creates exceptions to those prohibitions. regulations 9 and 10 make consequential amendments and regulation 11(9) amends the list of gold and gold products in order to define the items for which trade in gold jewellery is prohibited. regulation 6 makes provision concerning the prohibition of imports of liquefied natural gas and the export of russia’s vulnerable goods (set out in regulation 11(10) and schedule 2) to russia. regulation 8(4) prescribes an exception to the russia’s vulnerable goods prohibition. regulation 11(2) to (4) makes minor clarificatory amendments to the lists of critical-industry goods and critical-industry technology. regulation 11(5) adds items to the list of oil refining goods and technology and regulation 12(7) adds items to the list of revenue generating goods. regulation 11(6) makes a minor clarificatory amendment to the list of quantum computing and advanced materials goods and technology. regulation 11(8) and schedule 1 insert additional goods as g7 dependency and further goods. regulation 12 and schedule 3 correct errors made in previous regulations amending the 2019 regulations. 130 financial sanctions notice 2 november 2022 amends 2019 uk-russia regulations 2 november 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: alexander grigoryevich abramov alexander vladimirovich frolov airat mintimerovich shaimiev albert kashafovich shigabutdinov 3 entries have also been amended under the russia regime and remain subject to an asset freeze. further information can be found in the notice, here. 131 general licence – truphone general licence - int/2022/2339452 2 november 2022 implemented under regulation 64 of 2019 uk-russia regulations 2 november 2022 general licence int/2022/2339452. this allows truphone limited to continue to make or receive payments for the purposes of continuing to provide telecommunication services. further information can be found in the notice, here. 132 general licence – transactions related to agricultural commodities including the provision of insurance and other services general licence - int/2022/2349952 4 november 2022 implemented under regulation 64 of 2019 uk-russia regulations 4 november 2022 general licence int/2022/2349952 issued to allow, subject to certain conditions, transactions related to agricultural commodities including the provision of insurance and other services. 133 the russia (sanctions) (eu exit) (amendment) (no. 16) regulations 2022 explanatory memorandum 4 november 2022 amends 2019 uk-russia regulations 5 december 2022 these amendments will apply to a uk person anywhere in the world or any person in the uk and uk territorial waters (henceforth “affected persons”). the amendments will ban the supply or delivery by ship of 2709 and 2710 oil and oil products from a place in russia to a third country, or from one third country to another third country, as well as the provision of related ancillary services (including brokering services and financial assistance).1 2 the purpose of the amendments will be to encourage russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine, as stated in regulation 4 of the 2019 regulations. 134 the russia (sanctions) (overseas territories) (amendment) (no. 3) order 2022 10 november 2022 russia (sanctions) (overseas territories) order 2020 10 november 2022 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (the principal order). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the russia sanctions regulations) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have been recently amended by the russia (sanctions) (eu exit) (amendment) (no. 11) regulations 2022 (s.i. 2022/792), the russia (sanctions) (eu exit) (amendment) (no. 12) regulations 2022 (s.i. 2022/801), the russia (sanctions) (eu exit) (amendment) (no. 13) regulations 2022 (s.i. 2022/814) and the russia (sanctions) (eu exit) (amendment) (no. 14) regulations 2022 (s.i. 2022/850) (the amending regulations). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations. 135 financial sanctions notice 11 november 2022 amends 2019 uk-russia regulations 11 november 2022 one entry has been amended and is still subject to an asset freeze: eugene markovich shvidler. further information can be found in the notice, here. 136 general licence – truphone general licence - int/2022/2339452 2 november 2022 amended 17 november 2022. implemented under regulation 64 of 2019 uk-russia regulations 17 november 2022 ofsi has also amended general licence int/2022/2339452 for truphone telecommunications services. details of the amendments can be found in the publication notice. 137 general licence: payment to energy companies for gas and/or electricity general licence - int/2022/2300292 17 november 2022 this licence is granted under all uk autonomous sanctions regulations listed in annex i of this licence 17 november 2022 ofsi issued general licence int/2022/2300292 under all uk autonomous sanctions regulations (see annex 1 of the general licence for the list of relevant regulations) which allows for payment to utility companies for gas and electricity by uk designated persons who own or rent properties in the uk. 138 financial sanctions notice 30 november 2022 amends 2019 uk-russia regulations 30 november 2022 22 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. further information can be found in the annex to this notice, here. 139 general licence – oil price cap general licence - int/2022/2469656 4 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 4 december 2022 oil services ban and price cap information. 140 general licence – winddown general licence - int/2022/2470256 4 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 4 december 2022 oil services ban and price cap information. 141 general licence – correspondent banking and payment processing general licence - int/2022/2470056 5 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 5 december 2022 oil services ban and price cap information. further information can be found here. 142 general licence – oil price cap: exempt projects and countries 5 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 5 december 2022 oil services ban and price cap information. further information can be found here. 143 uk maritime services prohibition and oil price cap guidance 5 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 5 december 2022 guidance for the uk ban on the provision of maritime transportation of, and associated services for the maritime transportation of, certain russian oil and oil products. further information and reporting forms issued can be found here. 144 financial sanctions notice 9 december 2022 amends 2019 uk-russia regulations 9 december 2022 the following entry has been added to the consolidated list and is now subject to an asset freeze: ramil rakhmatulovich ibatullin the following entries have been corrected and are still subject to an asset freeze: maxim alexandrovich loktev igor anatolievich yegorov denis valentinovich manturov 145 financial sanctions notice 13 december 2022 amends 2019 uk-russia regulations 13 december 2022 16 entries have been added and 1 entry amended to the consolidated list and are subject to an asset freeze. further information can be found in the annex to this notice, here. 146 general licence: trade 5 - financial prohibitions - 7 day winddown general licence - int/2022/2448692 15 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 15 december 2022 general licence int/2022/2448692 allows for a 7 day wind down period in respect to financial prohibitions in regulations 16, 17 and 18b of the russia regulations. the general licence takes effect from 00:01 on 16 december 2022 and expires at 23:59 on 22 december 2022. 147 russia (sanctions) (eu exit) (amendment) (no. 17) regulations 2022 16 december 2022 amends 2019 uk-russia regulations 16 december 2022 the russia (sanctions) (eu exit) (amendment) (no. 17) regulations 2022 prohibit the provision of trust services: to or for the benefit of a person connected with russia unless pursuant to an ongoing arrangement pursuant to which that person provided those services to or for the benefit of the person connected with russia immediately prior to 16 december 2022 to or for the benefit of a person designated for the purposes of regulation 18c (trust services) amendments have also been made to restrictions on transferable securities and money-market instruments, loan and credit arrangements, and investments in russia. these amendments have been designed to prohibit new investments in russia via third countries. ofsi has updated its russia guidance to reflect these measures. 148 general licence – oil price cap general licence - int/2022/2469656 4 december 2022 amended on 3 february 2023. implemented under regulation 64 of 2019 uk-russia regulations 3 february 2023 the uk, in partnership with the g7 countries, australia and the european union, has already implemented a price cap on russian crude oil trade by firms shipping oil to third countries. this cap was set at usd$60 per barrel, and came into effect on 5 december 2022. it was also agreed that a price cap would come into effect for russian refined oil products from 5 february 2023, and the uk and its price cap coalition partners have agreed that this cap will be determined by categorisation of refined oil products as follows: products categorised as ‘premium to crude’ will be subject to the premium to crude price cap. all other products are categorised as ‘discount to crude’ and will be subject to the discount to crude price cap review. as with the 5 december oil price cap, ofsi has issued a general licence to implement the caps for oil products. as with the existing price cap for oil, the level of both caps will be kept under review. 149 general licence – refined oil products winddown general licence - int/2023/2660772 3 february 2023 implemented under regulation 64 of 2019 uk-russia regulations 3 february 2023 ofsi has issued a further wind-down general licence for oil products. this will permit contracts to ship russian oil products traded at a price above the relevant cap where the products were loaded before 5 february 2023, and are unloaded at the destination port by 1 april 2023. 150 uk maritime services prohibition and oil price cap industry guidance 5 february 2023 amends 2019 uk-russia regulations 5 february 2023 ofsi has released updated guidance on the maritime services prohibition and the oil price cap, which provides full detail of the implementation of the price caps, ofsi’s approach to enforcement, and the requirements on involved persons. this has been reviewed and updated to reflect requests for clarification and additional details for refined oil products. bespoke forms for required reporting, reporting suspected breaches, and specific license applications are available here. hm treasury will organise teach-ins for interested stakeholders over the next few weeks. 151 financial sanctions notice 8 february 2023 amends 2019 uk-russia regulations 8 february 2023 8 individuals and 7 entities have been added to the russia financial sanctions regime and are now subject to an asset freeze. further information can be found in the annex to this notice. 152 financial sanctions notice 24 february 2023 amends 2019 uk-russia regulations 24 february 2023 92 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. furthermore, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: nigina zairova further information can be found in the annex to this notice. 153 financial sanctions notice 10 march 2023 amends 2019 uk-russia regulations 10 march 2023 the following entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze: oleg nikolaevich evtushenko vitaly anatolyvich markelov yuri alexandrovich olenin roman pakhomov andrei yuvenalyevich petrov alexander sergeevich prokopiev ilya vasilevich rebrov furthermore, 14 entries have also been corrected under the russia regime and remain subject to an asset freeze. the relevant notice can be found here. 154 financial sanctions notice 17 march 2023 amends 2019 uk-russia regulations 17 march 2023 the following entry has been amended under the russia regime and remains subject to an asset freeze: igor viktorovich makarov the following entry has been removed from the russia regime and is no longer subject to an asset freeze: brian mcdonald furthermore, the following duplicate entry has been removed from the russia regime and remains subject to an asset freeze under the belarus regime: minsk wheel tractor plant further information can be found in the annex to this notice, here. 155 general licence – publication notice – trust services sanctions general licence - int/2023/2589788 21 march 2023 amends 2019 uk-russia regulations 21 march 2023 ofsi has issued general licence int/2023/2589788 under regulation 64 of the russia (sanctions) (eu exit) regulations 2019. under this general licence, persons may wind down the provision of trust services to a designated person. the permissions under this general licence apply to persons from the date of designation and will expire at 23:59 on the 90th calendar day from taking effect for the purposes of regulation 18c. note that the expiry date will differ depending on the date for each designation. it may be varied, revoked, or suspended by hm treasury at any time. any persons intending to use the general licence should first consult the copy of the licence and refer to ofsi’s general guidance. persons using the general licence must report to ofsi within 30 calendar days of undertaking any activity. the relevant reporting form can be found here. ofsi has also published a blog and updated its russia guidance to include further information on prohibitions on trust services. 156 financial sanctions notice 22 march 2023 amends 2019 uk-russia regulations 22 march 2023 all persons currently designated under the russia regime (1,730 entries) have been amended on the consolidated list and are now subject to trust services sanctions. 7 entries have also been updated to reflect existing further restrictions. the 'other information' field for all entries has been amended to provide details of further financial restrictions, and the date trust services sanctions were imposed. all entries remain subject to an asset freeze and no further changes have been made to the consolidated list. further details can be found in the notice. 157 financial sanctions notice 22 march 2023 amends 2019 uk-russia regulations 22 march 2023 the following duplicate entry has been removed from the consolidated list. the original entry (sergei borisovich korolyov) remains on the consolidated list under the russia regime and the individual is still subject to an asset freeze: sergey borisovich korolev the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: alexey viktorovich kuzmichev 158 general licence – bond amendments and restructurings for non-designated persons general licence - int/2023/2824812 28 march 2023 implemented under regulation 64 of 2019 uk-russia regulations 28 march 2023 on 28 march 2023, ofsi issued general licence int/2023/2824812 under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 (“the russia regulations”) to allow, subject to certain conditions, transactions related to bond amendments and restructurings for non-designated persons. further details can be found in the general licence, here. 159 financial sanctions notice 12 april 2023 amends 2019 uk-russia regulations 12 april 2023 14 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. furthermore, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: nikolay ivanovich bortsov. ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice here. 160 financial sanctions notice 13 april 2023 amends 2019 uk-russia regulations 13 april 2023 the following entries has been amended under the russia financial sanctions regime and remain subject to an asset freeze: tatiana vladimirovna evtushenkova felix vladimirovich natalia nikolayevna evtushenkova nariman gadzhievich gadzhiev ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice here. 161 financial sanctions notice 21 april 2023 amends 2019 uk-russia regulations 21 april 2023 the following entries have been added to the consolidated list under the russia financial sanctions regimes and are now subject to an asset freeze. andrey andreevich zadachin denis vladmirovich kolesnikov elena anatolievna lenskaya ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice, here. 162 the russia (sanctions) (eu exit) (amendment) regulations 2023 statutory instruments 2023 no. 440 - sanctions 21 april 2023 amends 2019 uk-russia regulations 21 april 2023 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations). regulations 3 to 8 amend part 5 (which makes provision in respect of trade) of the 2019 regulations. regulation 3 specifically inserts a new chapter 4ca which makes specific provision prohibiting the importation of iron and steel products, containing iron or steel originating in russia, that have been processed in a third-country. regulation 4 amends chapter 4g which makes provision for revenue generating goods. in doing so, it recasts the former schedule 3d, and makes consequential amendments to regulations 46r to 46x. regulation 5 inserts a new chapter 4ga which also makes provision in respect of revenue generating goods and introduces a new schedule 3da which specifies certain revenue generating goods. no good appears in both schedule 3d and schedule 3da. regulation 6 makes remedial amendments to chapter 4i which relates to oil and oil products. regulations 7 and 8 make similar provision in relation to gold (chapter 4j) and coal and coal products (chapter 4k) respectively. regulation 9, 10 and 11 amend part 7 (which makes provision for exceptions and licences) of the 2019 regulations. the amendments include provision relating to the acquisition of otherwise prohibited goods for the purpose of the function of a united kingdom diplomatic mission in russia, and the acquisition of certain goods by united kingdom nationals situated in russia for use in russia. regulations 12 and 13 make provision in relation to enforcement of the 2019 regulations. the remainder of the regulations amend certain schedules to the 2019 regulations, some of which changes are remedial, whilst others, such as the insertion of schedule 3da, are entirely new. 163 general licence - legal services general licence - int/2023/2954852 28 april 2023 implemented under regulation 64 of 2019 uk-russia regulations 28 april 2023 on friday 28 april 2023, general licence int/2022/2252300 expired. at 00:01 hours on saturday 29 april 2023, a new general licence was issued covering legal services - general licence int/2023/2954852 (the general licence). the general licence and its reporting forms can be found here on gov.uk. those intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements as these do not mirror those of general licence int/2022/2252300. to accompany this update, ofsi has published a blog detailing the amendments to the general licence. the blog can be found here on gov.uk. 164 general licence – continuation of business of evraz plc’s north american subsidiaries general licence - int/2022/1710676 4 may 2023 implemented under regulation 64 of 2019 uk-russia regulations 4 may 2023 general licence int/2022/1710676 has been amended. the definition of the “north american subsidiaries” has been amended to clarify that the subsidiary companies of evraz north america plc, evraz inc. na and evraz inc. na – canada are covered by general licence int/2022/1710676. 165 ofsi licensing: travel guidance guidance on travel allowance for licence applications 12 may 2023 implemented under 2019 uk-russia regulations 12 may 2023 ofsi has published a new guidance to applicants of licences to release frozen funds for travel and associated expenses. it provides guidance on ofsi’s expected standard of reasonableness regarding the use of funds and economic resources for travel and expenses. 166 financial sanctions notice 16 may 2023 amends 2019 uk-russia regulations 16 may 2023 the following entry has been amended under the russia financial sanctions regime: roman nikolaevich lepa ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice here. 167 financial sanctions notice 19 may 2023 amends 2019 uk-russia regulations 19 may 2023 86 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust service sanctions. the following entries have been removed from the consolidated list and are no longer subject to an asset freeze or trust services sanctions: nikolay yurievi petrunin kyrylo sergiyovich stremousov vladimir nikolayevich sungorkin further details can be found in the notice here. 168 financial sanctions notice 22 may 2023 amends 2019 uk-russia regulations 22 may 2023 the following entries have been amended and are still subject to an asset freeze and trust services sanctions: ilya iosifovich klebanov valery pavlinovich shantsev afk sistema the non-latin script language for the following entry has been updated. no material changes have been made to the consolidated list in html/pdf format: vladimir nikolaevich lepin further details can be found in the notice, here. 169 general licence – prior obligations general licence - int/2023/3024200 22 may 2023 implemented under regulation 64 of 2019 uk-russia regulations 22 may 2023 ofsi has issued a new general licence to enable the payment of funds or economic resources from a designated person to a uk person to satisfy contractual obligations that arose pre-designation. the general licence and its reporting forms can be found here. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. 170 general licence – london court of international arbitration (lcia) arbitration costs general licence - int/2022/1552576 5 june 2023 implemented under regulation 32 of the uk - belarus regulations of 2019 and regulation 64 of the 2019 uk-russia regulations 5 june 2023 general licence int/2022/1552576 was amended to allow: designated person (dp) representatives to pay funds to the london court of international arbitration (lcia) to cover arbitration costs (dp representative is a non-dp who is a party to an lcia arbitral proceedings, and acts in lieu of, or for the benefit of a dp) dps or dp representatives to transfer funds to their legal representatives for onward payment to the lcia to cover arbitration costs non-dp arbitral parties to pay substitute deposit(s) to the lcia 171 general licence – transactions related to agricultural commodities including the provision of insurance and other services general licence - int/2022/2349952 6 june 2023 implemented under regulation 64 of 2019 uk-russia regulations 6 june 2023 general licence int/2022/2349952 was amended to allow the grain and feed trade association (gafta) to receive funds and economic resources from any person, including designated persons, in connection with the direct and indirect provision of services related to contracts for the trade in agricultural commodities, by or on behalf of gafta. 172 republic of belarus (sanctions) (eu exit) (amendment) regulations 2023 9 june 2023 amending the republic of belarus (sanctions) (eu exit) regulations 2019 9 june 2023 the 2019 belarus regulations are being amended in june 2023 to target exports from belarus that fund lukashenko’s regime and to target the circumvention of sanctions against russia. the belarusian regime continues to openly facilitate russia’s illegal invasion of ukraine. belarus also continues to provide diplomatic support to russia and their economies are closely integrated. the measures imposed and amended by the amendment regulations include the following: changes to designation criteria. this will allow the fcdo to more effectively target persons that are involved in supporting russia’s invasion of ukraine. this includes persons with the ability to nominate, appoint or remove a director or members of management and supervisory bodies of relevant entities and persons that work for, or are affiliated to, belarusian authorities. amendments to the dealing with transferable securities or money market instruments measure. new measures relating to internet services and social media. the prohibition of exports of machinery; banknotes; and precursor materials for chemical and biological weapons and technology. the prohibition of imports of cement, rubber, wood and gold. a ban on ancillary services for all prohibited goods, including technical assistance and financial and brokering services. these further sanctions align with hmg’s strategic approach in response to russia’s illegal invasion of ukraine by deterring the belarusian regime from supporting or enabling russian actions that are destabilising ukraine and demonstrating that the uk strongly condemns belarus’ role in facilitating russia’s invasion of ukraine. the press release can be accessed here. 173 the now-revoked general license - int/2022/2305324 14 june 2023 revoking the general licence implemented under regulation 64 of the 2019 uk-russia regulations 14 june 2023 on 14 june 2023, the securing energy for europe general licence (gl) int/2022/2305324 was revoked. the nationalisation of gazprom germania (renamed securing energy for europe) means that gazprom’s uk subsidiaries are no longer in scope of the credit restrictions originally introduced by the russia (sanctions) (eu exit) (amendment) (no. 15) regulations 2022, which this gl was designed to lift. ofsi no longer considers there to be a need for this gl. 174 general licence – oil price cap: trading in derivatives and futures general licence - int/2023/3074680 14 june 2023 implemented under regulation 64 of 2019 uk-russia regulations 14 june 2023 ofsi issued general licence int/2023/3074680. this general licence permits trading in derivatives and futures related to the supply or delivery by ship of russian oil and oil products which would otherwise breach the prohibition in regulation 46z9c of the russia regulations. 175 updated guidance for the maritime services ban and oil price cap 14 june 2023 implemented under regulation 64 of 2019 uk-russia regulations 14 june 2023 osfi published updated guidance for the maritime services ban and oil price cap, to provide additional clarity and detail on the following: wind-down periods: we are confirming that ofsi will introduce a 45-day wind-down period for any future changes to the oil price cap trading in derivatives and futures: trading in derivatives and futures is now exempt from the oil price cap “as soon as reasonably practicable”: clarification has been added on ofsi’s view of what is considered to be taking the required steps to withdraw contracted services “as soon as reasonably practicable” in the event of a suspected breach. bespoke reporting forms for required reporting, reporting suspected breaches, and specific licence applications can be found here. any reporting or queries should be directed to oilpricecap.ofsi@hmtreasury.gov.uk. 176 the russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2023 no. 665 19 june 2023 amendments to the 2019 uk-russia regulations 20 june 2023 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) (the act) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations) (as amended). under section 1 of the act, the secretary of state may make sanctions regulations for a purpose within subsection (2). in addition to the current purpose stated in regulation 4 (encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine), the secretary of state considers that the 2019 regulations are also appropriate for promoting the payment of compensation by russia for losses suffered by ukraine as a result of russia’s full-scale invasion of ukraine on or after 24 february 2022. regulation 4 of the 2019 regulations is amended to refer to this additional purpose. regulation 3 removes the existing definition of non-government controlled areas of the donetsk and luhansk oblasts, and substitutes a new definition of non-government controlled ukrainian territory which includes also the additional territory of non-government controlled areas of the kherson and zaporizhzhia oblasts of ukraine. the expanded definition has the effect of extending existing finance, shipping and trade sanctions relating to the autonomous republic of crimea and city of sevastopol (crimea) and non-government controlled areas of the donetsk and luhansk oblasts, and relevant exceptions, to non-government controlled areas of the kherson and zaporizhzhia oblasts. the regulations also introduce a defence to the strict liability offence under section 68(1) of the customs and excise management act 1979 relating to the prohibition on exportation of certain goods to, or for use in, non-government controlled areas of the donetsk, kherson, luhansk and zaporizhzhia oblasts. 177 general licence: humanitarian activity general licence - int/2022/1947936 20 june 2023 implemented under regulation 64 of the 2019 uk-russia regulations 20 june 2023 general licence int/2022/1947936 was amended to update: the definition of non-government controlled ukrainian territory to capture kherson and zaporizhzhia oblasts update annex i of designated financial institutions to capture financial institutions designated since 7 july 2022 178 financial sanctions notice 23 june 2023 amends the 2019 uk-russia regulations 23 june 2023 on 23 june 2023 the following entries have been amended and are still subject to an asset freeze and trust services sanctions: demetris ioannides galina evgenyevna pumpyanskaya dmitry alexandrovich pumpyansky ofsi’s consolidated list of asset freeze targets has been updated to reflect this change. 179 general licence – continuation of business of evraz plc’s north american subsidiaries general licence - int/2022/1710676 5 may 2022 and amended 26 june 2023 implemented under regulation 64 of the 2019 uk-russia regulations 26 june 2023 on 26 june 2023 general licence int/2022/1710676 has been extended further and will expire on 31 march 2024. 180 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 and amended 26 june 2023 implemented under regulation 64 of the 2019 uk-russia regulations 26 june 2023 general licence int/2022/1875276 has been amended to: remove certain entities, which ofsi does not believe are owned or controlled by designated persons (dp) add mosdachtrest and rossiya segodnya as news media services dps adjust the definition of civil telecommunications dps to include certain subsidiaries of zao transtelecom company 181 the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2023 30 june 2023 amendments to the 2019 uk-russia regulations 30 june 2023 this instrument amends the 2019 uk-russia regulations to impose further trade sanctions in relation to russia. following its illegal annexation of crimea in 2014, russia has continued a pattern of aggressive action towards ukraine, which culminated in the invasion of ukraine’s sovereign territory on 24 february 2022. announced by president putin as a “special military operation”, this included recognising the “donetsk people’s republic” and “luhansk people’s republic” as independent states and deploying russian military across ukraine. the uk has called on russia to cease its military activity, withdraw its forces from ukraine and crimea, end its support for the separatists, and fulfil its international commitments including under the 1975 helsinki final act, the 2014 and 2015 minsk protocols, the 1994 budapest memorandum and the un charter. uk policy remains focused on ending russia’s invasion and on assisting ukraine to secure its borders, ensuring a stable, prosperous and democratic future for all its citizens. the uk is unwavering in its support for the country’s independence, territorial integrity and sovereignty. these sanctions are part of a broader set of measures which includes: diplomatic, military, financial and humanitarian support; trade, financial and transport sanctions; and designations. change will therefore be sought through diplomatic pressure and other measures, supported by trade sanctions in respect of actions undermining the territorial integrity, sovereignty and independence of ukraine. the provision of legal services is already partially restricted by the 2019 uk-russia regulations, including by regulations 19 and 55 (the “circumvention regulations”) and several regulations that limit the provision of ancillary services related to sanctioned goods and technologies. the circumvention regulations prevent a person intentionally providing legal advisory services where the object or effect of the legal advisory services directly or indirectly circumvents prohibitions imposed by the 2019 uk-russia regulations, or enables or facilitates the contravention of those prohibitions. however, as a result of the territorial application of the 2019 uk-russia regulations, this generally applies only to legal advisory services provided in relation to prohibited activity undertaken in the uk or by a uk person. this means that without these regulations, it would potentially be lawful for a uk legal services provider to support commercial activity which advances the interests of russia, where that activity does not have sufficient connection to the uk to be prohibited under the uk sanctions regime. this is a particular concern given that the law of england and wales is often chosen as the law governing international commercial activities, and as such, the services of uk lawyers are frequently engaged in relation to those activities, even if the activity is not conducted in the uk or by uk persons. this instrument addresses this issue and supplements other restrictions on providing legal services. it means that no uk person or person in the uk can provide legal advisory services in relation to certain financial or trade activity which would be prohibited under the uk sanctions regime if the activity was done by a uk person or was taking place in the uk. this restriction is limited to legal advisory services and does not cover legal representation services. access to legal representation is an important element of the core democratic principle of the rule of law, and this sort of legal service has therefore been excluded. in keeping with this principle, the instrument introduces an exception that enables services providers to offer expert evidence in connection with legal proceedings, even where the services activity would otherwise be prohibited to a person connected with russia. other exceptions to the restriction are also set out including legal advice related to compliance with the sanctions regime itself. the instrument also introduces a new exception to the prohibition on the provision of professional and business services. the exception, which applies to auditing services, provides companies and auditors with a legal basis under which they can operate where there are statutory or regulatory obligations. this reflects how this measure interacts with the audit requirement in uk company law and the auditor’s obligations to shareholders. this instrument also sets out a referral process relevant to the way that his majesty’s revenue and customs will investigate certain offences under the 2019 uk-russia regulations. 182 financial sanctions notice 6 july 2023 amends the 2019 uk-russia regulations 6 july 2023 the following entry has been removed from the ofis’s russia financial sanctions regime and is no longer subject to an asset freeze: lev aronovich khasis ofsi’s consolidated list of asset freeze targets has been updated to reflect this change. 183 financial sanctions notice 17 july 2023 amends the 2019 uk-russia regulations 17 july 2023 14 entries have been added and 10 entries have been amended under the uk russia financial sanctions regime. these entries are all subject to an asset freeze and trust services sanctions. the ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes and can be accessed here. further details can be found in the annex to the notice here. 184 the russia (sanctions) (overseas territories) (amendment) (no. 2) order 2023 19 july 2023 amendments to the 2019 uk-russia regulations 20 july 2023 and article 4 on 30 september 2023 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (the “principal order”). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the “russia sanctions regulations”) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have recently been amended by the russia (sanctions) (eu exit) (amendment) regulations 2023 (s.i. 2023/440); the russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2023 (s.i. 2023/665) and the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2023 (s.i. 2023/713) (together “the amending regulations”). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations: to modify offences in relation to export of goods to non-government controlled ukrainian territory; to modify relevant offences in relation to import of relevant processed iron or steel products and revenue generating goods from russia; to modify certain provision in relation to prohibitions on the provision of professional and business services. 185 financial sanctions notice 20 july 2023 amends the 2019 uk-russia regulations 20 july 2023 the following entry has been removed from the russia financial sanctions regime: oleg yurievich tinkov furthermore, the following entry has also been corrected under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: sun ship management (d) ltd further details can be found in the annex to the notice. 186 general licence – mongolia energy payments general licence - int/2022/2085212 15 august 2022 and amended 27 july 2023. amends the 2019 uk-russia regulations 27 july 2023 on 27 july 2023 ofsi amended general licence int/2022/2085212. this amendment extends the duration of the general licence, which will now expire on 14 august 2025. 187 financial sanctions notice 28 july 2023 amends the 2019 uk-russia regulations 28 july 2023 the following entries have been amended under the russia regime and remain subject to an asset freeze and trust services sanctions: andrey vladimirovich sharonov eugene tenenbaum further details can be found in the annex to the notice. 188 financial sanctions notice 31 july 2023 amends the 2019 uk-russia regulations 31 july 2023 6 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: vitaly alexsandrovich belitsky ekaterina mikhailovna dorokhina natalia nikolaevna dudar boris georgievich loktionov danila yurievich mikheev anna evgenievna potychko furthermore, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: ella aleksandrovna pamfilova further details can be found in the annex to the notice. 189 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities general licence - int/2023/3263556 1 august 2023 implemented under regulation 64 of the 2019 uk-russia regulations 1 august 2023 the general licence int/2023/3263556 allows payments and other permitted activities to take place in relation to insolvency proceedings associated with gtlk europe and gtlk capital and their subsidiaries. 190 financial sanctions notice 8 august 2023 amends the 2019 uk-russia regulations 8 august 2023 19 entries have been added, and 1 entry has been corrected under the russia financial sanctions regime. all entries are subject to an asset freeze and trust services sanctions. further details can be found in the annex to the notice, here. 191 financial sanctions notice 8 august 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 8 august 2023 the following entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze: belomo holding joint stock company 2566 radioelectronic armament repair plant jsc peleng open joint stock company gomel radio plant open joint stock company kidma tech open joint stock company orsha aircraft repair plant further details can be found to the notice, here. 192 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 amended 21 october 2022, 26 june 2023, and 23 august 2023. implemented under regulation 64 of the 2019 uk-russia regulations 23 august 2023 general licence int/2022/1875276 has been amended to clarify that pjsc megafon is a designated person operating in the civilian telecommunications and news media service industry. 193 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities general licence - int/2023/3263556 01 august 2023 amended 23 august 2023 implemented under regulation 64 of the 2019 uk-russia regulations 23 august 2023 general licence int/2023/3263556 has been amended to make clear that stlc europe nine leasing limited is covered by the licence. 194 financial sanctions notice 31 august 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 31 august 2023 the following entry has been amended under the belarus financial sanctions regime and remains subject to an asset freeze: dana holdings a.k.a dana astra 195 general licence: payment to water companies for water & sewage general licence - int/2023/3179120 21 september 2023 implemented under regulation 64 of the 2019 uk-russia regulations 21 september 2023 general licence int/2023/3179120 was issued covering payments to water companies for water and sewage. under this licence, subject to the conditions; uk dps may make the permitted payments to water companies from a frozen uk bank account; any person may make a permitted payment to a water company (directly or indirectly), for or on behalf of a dp or for the benefit of a dp; and water companies may receive permitted payments made under paragraphs 1 or 2. under this licence, subject to the conditions the water companies may make return payments to frozen uk bank accounts due as a result of overpayment; and uk dps may receive return payments from water companies into a frozen uk bank account. a relevant uk institution may process payments made in accordance with paragraphs above. reporting requirements on a quarterly basis, the uk dp must report to hm treasury, with details and supporting evidence of: the name of the water company; the amount(s) paid; the payment route used; and the date on which the funds were paid. within 14 days of making a return payment under this licence, the water companies must report to hm treasury, with details of: the name of the uk dp; the amount(s) transferred; the payment route used; official - sensitive official - sensitive official - sensitive official - sensitive iv) the date on which the funds were transferred; and v) the reason for the return payment. record-keeping requirements the water companies and uk dps must keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years. 196 financial sanctions notice 27 september 2023 amends the 2019 uk-russia regulations 27 september 2023 the following entry has been amended under the russia regime and remains subject to an asset freeze and trust services sanctions: alexei kozlov 197 financial sanctions notice 29 september 2023 amends the 2019 uk-russia regulations 29 september 2023 11 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. further details can be found in the notice, here 198 general licence – correspondent banking payments general licence - int/2023/3566356 29 september 2023 implemented under regulation 64 of the 2019 uk-russia regulations 29 september 2023 general licence int/2023/3566356 was issued covering correspondent banking payments - the general licence and its publication notice can be found here on gov.uk anyone who intends to rely on the general licence should consult a copy of the licence for full details of the definitions, permissions, and usage requirements. 199 general licence – prior obligations general licence - int/2023/3024200 10 october 2023 implemented under regulation 64 of the 2019 uk-russia regulations 10 october 2023 general licence int/2023/3024200 has been extended, with additional amendments made to its conditions, definitions and annexes. the general licence and its publication notice can be found here. 200 general licence: payment to energy companies for gas and/or electricity general licence - int/2022/2300292 17 november 2022 and amended 24 february 2023 13 october 2023 all uk autonomous sanctions regulations listed in annex i of this licence 13 october 2023 ofsi amended general licence int/2022/2300292 - payment to energy companies for gas and/or electricity. the amendments include the extension of the term of the general licence - which no longer has an expiry date - and the permission for any person to make permitted payments to energy companies for or on behalf of a designated person. the general licence can be found here. 201 general licence: payments to companies house general licence - int/2023/3626884 19 october 2023 all uk autonomous sanctions regulations listed in annex i of this licence 6 october 2023 ofsi amended general licence int/2023/3626884 - payments to companies house. the amendment provides clarity on terms used within the general licence, specifically permitted payments and uk designated persons. the general licence can be found here. 202 general licence – legal services general licence - int/2023/3744968 25 october 2023 implemented under regulation 64 of the 2019 uk-russia regulations 25 october 2023 new ofsi general licence int/2023/3744968 for legal services to replace current licence int/2023/2954852 from 29 october 2023. the main changes are: the professional legal fees caps have been reset. users will be able to make use of the legal fees caps (£500,000 inc. vat) under parts a and b of the general licence. the expenses caps have been reset and increased from 5% of the legal fees (up to £25,000) to 10% of the legal fees (up to £50,000) under parts a and b. this means if expenses are required for work carried out in satisfaction of a prior obligation (£50,000 limit) and for work undertaken post-designation (£50,000 limit), up to £100,000 (inc. vat) in expenses could be paid. reporting is now due within 14 days of the law firm, legal adviser, counsel, or a provider of expenses receiving payment. the reporting requirement makes clear that the relevant letter of engagement sent to ofsi must be unredacted. the reporting form makes clear that the group id of the dp must be provided to ofsi. general licence int/2023/3744968 takes effect on 29 october 2023 and expires on 28 april 2024 and may be varied, revoked, or suspended by hm treasury at any time. general licence – publication notice can be found here. 203 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 and amended 21 october 2022 26 june 2023 23 august 2023 27 october 2023 implemented under regulation 64 of the 2019 uk-russia regulations 27 october 2023 on 27 october 2023, general licence int/2022/1875276 was updated to clarify that: pjsc megafon and its subsidiaries are civilian telecommunication dps. digital invest limited liability company (digital invest) is a civilian telecommunication dp. general licence int/2022/1875276 has been extended to 30 may 2026. the general licence and the publication notice can be found here. 204 financial sanctions notice 8 november 2023 amends the 2019 uk-russia regulations 8 november 2023 29 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. further details can be found in the notice, here. 205 financial sanctions notice 9 november 2023 amends the 2019 uk-russia regulations 9 november 2023 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: sergey stognienko further details can be found in the notice, here. 206 general licence – russian travel general licence - int/2022/1839676 23 may 2022 amended 14 february 2023 and 10 november 2023. implemented under regulation 64 of the 2019 uk-russia regulations 10 november 2023 ofsi amended general licence int/2022/1839676 - russian travel. the amendment makes clear that paragraph 4.1 only permits the purchase of tickets from a designated person or any subsidiary for passenger rail or passenger air journeys originating in, or within, russia. 207 general licence – london court of international arbitration (lcia) arbitration costs general licence - int/2022/1552576 17 october 2022 and amended 05 june 2023 13 november 2023 implemented under regulation 64 of the 2019 uk-russia regulations and also under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 13 november 2023 ofsi amended general licence int/2022/1552576 - london court of international arbitration (“lcia”) arbitration costs. the amendment removes the annex 1 that sets out the schedule of arbitration costs, and updates the definition of arbitration costs by referring to the relevant schedule of costs for lcia arbitration. 208 financial sanctions notice 6 december 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 6 december 2023 the following entry has been added to the belarus financial sanctions regime and is now subject to an asset freeze: jsc display design bureau further details can be found in the notice, here. 209 financial sanctions notice 6 december 2023 amends the 2019 uk-russia regulations 6 december 2023 45 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. more information can be found in the notice, here. 210 financial sanctions notice 8 december 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 8 december 2023 17 entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze. more information can be found in the notice, here. 211 general licence: payments to local authorities general licence - int/2023/3781228 8 december 2023 under all uk autonomous sanctions regulations 8 december 2023 a new general licence was issued covering payments to local authorities - general licence int/2023/3781228 (the general licence). the general licence and its publication notice can be found on gov.uk. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. more information can be found here. 212 financial sanctions notice 11 december 2023 amends the 2019 uk-russia regulations 11 december 2023 the following entry has been amended and is still subject to an asset freeze and trust services sanctions: ooo mvizion more information can be found in the notice, here. 213 financial sanctions notice 11 december 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 11 december 2023 the following entries have been amended and are still subject to an asset freeze: mikhail ivanovich dola mikhail kavaliou more information can be found in the notice, here. 214 the russia (sanctions) (eu exit) (amendment) (no. 4) regulations 2023 14 december 2023 amends the 2019 uk-russia regulations regulations 17, 18, 20 and 21 come into force on 26 december 2023. the remainder of these regulations come into force on 15 december 2023. these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations). regulation 3 amends the prohibitions relating to processing payments to provide that these apply to processing a payment in any currency which is received by a uk credit or financial institution but do not apply to the initial crediting of a payment to an account which is in the name of the credit or financial institution but not in the name of a customer of that credit or financial institution. regulation 4 amends existing definitions of certain products, both to add exclusions in relation to certain products where they fall within schedule 2 to the export control order 2008 (“the 2008 order”) (s.i. 2008/3231) or annex 1 of the dual-use regulation(a) and to remove exclusions relating to certain products where they fall within schedule 3 to the 2008 order. regulation 5 extends the prohibitions relating to trade in luxury goods and regulation 9 amends the exceptions to those prohibitions consequentially. regulation 6 makes minor amendments to the prohibitions relating to relevant processed iron and steel products. certain iron and steel products to which the prohibitions in chapter 4c of part 5 to the 2019 regulations are to apply are added by regulation 22(10) and schedule 1. new prohibitions relating to trade in certain metals are created by regulations 7 and 22(11) and schedule 2. regulation 8 amends the exceptions relating to the prohibition on processing payments in regulation 17a(2) of the 2019 regulations. regulation 10 creates new exceptions to the prohibitions on g7 dependency and further goods and expands those for luxury goods where these relate to consumer communication devices and software updates. regulations 11 to 13 create exceptions for iron and steel products, relevant processed iron and steel products and metals where they were exported from russia before the prohibition come into force or where they are already in free circulation in the united kingdom. regulation 14 expands the exceptions from the prohibitions on g7 dependency and further goods in the case of emergencies. regulations 15 and 22(22) allow the treasury to grant licences for certain activities carried out by a uk entity in order to divest itself of assets where those assets are subject to a sanction under the 2019 regulations. regulation 16 creates new reporting obligations to be imposed on relevant firms in relation to funds and economic resources held by them for prohibited persons (as defined by the amendment contained in that regulation). regulation 17 creates new reporting obligations on designated persons themselves, regulation 18 prescribes the criminal penalty for breach of those obligations, regulation 20 provides that those obligations are to be regarded as not being financial sanctions legislation for the purposes of part 8 of the policing and crime act 2017 (c. 3) and regulation 21 allows the treasury to impose civil monetary penalties for breaches of those obligations. regulation 19 prescribes offences created by these regulations, the suspected commission of which may be referred to his majesty’s revenue and customs for investigation. regulation 22— - makes changes to the products covered by the prohibitions on trade in critical-industry goods and critical industry technology (paragraphs (2) to (8)), luxury goods (paragraph (9)), defence and security goods and defence and security technology (paragraphs (12) to (16) and schedule 3) and g7 dependency and further goods (paragraphs (17) to (20)) and schedules 4, 5 and 6). - creates an additional ground on which the treasury may licence the processing of payments which would otherwise be prohibited by regulation 17a(2) of the 2019 regulations (paragraph (23)); - omits certain commodity codes and the associated descriptions (paragraph (24) and schedule 7). minor consequential amendments on that made in regulation 3(2) are made by regulation 23. 215 the russia (sanctions) (eu exit) (amendment) (no. 5) regulations 2023 14 december 2023 amends the 2019 uk-russia regulations 1 january 2024 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855). in particular, these regulations create prohibitions on the import, acquisition and supply and delivery of diamonds and diamond jewellery (as defined in the schedule inserted by regulation 7(2)) which are located, originate in or are consigned from russia and on the provision of ancillary services relating to those prohibitions (regulation 3). regulations 4 and 5 create certain exceptions to those prohibitions. regulation 6 prescribes which of the offences created by the amendments at regulation 3 of these regulations, may be referred to his majesty’s revenue and customs for investigation. regulation 7(1) makes consequential amendments to the list of schedule 3da revenue generating goods. 216 financial sanctions notice 15 december 2023 amends the 2019 uk-russia regulations 15 december 2023 1 entry has been added and is now subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions: joint-stock commercial bank novikombank and 26 entries have been amended and are all subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions. 217 maritime services ban and oil price cap exception - hmt industry guidance 20 december 2023 the russia (sanctions) (eu exit) (amendment) (no. 16) regulations 2022. 20 december 2023 ofsi published updated guidance for the maritime services ban and oil price cap, to provide additional clarity and detail on the following: attestations: upcoming changes to the existing model will require 1) attestation forms to be provided on a per-voyage basis and 2) itemised ancillary costs to be recorded by tier 1 entities and provided to tier 2 and tier 3a contractual counterparties upon request. the tier system has also been amended. uk nationals: clarification on reporting requirements for uk nationals in third countries reporting timelines: clarification on deadlines and requirements for record keeping and reporting activity under the general licences. more information can be found here. 218 general licence – publication notice 20 december 2023 implemented under regulation 64 of the 2019 uk-russia regulations 20 december 2023 amendments to general licences - int/2022/2469656, int/2022/2470256, int/2022/2470056, int/2022/2470156, int/2023/2660772 and int/2023/3074680 219 financial sanctions notice 21 december 2023 amends the 2019 uk-russia regulations 21 december 2023 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: yuri alekseyevich soloviev 220 general licence: permitted payments to uk insurance companies int/2022/2009156 22 july 2022 and amended 17 august 2022 15 december 2023 06 february 2024 15 february 2024 under all uk autonomous sanctions regulations 15 february 2024 ofsi amended general licence - int/2022/2009156 to remove reference to frozen uk bank accounts from permissions 4.1, 4.3.1, and 6.1 to make clear that payments by dps are not restricted to those made from frozen funds; and the language in permission 5.1 and 6.6 has been clarified. 221 financial sanctions notice 22 february 2024 amends the 2019 uk-russia regulations 22 february 2024 50 entries have been added to and 3 have been amended on the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. more information can be found in the notice. further information can be found in the annex to the notice here. 222 financial sanctions notice 22 february 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 22 february 2024 2 entries has been added to the belarus financial sanctions regime and are now subject to an asset freeze: jsc planar precise electro-mechanics plant further information can be found in the annex to the notice here. 223 financial sanctions notice 23 february 2024 amends the 2019 uk-russia regulations 23 february 2024 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trusts services sanctions: ilya borisovich brodskiy 224 the russia (sanctions) (eu exit) (amendment) regulations 2024 28 february 2024 amends the 2019 uk-russia regulations 1 march 2024 on 1 march 2024, the uk government issued a detailed guidance on the measures concerning russian diamonds processed in third countries and the key components of this guidance are: regulations overview: prohibits import of diamonds meeting specific criteria, including russian origin and processing in third countries. applies to diamonds equal to or larger than 1 carat from 1 march 2024, and 0.5 carats from 1 september 2024. guidance on compliance: traders must provide evidence of supply chain history consistent with regulations. required documentation includes weight, country of origin, processing details, and compliance attestation. licensing provisions: traders can apply for individual licences for prohibited imports, subject to specific criteria. general trade licence allows import of certain diamonds processed outside russia before 1 march 2024, with record-keeping requirements. enforcement and due diligence: traders may need to provide evidence of compliance at the border. hm revenue and customs is responsible for enforcement and investigating offenses. non-compliance may result in criminal penalties. for detailed information, refer to the statutory guidance on russia sanctions here the general trade licence for sanctioned russian diamonds processed in third countries can be found here. the russia (sanctions) (eu exit) (amendment) regulations 2024 can be accessed here and the explanatory memorandum here. 225 general licence – court funds office payments int/2024/4398024 29 february 2024 implemented under regulation 64 of the 2019 uk-russia regulations 29 february 2024 under this licence, subject to the conditions below: a person may make permitted payments, being the payment of monies owed to designated persons into civil court pursuant to a court order, into a bank account held by the court funds office, following confirmation by the court funds office of the relevant bank details. the court funds office may receive permitted payments from a person. a relevant uk institution may carry out any activity necessary to effect the permissions listed in paragraph above. reporting requirements - a person making a payment in the manner described above (see paragraph 4 of this general licence) must, within 14 days of completing such a transaction, provide hm treasury with details of the payments and supporting evidence of the name of the designated person; the amount(s) paid; a copy of the court order; and the date on which the funds were paid. record-keeping requirements - a person must keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years. 226 financial sanctions notice 1 march 2024 amends the 2019 uk-russia regulations 1 march 2024 the following entry has been corrected under the russia financial sanctions regime and remains subject to an asset freeze and trusts services sanctions: vladimir vladimirovich mikheychik 227 financial sanctions notice 5 march 2024 amends the 2019 uk-russia regulations 5 march 2024 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: igor viktorovich makarov 228 the russia (sanctions) (overseas territories) (amendment) order 2024 13 march 2024 amends the russia (sanctions) (overseas territories) order 2020 14 march 2024 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (“the principal order”). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (“the russia sanctions regulations”) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have recently been amended by the russia (sanctions) (eu exit) (amendment) (no. 4) regulations 2023 (s.i. 2023/1364) (“the amending regulations”). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations. 229 general licence – active denizcilik and beks ships transit to port and wind down > int/2024/4576632 28 march 2024 implemented under regulation 64 of the 2019 uk-russia regulations 28 march 2024 this general licence permits insurance and other services to be paid for in respect of vessels currently at sea managed by active denizcilik to facilitate their entry to port, and to permit persons to wind down their relationships involving both active denizcilik and beks gemi for the duration of this licence. 230 general licence under the russia regulations and the belarus regulations legal services general licence int/2024/4671884 26 april 2024 implemented under regulation 64 of the 2019 uk-russia regulations 29 april 2024 legal services general licence expired and replaced - on 28 april 2024, general licence int/2023/3744968 expired. on monday 29 april 2024, a new general licence has come into effect covering legal services - general licence int/2024/4671884 231 financial sanctions notice 3 may 2024 amends the 2019 uk-russia regulations 3 may 2024 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: sarvar ismailov 232 financial sanctions notice 8 may 2024 amends the 2019 uk-russia regulations 8 may 2024 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: said mikhailovich gutseriev 233 financial sanctions general guidance - updated 13 may 2024 section 6 - licensing 13 may 2024 section 6 licensing: ofsi has amended its guidance on our approach to licensing grounds for uk regimes, including updating the definitions for extraordinary expenses and extraordinary situations. 234 financial sanctions notice 17 may 2024 amends the 2019 uk-russia regulations 17 may 2024 the following entry has been added to the russia financial sanctions regime and remains subject to an asset freeze and trusts services sanctions: vostochnaya stevedore limited liability company 235 russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2024 24 may 2024 amends the 2019 uk-russia regulations 28 may 2024 these amendments modify the existing russia (sanctions) (eu exit) regulations 2019 under the sanctions and anti-money laundering act 2018. these updates aim to enhance the effectiveness of existing sanctions against russia and come into force from 28 may 2024 key changes include: expanded designation criteria: new activities that can lead to a person being designated under sanctions have been added. updated ship specification criteria: additional activities that can result in a ship being specified under the sanctions are now included. read the full russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2024, here. 236 general licence – funds of non-designated third parties involving designated credit or financial institutions (personal remittances) int/2024/4761108 28 may 2024 implemented under regulation 64 of the 2019 uk-russia regulations 28 may 2024 funds of non-designated third parties involving designated credit or financial institutions (personal remittances) general licence issued. general licence int/2024/4761108 allows a person to make use of the retail banking services of a designated credit or financial institution provided that the payments made or received are intended for the personal use of a person. the general licence and its publication notice can be found here. 237 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments int/2022/1280876 01 march 2022 amended 01 april 2022, 22 april 2022, 22 august 2022, 06 october 2022, 24 february 2023, 02 january 2024, and 31 may 2024. implemented under regulation 64 of the 2019 uk-russia regulations 31 may 2024 general licence int/2022/1280876 was amended to permit a scheme of arrangement prepared by the joint administrators of vtb capital plc. for full details of the new definitions and permissions that are associated with this amendment ofsi recommends consulting the copy of the licence, in particular paragraphs 5.3(a) – 5.7. 238 financial sanctions notice 31 may 2024 amends the 2019 uk-russia regulations 31 may 2024 the following entry has been amended under the russia financial sanctions regime and is still subject to an asset freeze: dmitry vladimirovich konov. 239 financial sanctions notice 13 june 2024 amends the 2019 uk-russia regulations 13 june 2024 42 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions. further information can be found in the annex to this notice. 240 financial sanctions notice 14 june 2024 amends the 2019 uk-russia regulations 14 june 2024 the following entries have been corrected under the russia financial sanctions regime and are still subject to an asset freeze and trusts services sanctions: central counterparty national clearing centre and llc kompaniya amg. 241 general licence: payments to the fca int/2024/4836676 20 june 2024 uk autonomous sanctions regulations 20 june 2024 this general licence allows for payments to the financial conduct authority (fca) from a designated person (dp), or on behalf of a dp. 242 financial sanctions notice 25 june 2024 amends the 2019 uk-russia regulations 25 june 2024 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions: aleksei nikolaevich filippovskii 243 financial sanctions notice 26 june 2024 amends the 2019 uk-russia regulations 26 june 2024 the following entries have been amended under the russia financial sanctions regime and are still subject to an asset freeze and trust services sanctions: the following entries have been amended and are still subject to an asset freeze: pavel sergeevich barchugov konstantin denisov fractal marine dmcc 244 general licence: payments for statutory audits int/2024/4888228 27 june 2024 uk autonomous sanctions regulations 27 june 2024 this general licence allows for payments to statutory auditors for a statutory audit from a designated person (dp), or on behalf of a dp. 245 general licence – oil price cap: exempt projects and countries int/2022/2470156 04 december 2022 amended 05 january 2023 14 september 2023 28 june 2024 implemented under regulation 64 of the 2019 uk-russia regulations 28 june 2024 on 28 june, the office of financial sanctions implementation (osfi) updated the oil price cap general licence: exempt projects and countries – int/2022/2470156– to extend the sakhalin-2 project expiration date to the 28 june 2025. ofsi has also updated the associated publication notice 246 general licence: payments to revenue authorities int/2024/4881897 1 july 2024 uk autonomous sanctions regulations 1 july 2024 on 1 july 2024, general licence int/2024/4881897 (the general licence) was issued. this general licence allows for payments to be made to the revenue authorities by a uk designated person (dp), or on behalf of a dp. 247 general licence: payments for visa application services int/2024/4907888 3 july 2024 uk autonomous sanctions regulations 3 july 2024 this general licence allows for payments to visa application services providers from a designated person (dp), or on behalf of a dp. 248 general licence – sale, divestment and transfer of financial instruments held by the national settlement depository and payment of safe keeping fees to the national settlement depository int/2024/4919848 3 july 2024 implemented under regulation 64 of the russia (sanctions) (eu exit) (regulations) 2019 3 july 2024 this general licence allows for the sale, divestment or transfer of financial instruments held at the national settlement depository of russia (nsd), and the payment of safe keeping fees to the nsd for the holding of such financial instruments. 249 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments int/2022/1280876 01 march 2022 amended on 01 april 2022, 22 april 2022, 22 august 2022, 06 october 2022, 24 february 2023, 02 january 2024, 31 may 2024, and 23 july 2024. implemented under regulation 64 of the russia (sanctions) (eu exit) (regulations) 2019 23 july 2024 general licence int/2022/1280876 on russian banks. this general licence was amended to change permission 5.2, specifically the insolvency proceedings that apply to owh se (previously known as vtb bank (europe) se), the eu subsidiary. 250 the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2024 30 july 2024 made under the sanctions and anti-money laundering act 2018 (c. 13) (samla), and amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations) 31 july 2024 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) (samla) and amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations). they revoke and replace the russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2024 (s.i. 2024/695) (the 2024 regulations) regulation 3 makes amendments to the designation criteria in regulation 6 of the 2019 regulations to specify additional activities for which a person may be designated. regulation 4 makes amendments to the ship specification criteria in regulation 57f of the 2019 regulations to specify additional activities for which a ship may be specified. regulation 5 revokes the 2024 regulations for the reason explained above. 251 general licence – sale, divestment and transfer of financial instruments held by the national settlement depository and payment of safe keeping fees to the national settlement depository int/2024/4919848 2 august 2024 implemented under regulation 64 of the russia (sanctions) (eu exit) (regulations) 2019 2 august 2024 the general licence int/2024/4919848 allows the sale, divestment, and transfer of financial instruments held by the national settlement depository (nsd) and the payment of safekeeping fees to nsd. this licence exempts certain actions from prohibitions under the russia (sanctions) (eu exit) regulations 2019. it defines key terms, outlines permissions for relevant institutions, and mandates record-keeping for six years. the licence is effective from 3 july 2024, to 12 october 2024, and may be altered by hm treasury. 252 financial sanctions notice 9 august 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 9 august 2024 the following 7 entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze: aleksey valerievich lazarenko andrei sergeevich palchyk filip vladimirovich sturchanka denis anatolievich tolstenkov jsc niievm ojsc stankogomel ruchservomotor llc ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 253 financial sanctions notice 26 september 2024 amends the 2019 uk-russia regulations 26 september 2024 the following entries have been added to the russian financial sanctions regime and are now subject to an asset freeze and trust services sanctions: ocean speedstar solutions opc pvt ltd white fox ship management fzco 254 general licence: payment to water companies for water & sewage int/2023/3179120 21 september 2023 updated 1 october 2024 uk autonomous sanctions regulation 21 september 2023 general licence int/2023/3179120 was updated as follows: the definition of uk designated persons(dps) was amended to: those individuals or entities designated (or owned or controlled by an individual or an entity designated) for the purposes of an asset freeze by the uk under the uk autonomous sanctions regulations, excluding those designated for the purpose of compliance with united nations obligations. the definition of return payments was amended to: a payment payable by a water company to a uk dp in connection with water and/or sewerage services to a uk property owned or rented by the dp and arising from: an overpayment by the dp, a credit on the account of the dp, a billing adjustment (whether or not as a result of error) by the water company, termination of the services. the validity of the general licence is now indefinite. 255 financial sanctions notice 3 october 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 3 october 2024 the following entry has been added to the belarus financial sanctions regime and is now subject to an asset freeze: cjsc alfa bank belarus 256 the russia (sanctions) (overseas territories) (amendment) (no. 2) order 2024 2 october 2024 amendment of the russia (sanctions) (overseas territories) order 2020 3 october 2024 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (“the principal order”). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (“the russia sanctions regulations”) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have recently been amended by the russia (sanctions) (eu exit) (amendment) (no. 5) regulations 2023 (s.i. 2023/1367), the russia (sanctions) (eu exit) (amendment) regulations 2024 (s.i. 2024/218), the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2024 (s.i. 2024/900) (together, “the amending regulations”). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations. 257 financial sanctions notice 11 october 2024 amends the 2019 uk-russia regulations 11 october 2024 the following entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze and trust services sanctions: andrey igorevich melnichenko grigory vikotorovitsj berezkin 258 general licence: government debt payments int/2024/5294388 14 october 2024 uk autonomous sanctions regulations 14 october 2024 the general licence allows persons to make and facilitate payments in respect of uk government debt where either the legal holder or the direct or indirect recipient or beneficiary of that payment is a uk dp or uk prohibited person provided the payments are held in frozen accounts or uk prohibited persons accounts. the general licence and its publication notice can be found here. 259 financial sanctions notice 17 october 2024 amends the 2019 uk-russia regulations 17 october 2024 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: semyon mkrtychovich simonyan 260 ofsi general licence under the russia regulations and the belarus regulations int/2024/5334756 25 october 2024 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations 29 october 2024 on 28 october 2024, general licence int/2024/4671884 will expire. on 29 october 2024, a new general licence will come into effect covering legal services - general licence int/2024/5334756 (the general licence). the general licence and its reporting forms can be found on the legal services general licence page on gov.uk. anybody intending to use the general licence should consult the copy for full details of the definitions, permissions and usage requirements. the publication notice lists the main changes to support users of this licence. 261 financial sanctions notice 28 october 2024 amends the 2019 uk-russia regulations 28 october 2024 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: ilya andreevich gambashidze andrey naumovich perla nikolai aleksandrovich tupikin ano dialog social design agency structura national technologies ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 262 general licence: payment to energy companies for gas and/or electricity int/2022/2300292 17 november 2022 amended 24 february 2023, 13 october 2023, 15 december 2023, 29 february 2024, and 29 october 2024. uk autonomous sanctions regulations 29 october 2024 general licence int/2022/2300292 was amended to: make clear that the definition of uk dps includes entities owned or controlled by a designated individual or entity; and excludes those designated for the purpose of compliance with united nations obligations. add heating and/or hot water powered by gas or electricity from an external source such as through a district heating network; and meters related to district heating networks to the “permitted payments” definitions section. update the reference to the energy bills discount support scheme (ebds) in the “return payments” definitions section. update the list of the uk autonomous sanctions regulations schedules contained within annex 1 so that all the relevant regulations are included. 263 financial sanctions notice 7 november 2024 amends the 2019 uk-russia regulations 7 november 2024 47 entries have been added to the consolidated list and are now subject to an asset freeze and trusts services sanctions. further information can be found in the annex to this notice. 264 general licence – payments made in the year 2022 between non-designated third parties involving designated credit or financial institutions (“correspondent banking - 2022 blocked payments”) int/2024/5394840 7 november 2024 under regulation 64 of the russia regulations 7 november 2024 this general licence allows relevant institutions to process payments made in the year 2022 from or via a designated credit or financial institution, provided that the original sender and original intended recipient are not designated persons. 265 the sanctions (eu exit) (miscellaneous amendments) (no. 2) regulations 2024 14 november 2024 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13). they make miscellaneous amendments to most of the existing sanctions regulations. 5 december 2024 and one measure on 14 may 2025 changes to sanctions legislation introduced through the sanctions (eu exit) (miscellaneous amendments) (no.2) regulations 2024 and faqs updated. on 14 november 2024, the sanctions (eu exit) (miscellaneous amendments) (no.2) regulations 2024 was laid in parliament. this instrument introduces numerous changes to improve ofsi’s intelligence on industry’s compliance, strengthen ofsi’s enforcement powers, enable ofsi to deal with licensing applications more efficiently, and clarify financial sanctions legislation where there is existing uncertainty. all measures except for one will come into force on 5 december 2024. the extension of reporting obligations to high value dealers, art market participants, letting agents and insolvency practitioners will come into force on 14 may 2025. the ofsi’s frequently asked questions page has been updated from 125-131 to clarify the use of regulatory payments exceptions. click here to view. 266 financial sanctions notice 15 november 2024 amends the 2019 uk-russia regulations 15 november 2024 on 15 november 2024 the foreign, commonwealth and development office updated the uk sanctions list on gov.uk. this list provides details of those designated under regulations made under the sanctions act. the following entries have been amended under the russia financial sanctions regime and are still subject to an asset freeze and trust services sanctions: anatoly ilyich bibilov juhang aviation technology (shenzhen) co., limited bringing the entries in line with the uk sanctions list, the following entries have been corrected under the russia financial sanctions regime and remain subject to an asset freeze and trust services sanctions: konstantin yurievich mirzayants virmavia ou the following entry has been removed under the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: didier casimiro 267 financial sanctions notice 19 november 2024 amends the 2019 uk-russia regulations 19 november 2024 10 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trusts services sanctions. more information can be found in the notice. ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further information can be found in the annex to this notice. 268 financial sanctions notice 25 november 2024 amends the 2019 uk-russia regulations 25 november 2024 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: alfastrakhovanie plc vsk ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 269 general licence - int/2024/4836676 general licence - int/2023/3626884 general licence – int/2023/3781228 general licence - int/2024/4881897 5 december 2024 sanctions and anti-money laundering act 2018 (the sanctions act) 5 december 2024 general licences - int/2024/4836676, int/2023/3626884, int/2023/3781228 and int/2024/4881897 revoked these general licences have been revoked. the new required payments exception allows for certain payments to be made from, or on behalf of, non-un designated persons to the authorities covered by these general licences, without the need for an ofsi licence. 270 financial sanctions notice 9 december 2024 amends the 2019 uk-russia regulations 9 december 2024 the following entry has been added to the russia financial sanctions regime and is now subject to an asset freeze and trust service sanctions: anto joseph 271 financial sanctions notice 17 december 2024 amends the 2019 uk-russia regulations 17 december 2024 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: 2rivers dmcc 2rivers pte ltd 272 financial sanctions notice 18 december 2024 amends the 2019 uk-russia regulations 18 december 2024 the following entry has been amended under the russia financial sanctions regime and is still subject to an asset freeze and trust services sanctions: autel robotics co., ltd 273 financial sanctions notice 19 december 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 19 december 2024 the following entry has been amended under the belarus financial sanctions regime and is still subject to an asset freeze: mikail safarbekovich gutseriev 274 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments int/2022/1280876 01 march 2022amended1 april 202222 april 202222 august 20226 october 202224 february 20232 january 202431 may 202423 july 20248 january 2025 under regulation 64 of the russia regulations 8 january 2025 general licence int/2022/1280876 was amended to add permission 5.3a which states that no distributions on vtb bank pjsc’s claim should be made without first deducting from the distributions the value of any vtb capital plc assets which have been or are subject to vtb bank pjsc enforcement action, and the vtb group receivables; and statutory interest should not be paid for any time over which distributions are not paid because of these deductions. 275 financial sanctions notice 9 january 2025 amends the 2019 uk-russia regulations 9 january 2025 the following entry has been amended to the russia financial sanctions regime and is still subject to an asset freeze and trust services sanctions: zapchasttrade llp 276 financial sanctions notice 10 january 2025 amends the 2019 uk-russia regulations 10 january 2025 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: pjsc surgutneftegas gazprom neft 277 general licence: russian oil exempt projects int/2025/5635700 10 january 2025 under regulation 64 of the russia regulations 10 january 2025 this general licence allows for the continuation of business operations with the relevant subsidiary to the extent they are in relation to the exempt projects (as defined in the licence). 278 general licence: russian oil majors wind down int/2025/5635701 10 january 2025 under regulation 64 of the russia regulations 10 january 2025 this general licence allows for a wind down period of positions involving the gazprom neft and pjsc surgutneftegas or any entity owned or controlled by gazprom neft and pjsc surgutneftegas. 279 general licence interim basic necessities for designated persons int/2025/5632740 14 january 2025 uk autonomous sanctions regulations 14 january 2025 this general licence allows persons to make funds available to or for the benefit of a uk designated person(dp) up to the permitted maximum in each of the two months following the date of the uk dp’s designation for the purpose of the uk dp making permitted payments. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. 280 financial sanctions notice 15 january 2025 amends the 2019 uk-russia regulations 15 january 2025 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: gazprom neft (group id: 16736) 281 financial sanctions notice 15 january 2025 amends the 2019 uk-russia regulations 15 january 2025 the following entry has also been amended on ofsi's list of investment ban targets and remains subject to an investment ban: gazprom neft (group id: 13119) 282 financial sanctions notice 27 january 2025 implemented under 2019 belarus (sanctions) (eu exit) regulations 27 january 2025 the following entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze: alevkurp ojsc andrei valerievich ananeko mikhail petrovitch bedunkevich viktor alexandrovich dubrovka igor vasilyevich karpenko pavel ivanovich kazakov andrey mikhailovich tsedrik kb unmanned helicopters (uavheli) ledmash plant jsc ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 283 general licence–oil price cap nt/2024/4423849 19 february 2024 amended 08 march 2024, 24 may 2024, and 29 january 2025. under regulation 64 of the russia regulations 29 january 2025 the oil price cap (opc) general licence (gl) – int/2024/4423849– was amended to update the combined nomenclature (cn) / harmonized system (hs) commodity code for “premium to crude”, 2710 19 43, which now falls under2710 19 42. this change does not alter uk providers use of the opc gl in relation to the supply or delivery of this oil product, prior to or following the update. providers should also continue to report to ofsi as per the gl’s reporting conditions, just updating the product code if relevant. the full list of products at the uk integrated online tariff is here for further information. 284 financial sanctions notice 30 january 2025 amends the 2019 uk-russia regulations 30 january 2025 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: nikolay ivanovich bortsov 285 financial sanctions notice 10 february 2025 amends the 2019 uk-russia regulations 10 february 2025 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: irina vladimirovna chubarova 286 financial sanctions notice 14 february 2025 amends the 2019 uk-russia regulations 14 february 2025 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: artem yuryevich chaika pavel mikhailovich fradkov joint stock company kirov energomash plant limited liability company rosatom additive technologies vladimir viktorovich selin the following entry has been amended on the russia financial sanctions regime and is still subject to an asset freeze and trust service sanctions: yuri yakovlevich chaika 287 general licence: membership fees for international organisations int/2025/5855272 21 february 2025 amends the 2019 uk-russia regulations 21 february 2025 this general licence allows international organisations to receive permitted payments transferred from an account held with gazprombank. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. 288 financial sanctions notice 24 february 2025 amends the 2019 uk-russia regulations 24 february 2025 66 entries have been added to the consolidated list under the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. further information can be found in the notice. the following entry has been added to the consolidated list under the russia financial sanctions regime and is now subject to an asset freeze, trust services sanctions and a prohibition on correspondent banking and clearing: ojsc keremet bank also the following entry has been amended on the consolidated list under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: tsargrad ooo ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 289 not used not used not used not used not used 290 financial sanctions notice 27 february 2025 amends the 2019 uk-russia regulations 27 february 2025 the following entries have been corrected under the russia financial sanctions regime and are still subject to an asset freeze and trust services sanctions: vasily vitalyevich abramov natalya aleksandrovna tyurina jsc siberia airlines monolink group fzco the following entry has been corrected and is still subject to an asset freeze, trust services sanctions and a prohibition on correspondent banking and clearing: ojsc keremet bank 291 financial sanctions notice 7 march 2025 amends the 2019 uk-russia regulations 7 march 2025 the following entries have been removed from the russia financial sanctions regime and are no longer subject to an asset freeze or trust services sanctions: rosbank pjsc active denizcilik ve gemi isletmeciligi anonim sirketi the following entry has been amended on the russia financial sanctions regime and is still subject to an asset freeze, trust services sanction and a prohibition on correspondent banking and clearing: tbank 292 general licence – petrol station payments for united kingdom nationals in kyrgyzstan and tajikistan int/2025/5886860 14 march 2025 under regulation 64 of the russia regulations 14 march 2025 general licence - int/2025/5886860, allows a uk national to purchase petrol from the designated persons(dp) at any petrol station in kyrgyzstan and tajikistan that is either owned by the dp or sells the dp’s petrol, provided that the petrol is for that uk national’s personal vehicle 293 financial sanctions notice 19 march 2025 amends the 2019 uk-russia regulations 19 march 2025 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions: farkhad akhmedov the following entries have been corrected and are still subject to an asset freeze and trust services sanctions: mcr global elektronik sanayi ve ticaret ltd sirketi poly technologies, inc 294 financial sanctions notice 19 march 2025 implemented under 2019 belarus (sanctions) (eu exit) regulations 19 march 2025 the following entry has been amended and is still subject to an asset freeze: alexander vasilevich shakutin 295 financial sanctions notice 20 march 2025 amends the 2019 uk-russia regulations 20 march 2025 the following entry has been amended and is still subject to an asset freeze and trust services sanctions: red box energy services pte ltd 296 general licence: humanitarian activity int/2022/1947936 7 july 2022 amended:20 june 202324 march 2025 under regulation 64 of the russia regulations 24 march 2025 general licence int/2022/1947936 was amended to remove rosbank pjsc and tinkoff bank from annex i; and add tbank to annex i 297 general licence – mongolia energy payments int/2022/2085212 15 august 2022 amended 27 july 2023 and 24 march 2025. under regulation 64 of the russia regulations 24 march 2025 general licence int/2022/2085212, was amended such that rosbank pjsc has been removed from the definition of sanctioned banks; and tbank has been added to the definition of sanctioned banks 298 financial sanctions notice 24 march 2025 amends the 2019 uk-russia regulations 24 march 2025 the following entry has been amended and is still subject to an asset freeze and trusts services sanctions: tigran oganesovich khudaverdyan 299 financial sanctions notice 27 march 2025 amends the 2019 uk-russia regulations 27 march 2025 the following entries have been amended and are still subject to an asset freeze and trust service sanctions: 2rivers dmcc 2rivers pte ltd 300 general licence – lithuania rail int/2023/2883496 14 april 2023 updated27 march 2025 under regulation 64 of the russia regulations 27 march 2025 general licence int/2023/2883496, lithuania rail was extended until 23:59 on 13 april 2027 301 general licence – russia: regulatory authorities – prudential supervision, financial stability, protection of consumers or integrity of the uk financial system int/2022/1280976 01 march 2022 amended 24 february 2023, 14 april 2023, and 27 march 2025 uk autonomous sanctions regulations 27 march 2025 general licence int/2022/1280976, regulatory authorities – prudential supervision, financial stability, protection of consumers or integrity of the uk financial system was amended so that it: applies to all persons designated under the uk’s autonomous sanctions regimes listed in annex 1 of the general licence; and is extended indefinitely 302 general licence – bond amendments and restructurings for non-designated persons int/2023/2824812 28 march 2023, 28 march 2025 under regulation 64 of the russia regulations 28 march 2025 general licence int/2023/2824812, bond amendments and restructurings for non-designated persons was extended until 27 march 2026. 303 general licence – london court of international arbitration (lcia) arbitration costs int/2022/1552576 17 october 2022 amended 05 june 2023, 13 november 2023, and 15 december 2023 revoked 28 march 2025. implemented under 2019 belarus (sanctions) (eu exit) regulations 28 march 2025 general licence int/2022/1552576, london court of international arbitration (lcia) arbitration costs was revoked following the issuance of the arbitration costs general licence gl int/2025/5787748. 304 ofsi general licence under the russia regulations and the belarus regulations int/2024/5334756 25 october 2024 amended 28 march 2025 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations 28 march 2025 general licence int/2024/5334756, legal services was amended to clarify: that legal advice and/or representation in dispute resolution is included in the definition of “legal services”; and the reference to ‘owned and controlled’ applies only to companies and not individuals under the definition of “dp”. 305 general licence: arbitration costs int/2025/5787748 28 march 2025 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations 28 march 2025 general licence int/2025/5787748, arbitration costs was issued. this licence allows persons to make payments to arbitration associations and arbitrators to cover fees and expenses for their arbitration services. the general licence also permits arbitrators and arbitration associations to direct payment of, receive and use such payments to cover arbitration costs. 306 financial sanctions notice 14 april 2025 amends the 2019 uk-russia regulations 14 april 2025 the following entries have been amended and are still subject to an asset freeze: niels oscar troost and paramount energy & commodities dmcc 307 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities int/2023/3263556 01 august 2023 amended 23 august 2023 24 april 2025 under regulation 64 of the russia regulations 24 april 2025 the general licence int/2023/3263556 is extended to allow payments and other permitted activities to take place in relation to insolvency proceedings associated with gtlk and subsidiaries. 308 the russia (sanctions) (eu exit) (amendment) regulations 2025 new guidance documents: complying with technology transfer sanctions complying with sectoral software sanctions 24 april 2025 amends the 2019 uk-russia regulations 24 april 2025 effective april 24, 2025, the uk introduced updated trade sanctions on russia under the russia (sanctions) (eu exit) (amendment) regulations 2025. these measures expand export, import, and technology transfer restrictions to curtail russia's military-industrial operations and economic resilience. newly sanctioned items include chemicals, electronics, machinery, and metals, with additional prohibitions on sectoral technology and software transfers, such as industrial design tools and oil and gas-related software. new import bans target helium and synthetic diamonds processed in third countries to close potential revenue streams for russia. these measures closely align with sanctions imposed by allies like the us and eu for maximum impact against russia's war economy. to assist businesses with compliance, the office of financial sanctions implementation (ofsi) has issued two new guidance documents. the first, complying with technology transfer sanctions, outlines rules for managing restricted technologies. the second, complying with sectoral software sanctions, focuses on software transfer restrictions, including intangible formats like downloads and cloud services. these sanctions underline the uk's commitment to supporting ukraine while disrupting russia's ability to sustain its aggression. businesses are urged to review the updated regulations and guidance to ensure full compliance. 309 general licence: membership fees for international organisations int/2025/5855272 21 february 2025 amended 28 april 2025 under regulation 64 of the russia regulations 28 april 2025 general licence int/2025/5855272, membership fees for international organisations was amended to include the international maritime organisation. 310 ofsi general licence under the russia regulations and the belarus regulations int/2025/6160920 28 april 2025 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations. 28 april 2025 general licence int/2025/6160920, legal services was issued. streamlined guidance for legal services under sanctions. the ofsi general licence permits specified payments for legal services to assist designated entities (dp) under the russia & belarus regulations, ensuring compliance with strict conditions. activities must adhere to financial caps, reporting requirements, and restrictions on funds benefiting dps directly. comprehensive record-keeping and adherence to hourly rate limits are non-negotiable. misuse or breaches render the licence invalid, risking penalties. any persons intending to use general licence int/2025/6160920 should consult the copy of the licence for full details of the definitions, permissions, and usage requirements as these do not mirror those of general licences int/2022/2252300, int/2023/2954852, int/2023/3744968, int/2024/4671884 or int/2024/5334756. 311 general licence – integration of credit suisse group ag and ubs group ag int/2025/6135848 28 april 2025 under regulation 64 of the russia regulations 28 april 2025 general licence int/2025/6135848, integration of credit suisse group ag and ubs group ag was issued. the general licence allows the transfer of assets and liabilities as part of the integration of credit suisse group ag into ubs group ag. 312 financial sanctions notice 1 may 2025 amends the 2019 uk-russia regulations 1 may 2025 the following entry has been amended and is still subject to an asset freeze and trust service sanctions: albert kashafovich shigabutdinov 313 financial sanctions notice 9 may 2025 amends the 2019 uk-russia regulations 9 may 2025 uk government has sanctioned 101 ships, 5 individuals, and 4 entities under the russia sanctions regime. further details the uk full list of russia sanctions targets on 9 may 2025 can be accessed here 314 general licence – amsterdam trade bank n.v – winding down, basic needs and insolvency related payments int/2022/1678476 12 may 2022 amended 28 march 2023 and 12 may 2025 under regulation 64 of the russia regulations 12 may 2025 the updated general licence, allows amsterdam trade bank n.v. (atb) to conduct specific activities under the russia (sanctions) (eu exit) regulations 2019. it permits atb to make payments for basic needs, such as employee remuneration, taxes, and supplier payments. additionally, it authorises actions related to insolvency proceedings, including payments and the exercise of rights by insolvency practitioners, provided no funds benefit designated persons under the russia regulations. the licence also facilitates the winding down of transactions involving atb or its subsidiaries, including loan restructuring and closing out positions, with relevant institutions allowed to process these payments. the licence requires atb, its subsidiaries, or involved parties to notify hm treasury within seven days of conducting permitted activities and maintain accurate records for six years. 315 financial sanctions notice 20 may 2025 amends the 2019 uk-russia regulations 20 may 2025 the uk government has sanctioned 20 individuals, 62 entities, and 18 ships under the russia (sanctions) (eu exit) regulations 2019. this package targets russian revenue generating sectors, including energy, communications and financial services, the russian military industrial complex (rmic) and its third country suppliers, and malign actors involved in democratic interference and russia’s information war on ukraine. further details the uk full list of russia sanctions targets on 20 may 2025 can be accessed here. 316 general licence – wind down of positions involving st petersburg currency exchange and non-bank credit organisation joint-stock company petersburg settlement centre 20 may 2025 under regulation 64 of the russia regulations 20 may 2025 general licence int/2025/6275812, wind down of positions involving st petersburg currency exchange and non-bank credit organization joint-stock company petersburg settlement center was issued. the general licence allows for persons to wind down from any transactions involving the designated persons to which that person is a party. any persons intending to use general licence int/2025/6275812 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 317 general licence – deposit insurance agency permitted payments 20 may 2025 under regulation 64 of the russia regulations 20 may 2025 the general licence int/2025/6279615, deposit insurance agency permitted payments was issued. the general licence allows for persons to make insurance premiums payments to the deposit insurance agency. any persons intending to use general licence int/2025/6279615 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 318 general licence – russia designated persons – charities and interim managers and trustees 30 may 2022 amended 28 march 2023 and 21 may 2025 under regulation 64 of the russia regulations 21 may 2025 the general licence int/2022/1834876 was extended until 23:59 on 30th may 2028. any persons intending to use general licence int/2022/1834876 should consult the copy of the licence for full details of the permissions and usage requirements. 319 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities int/2023/3263556 01 august 2023 amended 23 august 2023, 24 april 2025, 12 june 2025, and 13 june 2025 under regulation 64 of the russia regulations 13 june 2025 ofsi general licence int/2023/3263556, gtlk companies and their subsidiaries – insolvency related payments and activities amended on 13 june 2025, the general licence int/2023/3263556 was amended to: add regulation 18a to the regulations that are exempt under the general licence; add definitions for notes, noteholders, trustee, relevant non-uk institution, uk prohibited persons and uk prohibited persons account; make it clear in permission 4.2 that any funds made available to dps must be held in a frozen account and any economic resources made available must be treated as frozen; add permission 4.3 which states that financial services for foreign exchange reserve and asset management must not be provided to a uk prohibited person unless any resulting payments are credited to a uk prohibited person’s account; make corresponding clarificatory changes to permission 5, the notification requirement and the record-keeping requirement; and add a new reporting requirement. 320 financial sanctions notice 13 june 2025 amends the 2019 uk-russia regulations 13 june 2025 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze: aleksey leonidovich fisun. 321 financial sanctions notice 17 june 2025 amends the 2019 uk-russia regulations 17 june 2025 uk government has sanctioned 4 individuals, 6 entities, and 20 ships under the russia (sanctions) (eu exit) regulations 2019. 322 financial sanctions notice 26 june 2025 amends the 2019 uk-russia regulations 26 june 2025 16 entries have been amended on the consolidated list and remain subject to an asset freeze and trust services sanctions. further information can be found in the annex to this notice, here. 323 general licence: russian oil exempt projects int/2025/5635700 10 january 2025 amended 27 june 2025 under regulation 64 of the russia regulations 27 june 2025 on the 27 june 2025, the date of expiration of the sakhalin-2 project was extended to 28 june 2026. any persons intending to use general licence int/2025/5635700 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. ofsi has also updated the associated publication notice. 324 general licence – oil price cap: exempt projects and countries int/2022/2470156 4 december 2022 amended on 05 january 2023, 14 september 2023, 28 june 2024, and 27 june 2025 under regulation 64 of the russia regulations 27 june 2025 on 27 june 2025, the office of financial sanctions implementation updated the oil price cap general licence: exempt projects and countries – int/2022/2470156– to extend the sakhalin-2 project expiration date to the 28 june 2026. ofsi has also updated the associated publication notice. 325 financial sanctions notice 01 july 2025 amends the 2019 uk-russia regulations 01 july 2025 the following entries have been amended and are still subject to an asset freeze and trust services sanctions: yegor yurievich karasev anatoliy moiseevich cherner the main directorate of deep-sea research of the ministry of defence of the russian federation. 326 general licence: non-designated third-party brokerage accounts held at designated brokerage firms (brokerage accounts) int/2025/6641960 18 july 2025 under regulation 64 of the russia regulations and regulation 32 of the republic of belarus regulations 18 july 2025 the general licence int/2025/6641960 was issued under the russia and the belarus regulations which allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker. this general licence only applies where the only designated party involved is the designated broker. any persons intending to use general licence int/2025/6641960 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 327 financial sanctions notice 18 july 2025 amends the 2019 uk-russia regulations 18 july 2025 the following entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions: african initiative anna sergeevna zamaraeva victor aleksandrovich lukovenko artyom sergeevich kureyev 328 general licence – oil price cap int/2024/4423849 19 february 2024 amended 8 march 2024, 24 may 2024, 29 january 2025, 13 february 2025, and 18 july 2025. under regulation 64 of the russia regulations 18 july 2025 the uk, alongside the eu, is lowering the oil price cap on seaborne russian crude oil from $60 to $47.60, reducing russia’s income and ability to fund its war machine. the lowered oil price cap of $47.60 per barrel comes into effect at 23:01 (bst), tuesday, 2 september 2025. this action forms part of the uk’s ongoing commitment to supporting ukraine in its struggle against russia’s illegal war of aggression. this will apply to all services captured by the oil price cap, including maritime transportation and the provision, directly, or indirectly, of brokering services or financial services or funds, related to the maritime transport of russian crude from a place in russia to third countries or from one third country to another. for any trades with an effective date of contract before 23:01 (bst), tuesday, 2 september 2025 and which are compliant with the existing price cap of $60 per barrel, there will be a wind-down period of 45 days. after the wind-down period of 45 days, ending at 23:01 (bst), friday, 17 october 2025, the lower price cap of $47.60 per barrel takes effect. this measure is necessary to give uk businesses the required time to adjust and ensure the consistent implementation of the price cap by all operators. ofsi has published faqs 154 to 161 today to support industry to adapt to the lower price cap and explain the 45-day wind-down period. market participants must comply with the usual reporting and attestation requirements imposed by the oil price cap general licence. 329 general licence – wind down of positions involving litasco middle east dmcc 21 july 2025 under regulation 64 of the russia regulations 21 july 2025 on 21 july 2025, general licence int/2025/6488808, wind down of positions involving litasco middle east dmcc was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. any persons intending to use general licence int/2025/6488808 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 330 general licence – intershipping services llc wind-down general licence 21 july 2025 under regulation 64 of the russia regulations 21 july 2025 the general licence int/2025/6397444, intershipping services llc wind-down was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. any persons intending to use general licence int/2025/6397444 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 331 financial sanctions notice 21 july 2025 amends the 2019 uk-russia regulations 21 july 2025 the following entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions: intershipping services llc litasco middle east dmcc the following entries have been amended and are still subject to an asset freeze and trust services sanctions: yegor yurievich karasev ojsc keremet bank 332 general licence: intershipping services llc general licence 21 july 2025 under regulation 64 of the russia regulations 21 july 2025 the general licence int/2025/6403704 was issued. the general licence allows for the continuation of business operations of vessels owned or operated by, or on behalf of, the government of the gabonese republic. 333 financial sanctions notice 20 august 2025 amends the 2019 uk-russia regulations 20 august 2025 uk government has designated the following 5 entities and 3 individuals under the russia sanctions regime: kantemir kaparbekovich chalbayev zhanyshbek uulu nazarbek leonid shumakov altair holding sa cjsc tengricoin grinex llc grinex llc capital bank of central asia old vector llc 334 general licence – continuation of business of evraz plc’s north american subsidiaries 5 may 2022 revoked 3 september 2025 under regulation 64 of the russia regulations n/a ofsi general licence int/2022/1710676 revoked - on 3 september 2025, following the sale of evraz's n. american business, general licence (int/2022/1710676) on the continuation of business of evraz plc’s north american subsidiaries has been revoked. 335 financial sanctions notice 11 september 2025 amends the 2019 uk-russia regulations 11 september 2024 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze and trust service sanctions: ilya borisovich brodskiy 336 financial sanctions notice 12 september 2025 amends the 2019 uk-russia regulations 12 september 2025 the uk government has designated the 27 entities, 3 individuals and specified 70 ships under the russia sanctions regime. for more detailed information, the uk sanctions list from fcdo lists which people, entities and ships are designated or specified under the sanctions and anti-money laundering act 2018, and why, can be accessed here the ofsi consolidated list from hmt provides information relating to asset freeze and investment ban targets across all financial sanctions regimes implemented in the uk, can be found here 337 general licence for int/2025/5886860 - here to see the general licence for int/2025/5635700 - here 10 january 2025 amended 27 june 2025 and 15 october 2025. under regulation 64 of the russia regulations 15 october 2025 on 15 october 2025, the definitions of a dp and a subsidiary in general licences int/2025/5886860 and int/2025/5635700 were amended to include pjsc lukoil oil company and pjsc rosneft oil company following their designation by the uk. 338 general licence – energy entities wind-down general licence int/2025/7538856 15 october 2025 under regulation 64 of the russia regulations 15 october 2025 on 15 october 2025 the general licence int/2025/7538856, energy entities wind-down was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. 339 general licence – russian oil majors wind down int/2025/7539056 15 october 2025 under regulation 64 of the russia regulations 15 october 2025 general licence int/2025/7539056, russian oil majors wind down was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. 340 financial sanctions notice 15 october 2025 amends the 2019 uk-russia regulations 15 october 2025 the uk government has designated the following 34 entities, 5 individuals, and specified the following 51 ships under the russia (sanctions) (eu exit) regulations 2019. 341 general licence – continuation of business of pjsc rosneft oil company’s german named subsidiaries int/2025/7598960 22 october 2025 under regulation 64 of the russia regulations 22 october 2025 on 22 october 2025, the general licence int/2025/7598960 was issued. the general licence allows a person to continue business operations involving the named subsidiaries. any persons intending to use general licence int/2025/7598960 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. ofsi has released faq 169 to accompany this licence regarding if business operations with rosneft deutschland gmbh and rn refining and marketing gmbh continue as normal with regard to uk financial sanctions. 342 general licence – legal services int/2025/7323088 22 october 2025 under uk autonomous sanctions regulations 22 october 2025 the general licence int/2025/7323088 was issued. the general licence allows a uk legal firm or uk counsel who has provided legal advice to a person designated under the uk autonomous sanctions regimes which will take effect following the expiry of legal services general licence int/2024/6160920 on 28 october 2025. any persons intending to use general licence int/2025/7323088 should consult the copy of the licence for full details of the definitions, permissions, and usage requirements as these do not mirror those of general licences int/2022/2252300, int/2023/2954852, int/2023/3744968, int/2024/4671884, int/2024/5334756 or int/2025/6160920. 2 faqs added regarding general licence int/2025/7323088 and 2 faqs withdrawn on 24 october 2025, faqs 170 and 171 were added to the faqs page to address questions around the changes of the upcoming licence int/2025/7323088 and if payments can be made from abroad into the uk. faqs 54 and 76 have been withdrawn. to see the faqs page - here 343 financial sanctions notice 23 october 2025 amends the 2019 uk-russia regulations 23 october 2025 the following entries have been amended and are still subject to an asset freeze and trust service sanctions: aleksandr aleksandrovich shulgin mihajlo perencevic alisher burkhanovich usm holdings limited narmina dadashova 344 general licence – payments made in the year 2022 between non-designated third parties involving designated credit or financial institutions (“correspondent banking - 2022 blocked payments”) int/2024/5394840 5 november 2025 under regulation 64 of the russia regulations 5 november 2025 general licence int/2024/5394840 has been extended to 7 november 2027. the definition of designated credit or financial institution has been amended. the reporting conditions have been amended. within 14 days of the end of each calendar month, a relevant institution must report to hm treasury any relevant payments processed under general licence int/2024/5394840 during that calendar month with details and supporting evidence of the amount(s) processed; the name of the original sender and the original intended recipient; the name on the account at the final institution in the chain of payments to which the funds were processed; the payment route used; and the date on which the funds were processed. 345 financial sanctions notice 19 november 2025 amends the 2019 uk-russia regulations 19 november 2025 the following entry has been added to the uk consolidated list and is now subject to an asset freeze and trust service sanctions: aeza group llc 346 general licence – continuation of business of lukoil bulgaria entities int/2025/7895596 14 november 2025 amended 20 november 2025) under regulation 64 of the russia regulations 20 november 2025 general licence int/2025/7895596 was amended to extend the subsidiaries covered to: lukoil aviation bulgaria eood; and lukoil bunker bulgaria eood. faq 173 was amended to reflect the recent update of general licence int/2025/7895596. the faq can be accessed here 347 general licence – continuation of business of lukoil international entities int/2025/8031092 27 november 2025 under regulation 64 of the russia regulations 27 november 2025 on 27 november 2025, ofsi issued general licence int/2025/8031092 under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 (“the russia regulations”) which allows for the continuation of business operations with the lukoil international entities. new content based on faq 174 has been added to the general licence, to confirm that business operations with lukoil international gmbh can continue as normal with regard to uk financial sanctions. this general licence is valid for 3 months, until 26 february 2026 (and may be extended). 348 financial sanctions notice 28 november 2025 amends the 2019 uk-russia regulations 28 november 2025 the following entry has been amended and is still subject to an asset freeze and trust service sanctions: sergey vladimirovich mikhailov 349 general licence – transactions related to agricultural commodities including the provision of insurance and other services int/2022/2349952 4 november 2022 amended 6 june 2023, 15 december 2023, and 28 november 2025) under regulation 64 of the russia regulations 28 november 2025 transactions related to agricultural commodities including the provision of insurance and other services amended. the general licence int/2022/2349952 was amended to reflect changes to schedule 3e part 2a of the russia regulations (expanding the definition of fertiliser to include those permitted under commodity code 2814 and its subheadings). the revisions relate to the grain and feed trade association receiving funds and economic resources in connection with the provision of services by or on behalf of gafta, including membership, arbitration fees, and training/certification courses, and also provide that insurance providers will not be in contravention of the russia regulations when providing professional indemnity insurance services to gafta.

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Update to EU Sanctions on Russia-Ukraine-Belarus (up to 20 November 2025)

further to our blog post on eu russia sanctions, please find below an updated table of sanctions. table.instrument-table { table-layout: auto; border-collapse: collapse; width: 100%; max-width: 100%; margin-left: auto; margin-right: auto; margin-bottom: 10px; border: 1px solid #000000; overflow-x: auto; } table.instrument-table th, table.instrument-table td { border: 1px solid #000000; padding: 5px; vertical-align: top; } table.instrument-table thead tr { color: #ffffff; background-color: #3a5dae; } table.instrument-table tbody tr:nth-child(even) { background-color: #f1f1f1; /* light grey */ } table.instrument-table h5 { font-size: 1.15em; margin: 0; } table.instrument-table p { font-size: 14px; color: #000000; margin: 0; line-height: 1.6; } table.instrument-table a { color: inherit; text-decoration: underline; } table.instrument-table li { font-size: 14px; color: #000000; padding-top: 2px; line-height: 1.6; } name of instrument date published amends or implements? comes into force summary of key provisions council regulation (eu) 2022/259 23 february 2022 regulation (eu) no 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (regulation 269) on publication date but with reference to 24 august 2022 new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. council implementing regulation (eu) 2022/260 23 february 2022 regulation 269 on publication date addition of 22 russian government figures/individuals and four entities added to the asset freeze list under regulation 269, related to the recognition by russia of donetsk and luhansk breakaway republics. council implementing regulation (eu) 2022/261 23 february 2022 regulation 269 on publication date addition of 336 members of the russian state duma to the asset freeze list under regulation 269, related to the vote on recognition of the breakaway republics. council decision (cfsp) 2022/265 23 february 2022 decision 2014/145/cfsp concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (decision 145) on publication date new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. addition of 22 russian government figures/individuals and four entities added to the asset freeze list under decision 145, related to the recognition by russia of donetsk and luhansk breakaway republics. council decision (cfsp) 2022/267 23 february 2022 decision 145 on publication date addition of 336 members of the russian state duma to the asset freeze list under decision 145, related to the vote on recognition of the breakaway republics. council regulation (eu) 2022/262 23 february 2022 regulation (eu) no 833/2014 concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (regulation 833) on publication date but with reference to 9 march 2022 new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council decision (cfsp) 2022/264 23 february 2022 decision 2014/512/cfsp concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (decision 512) on publication date new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council regulation (eu) 2022/263 concerning restrictive measures in response to the recognition of the non-government controlled areas of the donetsk and luhansk oblasts of ukraine and the ordering of russian armed forces into those areas 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. luhansk/donetsk embargo. council decision (cfsp) 2022/266 concerning restrictive measures in response to the recognition of the non-government controlled areas of the donetsk and luhansk oblasts of ukraine and the ordering of russian armed forces into those areas 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. council implementing regulation (eu) 2022/300 (regulation 300) 24 february 2022 regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus (regulation 765) on day following publication date implementing article 8a of regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus. some changes to reasoning of designation. not directly relevant to russia-ukraine conflict but contemporaneous with it. council decision (cfsp) 2022/307 24 february 2022 decision 2012/642/cfsp concerning restrictive measures in view of the situation in belarus (decision 642) on day following publication date materially equivalent to measures referred to in regulation 300. not directly relevant to russia-ukraine conflict but contemporaneous with it. decision (eu) 2022/313 of the european parliament and of the council of 24 february 2022 providing macro-financial assistance to ukraine 24 february 2022 n/a. new measure on day following publication date provision of macro-financial assistance to support ukraine’s commitment to values shared with the eu, including democracy, the rule of law, good governance, respect for human rights, sustainable development and poverty reduction, as well as its commitment to the principles of open, rule-based and fair trade. not directly relevant to russia-ukraine conflict but contemporaneous with it. council regulation (eu) 2022/328 (regulation 328) 25 february 2022 regulation 833 on day following publication date, however many measure come into force from 12 april 2022 imposition of numerous restrictive measures in various sectors of the russian economy, specifically defence, energy, aviation and finance. restrictions and prohibitions on: exports of dual-use goods and technology and on the provision of related services, as well as restrictions on exports of certain goods and technology which might contribute to russia’s technological enhancement of its defence and security sector (articles 2, 2a, 2b, 2c) the provision of public financing or financial assistance for trade with, or investment in, russia, subject to certain exceptions (article 2e) the sale, supply, transfer or export to russia of specific goods and technologies for use in oil refining, together with restrictions on the provision of related services (article 3b) export ban covering goods and technology suited for use in aviation and the space industry and prohibits the provision of insurance and reinsurance and maintenance services in relation to those goods and technology (article 3c) expanding the existing financial restrictions, in particular those on access by certain russian entities to the capital markets – including elimination of maturity periods for debt issued after 12 april 2022 (article 5) addition of new annex xii (now includes alfa bank and otkritie bank) the listing and provision of services in relation to shares of russian state-owned entities on union trading venues (article 5(5)) the acceptance of deposits exceeding certain values from russian nationals or residents (article 5b), the holding of accounts of russian clients by eu based central securities depositories (article 5e) as well as the sale of euro-denominated securities to russian clients (article 5e) bank account reporting requirements where eu bank accounts hold in excess of €100,000 (article 5g) council decision (cfsp) 2022/327 25 february 2022 decision 512 on day following publication date, however many measure come into force from 12 april 2022 equivalent to those listed under regulation 328. council regulation (eu) 2022/330 25 february 2022 regulation 269 on publication date recasting and expanding designation criteria for asset freeze under regulation 269. council decision (cfsp) 2022/329 25 february 2022 decision 145 on publication date recasting and expanding designation criteria to include persons and entities supporting and benefitting from the government of the russian federation as well as persons and entities providing a substantial source of revenue to it, and natural or legal persons associated with listed persons or entities. council implementing regulation (eu) 2022/332 (regulation 332) 25 february 2022 regulation 269 on publication date addition of: members of the russian national security council who supported russia's immediate recognition of the two self-proclaimed republics donetsk and luhansk persons who facilitated the russian military aggression from belarus, as well as those members of the state duma not yet included in that list who ratified the government decisions of the 'treaty of friendship, cooperation and mutual assistance between the russian federation and the donetsk people's republic and between the russian federation and the luhansk people's republic comprises 98 new individuals including president vladimir putin and minister of foreign affairs sergei lavrov. council decision (cfsp) 2022/331 25 february 2022 decision 145 on publication date measures equivalent to those in regulation 332. council decision (eu) 2022/333 on the partial suspension of the application of the agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia 25 february 2022 2007 agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia (2007 visa agreement) on publication date suspends application of 2007 visa agreement, including as relevant to business people and representatives of business organisations. council regulation (eu) 2022/334 28 february 2022 regulation 833 on publication date prohibition for any aircraft operated by russian air carriers, including as a marketing carrier in codesharing or blocked-space arrangements, or for any russian registered aircraft, or for any non-russian-registered aircraft which is owned or chartered, or otherwise controlled by any russian natural or legal person, entity or body, to land in, take off from or overfly the territory of the eu (article 3d). prohibition on transactions related to the management of reserves as well as of assets of the central bank of russia, including transactions with any legal person, entity or body acting on behalf of, or at the direction of, the central bank of russia, are prohibited (article 5a(4)). council decision (cfsp) 2022/335 28 february 2022 decision 512 on publication date prohibition of any transactions with the central bank of russia. russia central bank asset freeze (article 1a). denial of permission to land in, take off from, or overfly, their territories to any aircraft operated by russian air carriers, including as a marketing carrier, to any russian-registered aircraft, and to non-russian-registered aircraft which are owned or chartered, or otherwise controlled by a russian legal or natural person (article 4e). council decision (cfsp) 2022/338 on an assistance measure under the european peace facility for the supply to the ukrainian armed forces of military equipment, and platforms, designed to deliver lethal force 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 establishment of an assistance measure benefitting ukraine financed under the european peace facility (epf). the objective of the assistance measure is to contribute to strengthening the capabilities and resilience of the ukrainian armed forces to defend the territorial integrity and sovereignty of ukraine and protect the civilian population against the ongoing military aggression. provides for a centralised budget framework and reporting coordination between ministries of defence of the eu member states. council decision (cfsp) 2022/339 on an assistance measure under the european peace facility to support the ukrainian armed forces 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 provision of assistance measures calling for contributions up to €50,000,000. the funds called by the administrator for assistance measures to be used to pay expenditure within the limits approved by the committee established by decision (cfsp) 2021/509 in the 2022 amending budget corresponding to the assistance measure. council implementing regulation (eu) 2022/336 28 february 2022 regulation 269 on publication date addition of: numerous ultra-high net worth russian businessmen (oligarchs) including igor sechin, chief executive of rosneft oil co. alexey mordashov, the majority owner of steel giant severstal pao alisher usmanov mikhail fridman and petr aven, founders of alfa bank the measures also target key kremlin officials including dimitry peskov, vladimir putin’s press secretary; several journalists the eu accuses of anti-ukrainian propaganda; and military officers council decision (cfsp) 2022/337 28 february 2022 regulation 269 on publication date measures equivalent to those in regulation 336. council regulation (eu) 2022/345 1 march 2022 regulation 833 on publication date imposing further restrictive measures with regard to the provision of specialised financial messaging services to certain russian credit institutions and their russian subsidiaries, which are relevant for the russian financial system and which are already the subject of restrictive measures imposed by the union or by partner countries and, subject to certain exceptions, with regard to engagement with the russian direct investment fund. it also prohibits, subject to certain exceptions, the supply of euro banknotes to russia. these measures fall within the scope of the treaty and, therefore, in particular with a view to ensuring their uniform application in all member states, regulatory action at the level of the union is necessary. council decision (cfsp) 2022/346 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 345. council regulation (eu) 2022/350 1 march 2022 regulation 833 on publication date prohibition on the broadcasting and the facilitation of broadcasting by the following media outlets, including through transmission/distribution by any means such as cable, satellite, ip-tv, internet service providers, internet video-sharing platforms or apps: sputnik rt – russia today english rt – russia today uk rt – russia today germany rt – russia today france rt – russia today spanish these measures also suspend any broadcasting licence, authorisation or arrangement with the above entities. council decision (cfsp) 2022/351 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 350. council regulation (eu) 2022/353 2 march 2022 regulation 269 on publication date addition of 22 belarusian individuals to the asset freeze list under regulation 269. council decision (cfsp) 2022/354 2 march 2022 decision 145 on publication date equivalent to those listed under regulation 353 above. council regulation (eu) 2022/355 2 march 2022 regulation 765 on publication date renames the regulation 765 to refer expressly to the fact that these measures relate also to the involvement of belarus in the russian aggression against ukraine. introduces extensive new prohibitions with respect to dealing with belarus, some of these equivalent to the prohibitions introduced on russia under regulation 328 (eg in relation to dual-use goods and technology, goods and technology which might contribute to belarus’s military and technological enhancement), as well as a number of prohibitions with respect to wood, cement, iron, steel and rubber products and specific machinery as listed in the regulation. council decision (cfsp) 2022/356 2 march 2022 decision 642 on publication date equivalent to those listed under regulation 356 above. council implementing regulation (eu) 2022/375 4 march 2022 (but dated 3 march) regulation (eu) no 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date update following a review by the council, on the rights of defence and effective judicial protection on individuals charged with the misappropriation of ukrainian state funds, including former ukrainian president yanukovych (now thought to be in hiding in russia). council decision (cfsp) 2022/376 4 march 2022 (but dated 3 march) decision 2014/119/cfsp concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date equivalent to those listed under implementing regulation 375 above. council implementing regulation (eu) 2022/396 9 march 2022 regulation 269 on publication date adds a further 160 persons to the asset freeze list under regulation 269, including persons owning or holding senior management positions or otherwise connected to prominent russian businesses considered to support the russian government, as well as a number of persons of the federation council who ratified the government decisions to recognise the declaration of independence of the donetsk and luhansk regions. council decision (cfsp) 2022/397 9 march 2022 decision 145 on publication date equivalent to those listed under implementing regulation 397 above. council regulation (eu) 2022/394 9 march 2022 regulation 833 on publication date extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets”. this regulation also introduces a new prohibitions in relation to maritime navigation goods and technology to any natural or legal person, entity or body in russia, for use in russia, or for the placing on board of a russian-flagged vessel. council decision (cfsp) 2022/395 9 march 2022 decision 512 on publication date equivalent to those listed under regulation 394 above. council regulation (eu) 2022/398 9 march 2022 regulation 765 on publication date expands the existing financial restrictions under the belarus sanctions to include prohibitions similar to those already included under regulation 833 on russia. in particular, it prohibits the listing and provision of services in relation to shares of belarusian state-owned entities on eu trading venues. in addition, it introduces new measures which significantly limit the financial inflows from belarus to the union by prohibiting the acceptance of deposits exceeding certain values from belarusian nationals or residents, the holding of accounts of belarusian clients by the eu central securities depositories as well as the selling of euro-denominated securities to belarusian clients. it also prohibits transactions with the central bank of belarus related to the management of reserves or assets, the provision of public financing for trade with and investment in belarus, with limited exceptions, and the provision of euro denominated banknotes to belarus or for use in belarus it also imposes further restrictive measures with regard to the provision of specialised financial messaging services to certain belarusian credit institutions and their belarusian subsidiaries, which are relevant for the belarusian financial system and which are already the subject of restrictive measures imposed by the union it also extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets” this also adds obligations on the network manager for air traffic management network functions of the single european sky regarding overflight prohibitions and amend the provisions on non-circumvention council decision (cfsp) 2022/399 9 march 2022 decision 642 on publication date equivalent to those listed under regulation 398 above. council regulation (eu) 2022/408 11 march 2022 regulation 269 on publication date amends the information concerning 37 individuals and six entities already included under regulation 269. council decision (cfsp) 2022/411 11 march 2022 decision 145 on publication date equivalent to those listed under regulation 408 above. council regulation (eu) 2022/427 15 march 2022 regulation 269 on publication date adds a further 15 individuals and 9 entities to the asset freeze list under regulation 269, including among others prominent figures such as roman abramovich. council regulation (eu) 2022/428 15 march 2022 regulation 833 on publication date introduces further sectoral restrictive measures, as follows: prohibits all transactions with certain state-owned companies prohibit the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities, to any russian person or entity tightens export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, and expands the list of persons connected to russia’s defence and industrial base, which are subject to those restrictions prohibits new investments in the russian energy sector, and introduces a comprehensive export restriction on equipment, technology and services for the energy industry in russia, with the exception of nuclear industry and the downstream sector of energy transport introduces further trade restrictions concerning iron and steel, as well as on luxury goods council decision (cfsp) 2022/429 15 march 2022 decision 145 on publication date equivalent to those listed under regulation 427 above. council decision (cfsp) 2022/430 15 march 2022 decision 512 on publication date equivalent to those listed under regulation 428 above. council regulation (eu) 2022/580 8 april 2022 regulation 269 on publication date expands the provisions of article 6b of regulation 269 to provide for further grounds for persons to apply for a licence to be exempted from the asset freeze restrictions. in particular, the amendments introduce: as relevant to the latest russian banks addedto the asset freeze list (i.e. vtb, otkritie, novikombank and sovcombank), the possibility to apply for a licence for those entities to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to those entities, for the purposes of termination by 9 october 2022 of operations, contracts, or other agreements, including correspondent banking relations, concluded with those entities before 8 april 2022 as relevant generally to persons included on the asset freeze list, the possibility to apply for a licence for such asset frozen persons to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to such persons, provided that the relevant competent authority is able to determine that: the funds or economic resources are necessary for the sale and transfer by 9 october 2022 of proprietary rights in a legal person, entity or body established in the union where those proprietary rights are directly or indirectly owned by a natural or legal person, entity or body listed in annex i the proceeds of such sale and transfer remain frozen council implementing regulation (eu) 2022/581 8 april 2022 regulation 269 on publication date adds a further 216 individuals and 18 entities to the asset freeze list, notably including four russian banks (vtb, otkritie, novikombank and sovcombank) as well as further high profile russian government officials and businessmen. council decision (cfsp) 2022/582 8 april 2022 decision 145 on publication date equivalent to those listed under regulation 581 above. council regulation (eu) 2022/576 8 april 2022 regulation 833 on publication date introduces further sectoral prohibitions, as follows: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector introduces additional import restrictions on certain goods from russia, in particular on coal and other solid fossil fuels introduces further export restrictions to russia, in particular on jet fuel and other goods prohibits the award and continued execution of public contracts and concessions with russian nationals and entities or bodies established in russia imposes a prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to russian publicly owned or controlled entities extends the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of the member states extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for the purchase, import or transport of fossil fuels and certain minerals into switzerland, the eea and the western balkans extends the exemptions from the prohibition on transaction with certain russian state-owned enterprises and their subsidiaries to countries in the european economic area and switzerland as well as to the western balkans introduces a prohibition for road transport undertakings established in russia to transport goods by road in the eu prohibits access to ports to vessels registered under the flag of russia notably, introduces a prohibition on acting as a trustee or in similar capacities for russian persons and entities, as well as a prohibition on providing certain services to trusts council regulation (eu) 2022/577 8 april 2022 regulation 765 on publication date introduces further sectoral prohibitions, as follows: imposes further restrictive measures prohibiting the sale to belarus of transferable securities denominated in any official currency of a member state, and prohibiting the sale, supply, transfer or export to belarus of banknotes denominated in any official currency of a member state imposes further restrictive measures prohibiting road transport undertakings established in belarus from transporting goods by road within the territory of the european union council decision (cfsp) 2022/578 8 april 2022 decision 512 on publication date equivalent to those listed under regulation 576 above. council decision (cfsp) 2022/579 8 april 2022 decision 642 on publication date equivalent to those listed under regulation 577 above. council regulation (eu) 2022/625 13 april 2022 regulation 269 on publication date adds exceptions to the freezing of the assets of, and the restrictions on making funds and economic resources available to, designated persons, entities and bodies for certain clearly defined categories of bodies, persons, entities, organisations and agencies for exclusively humanitarian purposes in ukraine. council decision (cfsp) 2022/627 13 april 2022 decision 145 on publication date equivalent to those listed under regulation 625 above. council regulation (eu) 2022/626 13 april 2022 regulation 263 on publication date adds exceptions that allow clearly defined categories of bodies, persons, entities, organisations and agencies to provide goods and technology for use in certain sectors, as well as certain restricted services and assistance related to such goods and technology, to persons, entities and bodies in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine or for use in those areas, where necessary for humanitarian purposes. similarly, the exceptions allow for the provision of specific restricted services and assistance directly relating to certain infrastructure in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine, where necessary for humanitarian purposes. luhansk/donetsk embargo. council decision (cfsp) 2022/628 13 april 2022 decision 266 on publication date equivalent to those listed under regulation 626 above. council regulation (eu) 2022/658 21 april 2022 regulation 269 on publication date adds a further two individuals to the asset freeze list. council decision (cfsp) 2022/660 21 april 2022 decision 145 on publication date equivalent to those listed under regulation 658 above. council regulation (eu) 2022/876 3 june 2022 regulation 765 on publication date adds a further two individuals and eight entities should be included in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 (belarussian asset freeze list). council regulation (eu) 2022/877 3 june 2022 regulation 765 on publication date expands the list of entities subject to restrictions with regard to authorisations for the sale, supply, transfer or export of dual-use goods and technology, and goods and technology which might contribute to belarus’s military and technological enhancement, or to the development of its defence and security sector. this amendment also expands the list of belarusian credit institutions and their belarusian subsidiaries subject to a swift ban. it also includes provisions clarifying and strengthening the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements council regulation (eu) 2022/878 3 june 2022 regulation 269 on publication date adds a further 65 individuals and 18 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 269 (russian asset freeze list). council regulation (eu) 2022/879 3 june 2022 regulation 833 on publication date this is the key legal instrument introducing the new sectoral prohibitions under the sixth package. the new prohibitions consist of: oil imports: introduction of an embargo on the import of crude oil and refined oil products from russia, with a programme to gradually phase out russian oil imports. these provisions include temporary exemptions for certain cases where member states are heavily dependent on russian oil oil transport services: after a wind down period of 6 months, eu operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to third countries financial services: an additional three russian banks, including russia's largest bank sberbank, have been removed from swift business services: the deadline for winding down certain prohibited trust services has been extended to 5 july 2022 and those provisions have been further refined. this latest package also introduces a prohibition on the provision to the russian government, as well as to legal persons, entities or bodies established in russia of certain business-relevant services such as accounting, auditing, statutory audit, bookkeeping and tax consulting services, business and management consulting, and public relations services broadcasting suspension: the broadcasting activities of rossiya rtr/rtr planeta, rossiya 24/russia 24, and tv centre international – have been suspended. the advertising of products or services on sanctioned outlets has also been prohibited export restrictions: the list of advanced technology items banned from export to russia has been expanded to include additional chemicals that could be used in the process of manufacture of chemical weapons penalties: this amendment also clarifies and strengthen the provisions on national penalties for the breach of the sanctions under regulation 833 council regulation (eu) 2022/880 3 june 2022 regulation 269 on publication date introduces further derogation options from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities. this amendment also clarifies and strengthens the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements. council decision (cfsp) 2022/881 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 876 above. council decision (cfsp) 2022/882 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 877 above. council decision (cfsp) 2022/883 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 878 above. council decision (cfsp) 2022/884 3 june 2022 decision 512 on publication date equivalent to those listed under regulation 879 above. council decision (cfsp) 2022/885 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 880 above. regulation (eu) 2022/1280 of the european parliament and of the council 18 july 2022 n/a. new measure on publication date laying down specific and temporary measures, in view of russia’s invasion of ukraine, concerning driver documents issued by ukraine in accordance with its legislation. council regulation (eu) 2022/1269 (regulation 1269) 21 july 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector imposes a prohibition on the direct or indirect import, purchase or transfer of gold, which constitutes russia’s most significant export after energy extends the port access ban to locks allows, the sharing of technical assistance with russia in relation to aviation goods and technology to safeguard the technical industrial standard setting process of the international civil aviation organization (icao) introduces an exemption from the prohibition to enter into any transactions with russian public entities necessary to ensure access to judicial, administrative or arbitral proceedings harmonises the notification requirements for national competent authorities granting authorisations pursuant to derogations provided expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for agricultural products and the supply of oil and petroleum products to third countries this regulation also includes clarifications that the measures in regulation 833 do not prevent third countries and their nationals from trading with russia or trading in russian goods. council implementing regulation (eu) 2022/1270 21 july 2022 regulation 269 on publication date adds a further 48 persons and 9 entities to the asset freeze list under regulation 269, most notably sberbank which to date had not been listed. council decision (cfsp) 2022/1271 21 july 2022 decision 512 on publication date equivalent to those listed under regulation 1269 (amending regulation 833) above. council regulation (eu) 2022/1273 (regulation 1273) 21 july 2022 regulation 269 on publication date introduces a number of derogations to the asset freeze provisions of regulation 269: further derogation from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities in order to urgently prevent or mitigate an event likely to have a serious and significant impact on human health and safety or the environment derogation from the asset freeze and the prohibition to make funds and economic resources available to the key designated russian banks (being bank rossiya, promsvyazbnak, vnesheconombank (veb), otkiritie, novikombank, sovcombank, vtb bank and sberbank derogation from the asset freeze and the prohibition to make funds and economic resources available for the orderly wind-down of operations, including correspondent banking relations with respect to sberbank it additionally introduces requirements on designated persons and entities to report assets held within a member state and further strengthens the reporting obligations on eu operators to prevent breaches and circumvention of the asset freeze. council decision (cfsp) 2022/1272 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1273 (amending regulation 269) above. council implementing regulation (eu) 2022/1274 (regulation 1274) 21 july 2022 regulation 269 on publication date imposes an asset freeze on six individuals and one entity related to syrian regime involved in the recruitment of syrian mercenaries to fight in ukraine alongside russian troops. council decision (cfsp) 2022/1276 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1274 above. regulation (eu) 2022/1278 of the european parliament and of the council 22 july 2022 regulation 508 on publication date introduces measures to mitigate the impact of russia’s war of aggression against ukraine on the fishery and aquaculture sector. council implementing regulation (eu) 2022/1354 (regulation 1354) 4 august 2022 regulation 269 on publication date added two further individuals to the asset freeze list: oleksandr viktorovych yanukovych viktor fedorovych yanukovych council decision (cfsp) 2022/1355 4 august 2022 decision 145 on publication date equivalent to those listed under regulation 1354 above. council decision (cfsp) 2022/1355 (regulation 1446) 1 september 2022 regulation 269 on publication date added three further individuals to the asset freeze list. council decision (cfsp) 2022/1355 1 september 2022 decision 145 on publication date equivalent to those listed under regulation 1446 above. council regulation (eu) 2022/1903 (regulation 1903) 6 october 2022 regulation 263 on publication date extends the geographical scope of the restrictions to cover all the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia. council decision (cfsp) 2022/1908 6 october 2022 decision 266 on publication date equivalent to those listed under regulation 1903 above. council regulation (eu) 2022/1904 (regulation 1904) 6 october 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends the list of restricted items which might contribute to the russian federation’s military and technological enhancement or to the development of its defence and security sector prohibits the sale, supply, transfer or export of firearms, their parts and essential components and ammunition extends the import ban on steel products and imposes import and export prohibitions on further products originating from russia (such as woodpulp, paper and certain elements used in the jewellery industry such as stones and precious metals, among others) as well imposing restrictions on the sale, supply, transfer or export of additional goods used in the aviation sector introduces an exemption from the prohibition to provide technical assistance, brokering services, financing or financial assistance regarding maritime transport to third countries of crude oil or petroleum products which originate or are exported from russia, purchased at or below a pre-established price cap implements various provisions in connection with the introduction of a price cap as agreed by the price cap coalition expands the prohibitions related to the provision of services for the maritime transport of crude oil and certain petroleum products to third countries, to further prohibit the maritime transport of such goods to third countries, subject to implementation of the price cap expands the prohibition to engage in any transaction with certain russian state-owned or controlled legal persons, entities or bodies by including a ban on union nationals to hold any posts on the governing bodies of those legal persons, entities or bodies adds to the list of russian state-owned or controlled entities that are subject to the transaction ban of the russian maritime register of shipping; extends the port access and lock ban in the territory of the union to vessels certified by the russian maritime register of shipping bans the provision on crypto-asset wallet account or custody services, regardless of the total value of crypto assets extends the prohibition on the provision of certain services to the russian federation by including architectural, engineering, it consultancy and legal advisory services council decision (cfsp) 2022/1909 6 october 2022 decision 512 on publication date equivalent to those listed under regulation 1904 above. council regulation (eu) 2022/1905 (regulation 1905) 6 october 2022 regulation 269 on publication date introduced a further criterion for the listing of natural or legal persons, entities or bodies subject to asset freeze and the prohibition to make funds and economic resources available to designated persons and entities, allowing persons identified to facilitate infringements of the prohibition against circumvention of the provisions of regulation 269, to also be listed. it additionally introduces further derogations from the asset freeze and the prohibition to make funds or economic resources available and introduces additional provisions regarding member states’ obligations regarding the granting of derogations. council implementing regulation (eu) 2022/1906 (regulation 1906) 6 october 2022 regulation 269 on publication date adds a further 30 persons and 7 entities to the asset freeze list under regulation 269. council decision (cfsp) 2022/1907 6 october 2022 decision 145 on publication date equivalent to those listed under regulation 1905 and regulation 1906 above. council implementing regulation (eu) 2022/1985 (regulation 1985) 20 october 2022 regulation 269 on publication date adds 3 iranian persons and 1 entity to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/1986 20 october 2022 decision 145 on publication date equivalent to those listed under regulation 1985 above. council implementing regulation (eu) 2022/2229 (regulation 2229) 14 november 2022 regulation 269 on publication date adds 2 iranian individuals and 2 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2233 14 november 2022 decision 145 on publication date equivalent to those listed under regulation 2229 above. council regulation (eu) 2022/2367 (regulation 2367) 3 december 2022 regulation 833 on publication date establishes the price cap, which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. clarifies the existing prohibition on the trading and brokering of russian crude oil and petroleum products and extends the price cap exemption when such goods are traded at or below the price cap. extends the transition period applicable to the transport of crude oil and certain petroleum products after every subsequent change in the price cap for a period of 90 days to the provision, directly or indirectly, of technical assistance, brokering services or financing or financial assistance, related to the transport, subject to the same conditions, to ensure consistent implementation of the price cap by all operators. introduces a transitional period of 45 days for vessels carrying crude oil originating in russia, which was purchased and loaded onto the vessel prior to 5 december 2022 and unloaded at the final port of destination prior to 19 january 2023. clarifies that the prohibition to provide services related to the transport of russian crude oil or petroleum products by a third country flagged vessel applies in relation to vessels which in the past transported such goods purchased above the price cap, provided the operator responsible for that transport knew or had reasonable cause to suspect that this was the case. introduces an exemption from the prohibitions of providing maritime transport and technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries where necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters. introduces a regular review of the price cap mechanism as of mid-january 2023 and every two months thereafter. such review needs to take into account the objectives of the price cap, including its ability to reduce russia’s oil revenues, as well as the principle that the price cap should be at least 5% below the average market price for russian oil and petroleum products. commission implementing regulation (eu) 2022/2368 (regulation 2368) 3 december 2022 regulation 833 on publication date introduces the price cap (usd 60 / barrel) which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. council decision (cfsp) 2022/2369 3 december 2022 decision 512 on publication date equivalent to those listed under regulations 2367 and 2368 above. council implementing regulation (eu) 2022/ 2430 (regulation 2430) 12 december 2022 regulation 269 on publication date adds 4 iranian individuals and 4 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2432 12 december 2022 decision 145 on publication date equivalent to those listed under regulation 2430 above. council regulation (eu) 2022/2474 (regulation 2474) 16 december 2022 regulation 833 on publication date extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding drone engines, further chemical and biological equipment, riot control agents and electronic components. expands the list of entities connected to russia’s military and industrial complex, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed by adding 168 new entities. extends the suspension of the broadcasting licences in the union of certain russian media outlets. furthers the already existing prohibition targeting new investments in the russian energy sector by additionally prohibiting new investments in the russian mining sector, with the exception of mining and quarrying activities involving certain critical raw materials. expands the export ban covering goods and technology suited for use in aviation and the space industry to include aircraft engines and their parts. introduces a derogation allowing the provision of technical assistance related to the use of goods and technology suited for use in aviation or the space industry, when this is necessary to avoid collision between satellites, or their unintended re-entry into the atmosphere. introduces a possibility for the national competent authorities to grant derogations to allow for certain aviation goods, which are also widely used in the medical field, to be exported for medical, pharmaceutical and humanitarian purposes. extends the list of goods which could contribute to the enhancement of russian industrial capacities by including such items as generators, toy drones, laptops, hard drives, it components, night-vision and radio-navigation equipment, cameras and lenses. extends for an additional six months the exemption applicable to the imports of methanol originating in or exported from russia. clarifies that, as is the case for the member states importing russian crude oil by pipeline, bulgaria cannot sell petroleum products obtained from russian crude oil imported on the basis of that derogation to buyers located in other member states or in third countries. bunkering or refuelling of a vehicle or aircraft in the member states which benefit from those derogations does not fall under that prohibition. allows hungary, slovakia and bulgaria to export to ukraine certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question, including, when necessary, by transiting through other member states. allows bulgaria to export to third countries certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question. introduces a reporting obligation for the operators engaged in transactions concerning natural gas condensate from lng productions plants. adds the russian regional development bank to the list of russian state-owned or controlled entities that are subject to the transaction ban. bans union nationals from holding any posts on the governing bodies of all russian state-owned or controlled legal persons, entities or bodies that are established in russia, subject to certain derogations. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. introduces a temporary derogation from the import and export prohibitions, by enabling the sale, supply or transfer of such goods, or their import into the union until 30 september 2023 and applies only to those goods that were already physically located in russia at the time when the relevant prohibitions entered into force. aligns the member states’ reporting obligation on deposits exceeding eur 100 000 from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia, with the similar obligations that already exist for the other types of deposits. extends the existing prohibition on the provision of certain services to the russian federation and to legal persons, entities or bodies established in russia by banning the provision of advertising, market research and public opinion polling services, as well as product testing and technical inspection services. further clarifies and amends the exemptions to the import ban on steel products that either originate in russia or have been exported from russia. council regulation (eu) 2022/2475 (regulation 2475) 16 december 2022 regulation 269 on publication date introduces a new deadline, 17 june 2023, for the derogation allowing divestments by sberbank with a view to winding down its operations. extends to the 2 newly listed entities (being credit bank of moscow and dalnevostochny bank) the derogation from the asset freeze and from the prohibition to make funds and economic resources available, in order to allow the termination of operations, contracts, or other agreements, previously concluded with those entities. introduces a new derogation allowing the unfreezing assets of, and to make funds and economic resources available to, certain individuals who held a significant role in international trade and agricultural and food products, including wheat and fertiliser, prior to their listing. extends the deadline for certain general derogations. council implementing regulation (eu) 2022/2476 (regulation 2476) 16 december 2022 regulation 269 on publication date adds a further 141 individuals and 49 entities to the asset freeze list under regulation 269, including credit bank of moscow and dalnevostochny bank. council decision (cfsp) 2022/2477 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2476 above. council decision (cfsp) 2022/2478 16 december 2022 decision 512 on publication date equivalent to those listed under regulation 2474 above. council decision (cfsp) 2022/2479 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2475 above. council implementing regulation (eu) 2023/192 (regulation 192) 30 january 2023 regulation 269 on publication date adds 1 iranian entity to the asset freeze list under regulation 269 due to its involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2023/193 30 january 2023 decision 145 on publication date equivalent to those listed under regulation 192 above. council regulation (eu) 2023/426 (regulation 426) 25 february 2023 regulation 269 on publication date extends to certain newly-listed banks (rosbank, tinkoff bank and alfa bank) certain licensing grounds for derogations from the asset freeze, and to allow the processing of payments by the jewish claims conference through one of them. extends the deadline to apply for the disposal or the transfer of securities by the national settlement depository (nsd), and which are currently or were previously controlled by vtb bank. introduces a derogation allowing for the termination of operations, contracts or other agreements with limited liability company “commercial vehicles - gaz group”, and extended by three months the deadline for the derogation to allow the sale and transfer of proprietary rights in a legal person, entity or body established in the eu owned by a listed natural or legal person, entity or body. introduces a requirement that natural and legal persons, entities and bodies should supply to the national competent authorities detailed information on funds and economic resources which have been frozen or should have been treated as frozen, as well as information on funds and economic resources belonging to, owned, held or controlled by listed natural or legal persons, entities or bodies which were subject to any move, transfer, alteration, use, access, or dealing shortly before the listing. introduces a requirement that central securities depositories, due to their systemic importance for the functioning of securities markets, should provide the relevant information to the member state concerned and simultaneously to the commission. specifies the type of information to be provided to national competent authorities, which authorities should then transmit that information to the commission, with specific adaptations in the case of criminal proceedings. provides for deferred application of the more detailed reporting requirements, in order to allow time to adapt. clarifies that member states and the relevant natural and legal persons, entities and bodies are required to cooperate with the commission in any verification of such information, and that the commission should be able to request any additional information, while informing the member state concerned of such request. council regulation (eu) 2023/427 (regulation 427) 25 february 2023 regulation 833 on publication date adds 96 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed. adds several iranian entities to the list of natural and legal persons, entities and bodies subject to restrictive measures under decision 512, taking into account the direct connection between iranian manufacturers of unmanned aerial vehicles and the russian military and industrial complex and the concrete risk that certain goods or technology are used for the manufacture of military systems that contribute to russia’s war of aggression against ukraine. extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding rare-earths and compounds, electronic integrated circuits and thermographic cameras, among others. extends the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. prohibits the transit via the territory of russia of dual-use goods and technology and of arms exported from the eu in order to minimise the risk of circumvention of the restrictive measures. extends the suspension of broadcasting licences in the eu of russian media outlets under the permanent control of the russian leadership and the prohibition against broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of such media outlets in the eu, or directed at the eu. the measures should be maintained until the aggression against ukraine is put to an end, and until the russian federation, and its associated media outlets, cease to conduct propaganda actions against the eu and its member states. those measures do not prevent the media outlets and their staff from carrying out activities in the eu other than broadcasting, such as research and interviews. restricts the possibility to hold any posts in the governing bodies of european critical infrastructures and critical infrastructures identified or designated as such under national law. imposes a prohibition on providing gas storage capacity in the eu to russian nationals, natural persons residing in russia or legal persons or entities established in russia. introduces an obligation for aircraft operators to notify non-scheduled flights to their competent authorities the member state concerned should immediately inform other member states, the network manager and the commission where it does not clear such a flight. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. it also extends the duration of the period in which the competent authorities of the member states may authorise transactions which are necessary for the divestment and withdrawal by those russian state-owned entities from eu companies. requires that natural and legal persons, entities and bodies supply to the competent authorities of the member states and simultaneously to the commission information on the management of reserves and assets of the central bank of russia, which they hold or control or are a counterparty to. it is also appropriate to specify the type of information to be provided and how this should be treated and used to ensure the uniform application of this reporting obligation. it should also be clarified that member states and the relevant natural and legal persons, entities and bodies must cooperate with the commission in any verification of such information and that the commission may request any additional information, while informing the member state concerned of such request. in order to allow time to adapt, the new rules provide for deferred application of the new reporting requirements. introduces a temporary derogation from the prohibition on providing accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services, architectural and engineering services, legal advisory services and it consultancy services. in order to facilitate an expeditious exit from the russian market, this derogation is temporary and limited in scope, enabling until 31 december 2023 the continuation of the provision of services to and for the exclusive benefit of the legal persons, entities or bodies resulting from the divestment. additionally, the competent authorities of the member states should ensure that the services are not provided to the government of russia or benefit military end-users or have a military-end use. provides for certain exemptions for eu operators to provide pilot services to vessels in innocent passage as defined by international law which are necessary for reasons of maritime safety. provides for rules on the release by the customs authorities of the member states of goods which are physically in the eu and which had already been presented to customs authorities when they became subject to such restrictions. authorises member states to release goods already brought into the eu in the past. the competent authorities of the member states should ensure that the release of the goods and any payment related thereto comply with the provisions and objectives of eu restrictive measures. similarly, any decision not to release such goods should comply with those objectives and ensure, among others, that the goods are not returned to russia. makes certain technical corrections in the operative text of decision 512. council implementing regulation (eu) 2023/429 (regulation 429) 25 february 2023 regulation 269 on publication date adds a further 87 individuals and 34 entities to the asset freeze list under regulation 269, including most significantly rosbank, tinkoff bank and alfa bank. council implementing regulation (eu) 2023/430 (regulation 430) 25 february 2023 regulation (eu) 2020/1998 on publication date designates the wagner group and three of its members involved in serious human rights violations in different parts of the world. adds 8 individuals and 7 entities in the list of natural persons, legal persons, entities and bodies subject to restrictive measures under regulation (eu) 2020/1998. council decision (cfsp) 2023/432 25 february 2023 decision 145 on publication date equivalent to those listed under regulation 426 above. council decision (cfsp) 2023/433 25 february 2023 decision 1999 on publication date equivalent to those listed under regulation 430 above. council decision (cfsp) 2023/434 25 february 2023 decision 512 on publication date equivalent to those listed under regulation 427 above. council implementing regulation (eu) 2023/419 (regulation 419) 27 february 2023 regulation 765 on publication date renews the restrictive measures imposed on belarus until 28 february 2024. amends the entries relating to 21 individuals and 2 entities included in the list of natural and legal persons, entities and bodies subject to restrictive measures under regulation 765. council decision (cfsp) 2023/421 27 february 2023 decision 642 on publication date equivalent to those listed under regulation 419 above. council regulation (eu) 2023/1214 (regulation 1214) 23 june 2023 regulation 833 on publication date prohibits the transit of goods and technology suited for use in aviation or space industry and jet fuel and fuel additives, exported from the eu to third countries via russia. allows for appropriate individual measures such as designations or trade restrictions, to be adopted to address the involvement of third-country operators facilitating circumvention. introduces the possibility of last-resort measures restricting the sale, supply, transfer or export of sensitive dual-use goods and technology, or goods and technology that might contribute to the enhancement of russia’s military, technological or industrial capacities or to the development of russia’s defence and security sector to third countries used for circumvention. adds 87 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, certain entities from third countries involved in the circumvention of trade restrictions, and certain entities involved in the development, production and supply of electronic components for russia’s military and industrial complex. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which contribute to the development or production of russia’s military systems, including electronic components, semiconductor materials, manufacturing and testing equipment for electronic integrated circuits and printed circuit boards, precursors to energetic materials and precursors to chemical weapons, optical components, navigational instruments, metals used in the defence sector and marine equipment. extends the list of restricted firearms, their parts, essential components and ammunition, and adds other types of arms. imposes further restrictions on exports of goods which could contribute to the enhancement of russian industrial capacities. prohibits the sale, licence or transfer in any other way of intellectual property rights or trade secrets used in connection with restricted goods. extends the suspension of the broadcasting licences in the eu of five russian media outlets under the permanent control of the russian leadership, and the prohibition against broadcasting their content. extends the prohibition on the transport of goods by road in the eu by trailers and semi-trailers. prohibits access to ports and locks in the territory of the eu by vessels engaged in ship-to-ship transfers where the competent authorities have reasonable cause to suspect that a vessel is in breach of the ban on importing seaborne russian crude oil and petroleum products into the eu or is transporting russian crude oil or petroleum products purchased above the price cap agreed by the price cap coalition. prohibits access to ports and locks in the territory of the eu by vessels which competent authorities have reasonable cause to suspect of illegally interfering with, switching off or otherwise disabling their shipborne automatic identification systems (ais) when transporting russian crude oil and petroleum products. that prohibition does not apply in circumstances where the shipborne ais can be legitimately turned off in accordance with international agreements, rules or standards that provide for the protection of navigational information, such as navigation through high-security-risk waters. ends the temporary derogation granted to germany and poland for the supply of crude oil by pipeline from russia through the northern section of the druzhba oil pipeline. the import of oil which originates in kazakhstan or another third country and is transiting through russia via the druzhba oil pipeline is not prohibited. introduces derogations from the prohibitions on the sale, supply, transfer or export directly or indirectly to any natural or legal person, entity or body in russia or for use in russia of certain goods or technology, on the provision of related financing or financial assistance, technical assistance, brokering services or other services, or on the provision of auditing services, engineering services, legal advisory services, technical testing and analysis services which are strictly necessary for that purpose, subject to strict conditions to avoid the risk of circumvention. extends prohibition on providing transferable securities to financial instruments denominated in any currency. introduces a derogation from the prohibition to provide certain services to russian entities required for the setting-up, certification or evaluation of a firewall removing the control exercised by a listed person over the assets of a non-listed eu entity which the listed person owns or controls. clarifies the evidence required for importation of iron and steel products processed in a third country incorporating iron and steel products originating in russia. introduces clarifications regarding the competent authorities which receive notifications of non-scheduled flights between russia and the eu. extends the deadline for the application of a temporary derogation from the prohibition on providing certain services, with the aim of further facilitating divestment from the russian market by union operators. introduces a temporary derogation from the prohibition on providing legal advisory services to legal persons, entities or bodies established in russia. the competent authorities of the member states may authorise the provision, until 31 march 2024, of legal services which are mandatory, under the national legislation of the member state, for such divestments to be completed. adds switzerland to the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. council regulation (eu) 2023/1215 (regulation 1215) 23 june 2023 regulation 269 on publication date introduces a further criterion for the asset freeze listing to allow the designation of legal persons, entities or bodies operating in the russian it sector with a licence from federal security service of the russian federation (fsb) or the russian ministry of industry and trade. amends an existing listing criterion regarding the circumvention of eu sanctions, or significant frustration of eu sanctions by third country operators, including instances where the main activity of a third country operator consists of purchasing restricted goods in the eu that reach russia, the involvement of russian individuals or entities, the recent creation of a company for purposes related to restricted goods reaching russia, or a drastic increase in the turnover of a third country operator involved in such activities. introduces further derogations from the asset freeze to allow for divestment from russian companies and the disposal of certain types of securities held with vtb bank and national settlement depository (nsd). introduces a derogation allowing the provision of services required for the establishment of a firewall removing the control by a listed person over the assets of an eu entity. allows for the provision of pilot services in specific circumstances to safeguard maritime safety. insertion of certain clarifications in the provision on information sharing between competent authorities and regarding the respect of the confidentiality of the communications between lawyers and their clients in the context of reporting obligations. introduces a derogation allowing the release of frozen funds belonging to alexey alexandrovits mordashov after having determined that such funds are necessary for the completion of transactions of a joint venture. introduces a derogation allowing the release of frozen funds for certain banks when such funds are necessary for the purchase, import or transport of agricultural and food products, namely the following entities, bank rossiya, promsvyazbank, veb.rf, otkritie fc bank, novikombank, sovcombank, vtb bank, sberbank, credit bank of moscow, jsc ‘dalnevostochniy bank’, jsc ural civil aviation factory, alfa-bank js, public joint-stock company rosbank, mrb bank and cmr bank. council implementing regulation (eu) 2023/1216 (regulation 1216) 23 june 2023 regulation 269 on publication date adds a further 71 individuals and 33 entities to the asset freeze list under regulation 269, including most significantly mrb bank and cmr bank. council decision (cfsp) 2023/1217 23 june 2023 decision 512 on publication date equivalent to those listed under regulation 1214 above. council decision (cfsp) 2023/1218 23 june 2023 decision 145 on publication date equivalent to those listed under regulation 1215 above. council implementing regulation (eu) 2023/1591 (regulation 1591) 3 august 2023 regulation 765 on publication date adds a further 38 individuals and 3 entities from belarus to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765. council implementing decision (cfsp) 2023/1592 3 august 2023 decision 642 on publication date equivalent to those listed under regulation 1591 above. council regulation (eu) 2023/2873 (regulation 2873) 18 december 2023 regulation 269 on the day following that of its publication date extends the listing criteria to cover natural or legal persons, entities or bodies benefitting from the compulsory transfer of ownership of, or control over, entities established in russia that were previously owned or controlled by eu entities. sets out the conditions on which the council is able to retain the name of a deceased person on the asset freeze list under particular circumstances. introduces a derogation to allow for the release of frozen funds or economic resources, in cases where a member state deprives a listed person of funds or economic resources belonging to, or owned by or controlled by, it, and for making funds and economic resources available to such person for compensation to be paid. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the sale or use of shares in, or assets of, an entity established in russia where the ownership or control by an eu legal person of that entity has been compulsorily transferred by the russian government. that derogation would enable, among others, the payment of agreed adequate compensation to eu legal persons. extends the deadline applicable to the existing derogation allowing the processing of payments by the jewish claims conference until 31 december 2024 through alfa-bank jsc and introduces a derogation to allow for certain payments as an indemnity or benefit for the materialisation of a risk involving a newly listed entity. introduces a temporary derogation from the asset freeze and the prohibition on making funds and economic resources available to allow the sale and transfer of proprietary rights directly or indirectly owned by certain listed persons (namely petr aven, mikhail fridman, gennady timchenko, german khan, alexey kuzmichev, igor kesaev, boris rotenberg, arkady rotenberg, as well as certain legal entities) in a legal person, entity or body established in the eu. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the termination of contracts concluded with a newly listed entity. extends to a newly listed alfastrakhovanie, an insurance company, the existing derogation currently applicable to certain listed banks under certain circumstances. makes technical amendments in the operative text, defines the scope of certain reporting obligations and introduces an obligation for national competent authorities of member states to designate in accordance with national legislation the national authorities competent to identify and trace, where appropriate, funds and economic resources belonging to, or owned, held or controlled by, listed natural or legal persons, entities or bodies, with a view to preventing or detecting instances of a breach or circumvention, or attempts at a breach or circumvention, of regulation 269. council regulation (eu) 2023/2878 (regulation 2878) 18 december 2023 regulation 833 on the day following that of its publication date adds 29 new entities to the list of legal persons, entities and bodies supporting russia’s military and industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemicals, lithium batteries, thermostats, dc motors and servomotors for unmanned aerial vehicles, machine tools and machinery parts. introduces a list of partner countries, being swtizerland and norway, which apply a set of restrictive measures on imports of iron and steel and a set of import control measures. it also extends certain wind-down periods for the import of specific steel products. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. prohibits the transit via the territory of russia of certain goods and technology which could contribute in particular to the enhancement of russian industrial capacities, exported from the eu. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. provides for an exemption for the entry of cars into the eu for specific circumstances. introduces a derogation enabling the granting of loans or credits to entities operating in the russian energy sector which are subject to the transaction ban provided for in regulation 833, under the conditions provided for therein. imposes a prohibition on the direct or indirect import, purchase or transfer of diamonds from russia. that prohibition applies to diamonds originating in russia, diamonds exported from russia, diamonds transiting russia and russian diamonds when processed in third countries other than russia. the prohibition applies to non-industrial natural and synthetic diamonds, as well as diamond jewellery, as of 1 january 2024, and includes a progressive phasing-in, from 1 march 2024 until 1 september 2024, of an indirect import ban on russian diamonds when processed in third countries other than russia, including jewellery incorporating diamonds originating in russia. prolongs by an additional year specific derogations from the prohibition on imports from russia of crude oil and petroleum products in order to ensure the security of supply of certain member states. introduces a requirement that itemised price information for ancillary costs, such as insurance and freight, be shared upon request throughout the supply chain of russian oil trade. competent authorities can request that information from any actor, regardless of their place in the supply chain, at any time, in order to verify compliance with the price cap mechanism. provides for a notification obligation for the sale of tankers to any third country and a derogation from the prohibition on the sale of tankers to russian persons and entities, or for use in russia. this obligation applies to the owner of a tanker who is a national of a member state, to a natural person residing in a member state, and to a legal person, entity or body which is established in the eu. the owner, or anyone acting on his or her behalf, should notify the competent authorities of any such sale concluded since 5 december 2022 and provide all the necessary details. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2024 to ensure japan’s energy security needs. includes a ban on russian nationals or natural persons residing in russia from owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing crypto-asset wallet, account or custody services to russian persons. extends the existing prohibition on the provision of services to also include the provision of software for the management of enterprises and software for industrial design and manufacture, subject to appropriate exemptions and derogations. imposes certain reporting requirements for the transfer of funds out of the eu made by entities established in the eu, including special purpose entities, whose proprietary rights are owned by entities established in russia, by russian nationals or by natural persons residing in russia. requires that exporters contractually prohibit re-exportation to russia and re-exportation for use in russia of certain specific sensitive goods and technology. council implementing regulation (eu) 2023/2875 18 december 2023 regulation 269 on publication date adds a further 61 individuals and 86 entities to the asset freeze list under regulation 269, most notably including alfastrakhovanie group, the insurance arm of alfa bank. council decision (cfsp) 2023/2871 18 december 2023 decision 145 on publication date equivalent to those listed under regulation 2873 above. council decision (cfsp) 2023/2874 18 december 2023 decision 512 on publication date equivalent to those listed under regulation 2878 above. council decision (cfsp) 2024/195 3 january 2024 decision 145 on publication date adds pjsc alrosa and its ceo, pavel alekseevich marinychev, to the asset freeze list under decision 145. council regulation (eu) 2024/745 (regulation 745) 23 february 2024 regulation 833 on the day following that of its publication date adds 27 russian and third country entities to the list of legal persons, entities and bodies associated to russia’s military-industrial complex set out in annex iv of regulation 833. expands the list of controlled items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding components for the development and production of unmanned aerial vehicles. imposes further restrictions on exports of goods which contribute in particular to the enhancement of russian industrial capabilities. adds the united kingdom to the list of partner countries for the iron and steel imports. these partner countries apply a set of restrictive measures on imports of iron and steel and a set of import control measures that are substantially equivalent to those regulation 833. council implementing regulation (eu) 2024/753 (regulation 753) 23 february 2024 regulation 269 on publication date adds a further 106 individuals and 88 entities to the asset freeze list under regulation 269. council decision (cfsp) 2024/746 23 february 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 745 above. council decision (cfsp) 2024/747 23 february 2024 decision 145 on publication date equivalent to those listed under regulation 753 above. council regulation (eu) 2024/1428 (regulation 1428) 17 may 2024 regulation 833 on the day following that of its publication date introduces measures to suspend broadcasting activities within the union or directed at the union by certain media outlets listed in the annex to regulation (eu) 2024/1428. council regulation (eu) 2024/1485 (regulation 1485) 27 may 2024 n/a. new measure on publication date provides for the freezing of funds and economic resources of, and the prohibition to make funds and economic resources available to, natural or legal persons, entities or bodies, certain designated natural or legal persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. these restrictions largely mirror those of regulation 269 in substance. provides for certain sectoral restrictions on exporting equipment, technology or software, which might be used for internal repression, as well as items intended primarily for use in the monitoring or interception of information security and telecommunication and the provision of related technical assistance, brokering services, financing or financial assistance. council decision (cfsp) 2024/1484 27 may 2024 n/a. new measure on publication date provides for a travel ban on certain designated natural persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. contains other measures equivalent to those listed under regulation 1485. council implementing regulation (eu) 2024/1488 (regulation 1488) 27 may 2024 regulation 1485 on publication date adds 19 individuals and 1 entity to the asset freeze list under regulation 1485. council implementing regulation (eu) 2024/1493 (regulation 1493) 27 may 2024 regulation 269 on publication date adds a further 2 individuals and 1 entity to the asset freeze list under regulation 269. council decision (cfsp) 2024/1508 27 may 2024 decision 145 on publication date equivalent to those listed under regulation 1493 above. council regulation (eu) 2024/1739 24 june 2024 regulation 269 on publication date introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. clarifies that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. introduces a provision to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them, provided that the member state national or company concerned does not have effective access to remedies under the relevant jurisdiction. introduces a new reporting obligation on member states to report penalties imposed for violations of the restrictive measures provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties. ensures that any document held by the council, the commission or the high representative of the union for foreign affairs and security policy for the purpose of ensuring the enforcement of the measures set out regulation 269, or of preventing the violation or circumvention thereof, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. that protection also applies to the joint proposals from the high representative of the union for foreign affairs and security policy and the commission for the amendment of regulation 269 and to any preparatory documents related to them. council regulation (eu) 2024/1745 24 june 2024 regulation 833 on the day following that of its publication date amends the prohibition to land in, take off from or overfly the territory of the eu so that it also applies to any aircraft which is used for a non-scheduled flight and with regard to which a russian natural or legal person, entity or body is in a position to effectively determine the place or time of its take-off or landing. also amends the same prohibition to introduce an exemption for certain aircraft when used for private, non-corporate flights carried out within eu territory and airspace for recreational or training purposes. introduces an obligation for operators to provide, for non-scheduled flights, upon request of the competent authorities of the member state of departure, destination or overflying, information needed for the purpose of verifying compliance with the flight ban, including information about ownership of the aircraft and, where reasonable grounds to suspect circumvention of the flight ban exist, about passengers. amends the prohibition on the transport of goods by road within the territory of the eu, including in transit. eu operators which are owned for 25 % or more by a russian natural or legal person should be prohibited from becoming a road transport undertaking or from transporting goods by road in the eu, including in transit. clarifies that rough diamonds imported from russia prior to 1 january 2024 and polished diamonds imported from russia or manufactured before 1 march 2024 or 1 september 2024, depending upon the weight of the diamond, are not covered by the diamond ban. also amends the ban on russian diamonds in order to enable the temporary import or export of jewellery for repairs, auctions and trade fairs and amends the scope of application and the date of entry into force of the requirement to provide traceability-based evidence. provides that the indirect import ban on russian diamonds processed in third countries other than russia, is temporarily not to apply to jewellery incorporating such diamond. prohibits reloading services in the territory of the eu for the purposes of transshipment operations where such services are used to transship russian lng, except in the case of such transshipments to member states. prohibits new investment and the provisions of goods, technology and services for the completion of lng projects. introduces import restrictions on russian lng through union lng terminals that are not connected to the interconnected natural gas system. introduces a sectoral ban prohibiting access to member states’ ports and locks as well as certain services related to maritime transport for vessels which contribute to russia’s ability to wage war against ukraine. clarifies the scope of the port access ban for russian-flagged vessels and adds a derogation. introduces a prohibition on purchasing, importing, transferring or exporting ukrainian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance, where there are reasonable grounds to suspect that the goods have been unlawfully removed from ukraine, along with a prohibition on related services. enables the possibility to subject companies which make use of russian law provisions, which force the satisfaction of claims against assets of eu companies in a foreign jurisdiction, claims which they would otherwise be prohibited from satisfying pursuant to regulation 833 or regulation 269, to a transaction ban. prohibits eu entities which operate outside of russia from directly connecting to the ‘system for transfer of financial messages’ (spfs) or equivalent specialised financial messaging services set up by the central bank of russia, and adds a transaction ban on eu operators with specifically listed entities using that system outside russia. eu entities however are not prohibited from dealing with russian entities which use the spfs, provided that those eu entities do not connect to the spfs themselves. establishes a transaction ban on eu operators with credit and financial institutions as well as crypto assets providers, established outside of the eu, when the council has determined that those entities facilitate transactions that support russia’s defence-industrial base through the export, supply, sale, transfer or transport towards russia of dual-use goods and technology, common high priority items or firearms and ammunition. broadens the existing prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to any legal person, entity or body established in russia or to any legal person, entity or body majority owned by them. creates an exemption to the prohibition to provide certain services to the government of russia or to legal persons, entities or bodies established in russia, for eu nationals who resided in russia before february 2022 and who are employed by subsidiaries of eu and partner countries’ entities. imposes restrictions on accepting applications for registrations in the eu of certain intellectual property rights by russian nationals, natural persons resident in russia and russian companies. in particular, and without prejudice to their procedural rules, intellectual property offices and other competent institutions should not allow the filing of such applications. introduces a prohibition on the acceptance, by political parties, foundations, alliances, non-governmental organisations, including think tanks, and media service providers in the eu, of financing, donations or any other economic benefits or support from russia, whether directly or indirectly. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. provides for member states to report about penalties imposed for violations of restrictive measures. ensures that the documents held by the council, the commission and the high representative of the union for foreign affairs and security policy concerning the enforcement of the restrictive measures set out in regulation 833, or concerning the prevention of the violation or circumvention of those measures, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. introduces provisions to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them. provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties, as appropriate, in accordance with national administrative law or with other relevant national law or rules requires eu operators to undertake their best efforts to ensure that legal persons, entities and bodies established outside the eu that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 833. requires eu operators to contractually prohibit their commercial counterparts in third countries from using, or allowing the use of, the intellectual property rights, trade secrets or material or information protected by intellectual property rights or protected as trade secret transferred to them in connection with common high priority items to be sold, supplied or exported to russia or for use in russia. requires eu operators that are selling, supplying, transferring or exporting common high priority items to third countries, other than the partner countries listed in annex viii regulation 833, to implement due diligence mechanisms capable of identifying and assessing risks of exportation to russia and mitigating such risks. eu operators must also ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. adds 61 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512. also includes on that list certain entities in third countries other than russia that are involved in the circumvention of trade restrictions and that engage in the procurement of sensitive items used for. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. adds five common high priority items to the restrictions on exports of goods. introduces further restrictions on the import of helium. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2025 to ensure japan’s energy security needs. makes certain technical amendments in the operative text and annexes, deleting references to transitional periods which have expired introduces a horizontal exemption from the prohibitions in this regulation for the paks ii nuclear project, with a notification obligation for such activities. expands the lists of partner countries that apply a set of export control measures or a set of restrictive measures on imports of iron and steel and a set of import control measures which are substantially equivalent to those set out in regulation 833. council implementing regulation (eu) 2024/1746 24 june 2024 regulation 269 on publication date adds a further 69 persons and 47 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/1776 24 june 2024 regulation 833/regulation 1428 on the day following that of its publication date provides that the measures in relation to broadcasting in regulation 833 apply from 25 june 2024 in respect of all entities referred to in the annex to regulation 1428 and can be found here. council decision (cfsp) 2024/1738 24 june 2024 decision 145 on publication date equivalent to those listed under regulations 1739 and 1746 above. council decision (cfsp) 2024/1744 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1745 above. council decision (cfsp) 2024/1770 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1776 above. council regulation (eu) 2024/3189 (regulation 3189) 16 december 2024 regulation 269 on publication date introduces a derogation allowing the release of cash balances that are held by central securities depositories and attributable to the nsd. introduces a derogation allowing the release of frozen funds to arkady rotenberg, boris rotenberg and gennady timchenko. council regulation (eu) 2024/3192 (regulation 3192) 16 december 2024 regulation 833 on the day following that of its publication date adds 32 new entities to the list of persons, entities and bodies supporting russia’s military-industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles or missiles. adds further vessels to the list of vessels on which a ban from member states’ ports and locks, as well as a ban on the provision of a broad range of services related to maritime transport, are imposed. adds that certain actions by a central securities depository carried out in good faith do not give rise to liability of any kind on the part of that depository, or of its directors or employees, unless it is proved that the action was a result of negligence. introduces a prohibition on the recognition or enforcement in the union of injunctions, orders, judgments or other court decisions pursuant to or in relation to article 248 of the arbitration procedure code of the russian federation or equivalent russian legislation. makes certain technical amendments to regulation 833, including to extend the deadlines applicable to certain derogations needed for divestments from russia or for member states’ security of supply of certain petroleum products. council implementing regulation (eu) 2024/3177 (regulation 3177) 16 december 2024 article 8a(1) of regulation (ec) no 765/2006 on publication date adds 26 individuals and 2 entities in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 in view of the situations in belarus. council implementing regulation (eu) 2024/3183 (regulation 3183) 16 december 2024 regulation 269 on publication date adds a further 54 individuals and 30 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/3188 (regulation 3188) 16 december 2024 regulation 2642 on publication date adds 16 individuals and 3 entities to the list of natural and legal persons, entities and bodies set out in annex i to regulation (eu) 2024/2642. council decision (cfsp) 2024/3174 16 december 2024 decision 2643 on publication date equivalent to those listed under regulation 3188 above. council decision (cfsp) 2024/3182 16 december 2024 decision 145 on publication date equivalent to those listed under regulation 3189 and regulation 3183 above. council decision (cfsp) 2024/3187 16 december 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 3192 above. council implementing decision (cfsp) 2024/3175 16 december 2024 decision 642 on publication date equivalent to those listed under regulation 3177 above. council regulation (eu) 2025/390 (regulation 390) 24 february 2025 regulation 269 on publication date introduces two further criteria for the listing of natural or legal persons, entities or bodies in relation vessels involved in certain activities or who form part of, supporting, materially or financially, or benefitting from russia’s military and industrial complex. extends an existing divestment derogation to three additional listed individuals. extends the scope of two existing derogations regarding certain transfers of funds and payments. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries as referred to in annex viii of regulation 833 that apply similar restrictive measures. enables the commission to process personal data in relation to the due diligence required from union operators in respect of potential business partners. allows union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages. introduces a best-efforts obligation to union operators undertake such best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 269. further expands on the scope of the best efforts obligation. makes a number of technical amendments in order to ensure the clarity of certain provisions of regulation 269 including those concerning documents held by the union institutions and the processing of personal data. council regulation (eu) 2025/392 (regulation 392) 24 february 2025 regulation 765 on publication date strengthens the prohibition on the export of dual-use goods and technology and of goods and technology which might contribute to the technological enhancement of belarus’s defence and security sector. expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including chemical precursors to riot control agents, software related to computer numerical control machines, chromium ores and compounds and controllers used to guide unmanned aerial vehicles. imposes further restrictions on exports of goods which could contribute to the enhancement of belarusian industrial capacities, such as chemical elements, pyrotechnic articles and combustible materials. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus of machinery and of goods which could contribute, in particular, to the enhancement of belarusian industrial capacities. establishes derogations for the provision of certain goods and machinery necessary for civilian non-publicly available electronic communications networks. introduces further restrictions on the import of primary aluminium, which allows belarus to diversify its sources of revenue, thereby enabling its involvement in the russian aggression against ukraine. imposes a restriction on the sale, supply, transfer, export or provision of software related to oil and gas exploration in order to further restrict the oil and gas exploration and production capacities of belarus and minimise the risk of circumvention of restrictive measures via the territory of belarus. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, licence or transfer in any other way of intellectual property rights or trade secrets related to a software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of belarus located in a member state. expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by belarusian nationals or natural persons residing in belarus. subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities. prohibits the provision of crypto-asset wallet, account or custody services to belarusian persons and residents and includes a prohibition on belarusian nationals or natural persons residing in belarus owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing such services. introduces an exemption from the prohibition on the sale, supply, transfer or export of banknotes denominated in any official currency of a member state to or for use in belarus, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in belarus, under certain conditions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a belarusian natural or legal person. provides for the freezing of funds and economic resources of, and prohibits making funds or economic resources available to, designated persons, entities and bodies. introduces an additional designation criterion which applies to those forming part of, supporting, materially or financially, or benefiting from the military and industrial complex of belarus. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. union operators can seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as result of claims lodged by the entities or persons. union operators can seek damages from certain persons, entities or bodies that own or control the entities or bodies. introduces provisions in relation to the exchange of information and reporting requirements. union operators that are selling, supplying, transferring or exporting such goods to third countries are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to belarus and mitigating such risks. union operators are required to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions. includes technical amendments. council regulation (eu) 2025/395 (regulation 395) 24 february 2025 regulation 833 on publication date extends the suspension of the broadcasting licences in the union of russian media outlets under the permanent control of the russian leadership, and the prohibition on broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of certain media outlets in the union, or directed at the union. adds 53 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512 on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. also includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles (uavs) or missiles. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemical precursors to riot control agents, software related to computer numerical control (cnc) machines, chromium compounds and controllers used to guide uavs. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as chemicals, some plastics and rubber. further extends the list of goods and technology subject to the prohibition on transit via the territory of russia. empowers competent authorities to authorise the sale and export, and related technical assistance, of information security systems, equipment and components, for non-military use and for a non-military end user, after having determined that such goods or technology or the related technical assistance are intended for a civilian non-publicly available electronic communications network, and provided that that network is not the property of an entity that is publicly controlled or with over 50 % public ownership, such authorisations can be granted in particular to providers of specialised financial messaging services. introduces further restrictions on the import of primary aluminium, which generates significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. introduces a new targeted derogation from the prohibition on importing certain items that are strictly necessary for the operation of the druzhba pipeline. limits the application of an exemption to the flight ban on manned aircraft by introducing the need for an authorisation by the competent authorities. extends the flight ban to listed air carriers operating domestic flights within russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to a russian air carrier or for flights within russia, as well as to any entity owned or controlled by such air carrier. imposes further restriction on exports of goods and technology, in particular software related to oil and gas exploration, in order to further restrict russia’s oil and gas exploration and production capacities. provides for a derogation for the sale, supply, transfer or export from slovakia to hungary or from hungary to slovakia of certain petroleum products as listed in annex xxxi to regulation 833 which are obtained from crude oil imported by pipeline. introduces a prohibition on the provision of temporary storage for russian crude oil and petroleum products within the union, irrespective of the purchase price of the oil and of the final destination of those products. clarifies that reloading services for the purposes of transshipment operations of russian lng are allowed if necessary for its transport between ports of the same member state, including from the mainland of a member state to its outermost regions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a russian natural or legal person. entities established in the union before 8 april 2022 and already operating as road transport undertakings should be prohibited from making any changes to their capital structure that would increase the percentage share owned by a russian natural or legal person, entity or body, unless that percentage share remains below 25 % following such a change. extends prohibitions to the completion of crude oil projects in russia, such as the vostok oil project. introduces a derogation from the prohibition that can be granted by a member state that is not connected to the interconnected natural gas system when the lng is purchased, imported or transferred from a terminal located in another member state that is connected to the interconnected natural gas system in order to ensure its energy supply. requires imports of rough diamonds to be accompanied by a certificate in which the country of mining origin or the countries of mining origin are clearly stated. postpones the date of entry into force of the requirement to provide traceability-based evidence for imports of polished diamonds. furthermore, addressing governance issues associated with the traceability system will require ongoing cooperation with the g7 and third countries. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, license or transfer in any other way of intellectual property rights or trade secrets related to that software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of russia located in a member state. introduces a prohibition on any transaction with ports and locks and airports in russia that are used for the transfer of uavs or missiles or related technology or components thereof to russia, or for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices or of other restrictive measures. imposes restrictions on legal persons, entities or bodies established outside russia that use the system for transfer of financial messages of the central bank of russia. introduces a derogation allowing the execution of transactions with a specific entity included in annex xliv to regulation 833 that are necessary for the repayment of guarantees granted by a member state, divestment from russia or the wind-down of business activities in russia, or execution of certain contracts. further extends the transaction ban on credit institutions, financial institutions and entities providing crypto assets services that support transactions in relation to any listed vessel, thus frustrating the prohibition set out in article 3s of regulation 833. imposes restrictions on legal persons, entities and bodies, as listed in annex xlv to regulation 833, established outside of the union that are credit or financial institutions or entities providing crypto assets services involved in transactions that facilitate, directly or indirectly, the circumvention of the prohibitions set out in article 3n of regulation 833. extends the restrictive measures in relation to the provision of specialised financial messaging services to certain russian credit institutions or entities subscribing to financial messaging services or russian subsidiaries of third-country credit institutions, which are relevant for the russian financial and banking system, and are either large and important regional banks, which consequently facilitate regional and federal finances and business, or banks which facilitate significant cross-border payments or banks which are already the subject of restrictive measures imposed by the union or by partner countries. adds a derogation for the acceptance of deposits otherwise restricted for operations necessary for the restructuring or liquidation of a legal person associated with an entity listed in annex i to regulation 269. introduces an exemption from the prohibition on the sale, supply, transfer or export to russia of banknotes denominated in any official currency of a member state, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in russia under certain conditions. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries that apply similar restrictive measures. extends the provision in regulation 833 on recognition of a claim for damages suffered by union operators as a consequence of a decision pursuant to specific russian legislation to those persons who are responsible for issuing that decision. adds to this provision a reference to russian legislation that allows for the corporate rights of foreign holding structures in economically significant russian organisations to be restricted, as well as for the direct foreign ownership in such organisations to be acquired by russian beneficiaries and for them to receive dividends directly. entitles union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as a result of claims lodged by certain entities or person. enables the commission to assist union operators facilitate their due diligence in respect of potential business partners and enables the commission to process personal data for this purpose. union operators that are selling, supplying, transferring or exporting such goods to third countries, other than the partner countries listed in annex viii to regulation 833, are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to russia and mitigating such risks. requires union operators to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies, and replaces exemptions from certain prohibitions by derogations. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions of regulation 833. adds specific references to the applicable russian legislation in order to update some provisions concerning the protection of union operators. includes technical amendments to improve the accuracy of certain provisions of regulation 833 concerning personal data and documents held by the institutions of the union and to improve the linguistic clarity of certain other provisions. council regulation (eu) 2025/398 (regulation 398) 24 february 2025 regulation 263 on publication date prohibits, subject to certain exceptions, the supply to the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia of banknotes denominated in any official currency of a member state. introduces restrictions on the export to the non-government controlled areas of certain goods and technology that are also restricted by regulation 833. prohibits the provision to the non-government controlled areas of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. it also prohibits the provision to the non-government controlled areas of certain software for the management of enterprises and software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and amends the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. requires that union operators undertake their best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation (eu) 2022/263. member states report about penalties imposed for violations of the restrictive measures. clarifies that the protection against liability that is granted to union operators if they did not know, and had no reasonable cause to suspect, that their actions would infringe union restrictive measures cannot be invoked where union operators have failed to carry out appropriate due diligence. council regulation (eu) 2025/401 (regulation 401) 24 february 2025 regulation 692 on publication date prohibits, subject to certain exceptions, the supply to crimea and sevastopol of banknotes denominated in any official currency of a member state. restricts the export to crimea and sevastopol of certain goods and technology that are also restricted by regulation 833. prohibits the provision to crimea and sevastopol of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. prohibits the provision to crimea and sevastopol of certain software for the management of enterprises and of software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and to amend the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. introduces a best-efforts obligation to union operators. introduces reporting obligations for member states in relation to penalties imposed for violations of restrictive measures. council implementing regulation (eu) 2025/389 (regulation 389) 24 february 2025 regulation 269 on publication date adds a further 48 individuals and 35 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/388 24 february 2025 decision 145 on publication date equivalent to those listed under regulation 389 and 390 above. council decision (cfsp) 2025/391 24 february 2025 decision 642 on publication date equivalent to those listed under regulation 392 above. council decision (cfsp) 2025/394 24 february 2025 decision 512 on publication date equivalent to those listed under regulation 395 above. council decision (cfsp) 2025/396 24 february 2025 decision 266 on publication date equivalent to those listed under regulation 398 above. council decision (cfsp) 2025/397 24 february 2025 decision 386 on publication date equivalent to those listed under regulation 401 above. council implementing regulation (eu) 2025/527 (regulation 527) 14 march 2025 regulation 269 on the day following that of its publication date adds further 126 individuals and 36 entities to the asset freeze list under regulation 269. deletes 3 deceased persons, 4 other persons and 3 duplicate entries from the asset freeze list under regulation 269. council decision (cfsp) 2025/528 14 march 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 527 above. council implementing regulation (eu) 2025/631 (regulation 631) 27 march 2025 article 8a(1) of regulation (ec) no 765/2006 on publication date adds further 25 individuals and 7 legal persons in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 in view of the situations in belarus. council implementing decision (cfsp) 2025/632 27 march 2025 decision 642 on publication date equivalent to those listed under regulation 631 above. council implementing regulation (eu) 2025/701 (regulation 701) 8 april 2025 regulation 833 on the day following that of its publication date provides that the restrictive measures to suspend the broadcasting activities in the eu, or directed at the eu, of certain media outlets listed in annex v to regulation 395 should apply as of 9 april 2025. council decision (cfsp) 2025/700 8 april 2025 article 4g of decision 2014/512/cfsp on the day following that of its publication date equivalent to those listed under regulation 701 above. council regulation (eu) 2025/903 (regulation 903) 14 may 2025 regulation 269 on the day following that of its publication date introduces a new listing criterion to include natural or legal persons, entities or bodies that have participated in or enabled transfers of ownership, control or economic benefit of the business interests of leading businesspersons operating in russia. sets outs the burden of proof required for the council to maintain the inclusion of leading businesspersons on the list of natural or legal persons, entities or bodies subject to restrictive measures. council decision (cfsp) 2025/904 14 may 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 903 above. council regulation (eu) 2025/932 (regulation 932) 20 may 2025 regulation 833 on the day following that of its publication date adds 31 new entities to the list of natural or legal persons, entities or bodies set out in annex iv to regulation 833, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. also includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on unmanned aerial vehicles or computer numerical control machine tools. expands the list in annex vii of regulation 833 of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemical precursors to energetic materials and spare parts for machine tools. extends the duration of an exemption from the oil price cap which allows, in view of energy security concerns, the transport, by vessel, of crude oil originating in the sakhalin-2 project in russia to japan. adds 189 vessels to the list of vessels set out in annex xlii to regulation 833, which are banned from accessing member states’ ports and locks, as well as from receiving a broad range of services related to maritime transport. council regulation (eu) 2025/964 (regulation 964) 20 may 2025 regulation 2642 on the day following that of its publication date amends the criteria guiding individual designations in the listings freezing assets and the prohibition from making funds and economic resources available to listed persons bodies and entities. introduces additional measures prohibiting transactions with tangible assets supporting russia-driven destabilising activities, such as vessels, aircraft, real estate, ports, airports, physical elements of digital and communication networks. prohibits broadcasting in the eu by specifically-designated media outlets. suspends the broadcasting licences in the eu of the specifically-designated media outlets, and prohibits the broadcasting of their content in the eu directing it to the eu. council implementing regulation (eu) 2025/933 (regulation 933) 20 may 2025 regulation 269 on publication date adds a further 17 individuals and 58 entities to the asset freeze list under regulation 269 council implementing regulation (eu) 2025/958 (regulation 958) 20 may 2025 regulation 1485 on publication date adds 28 individuals to the asset freeze list under regulation 1485. council implementing regulation (eu) 2025/965 (regulation 965) 20 may 2025 regulation 2642 on publication date adds 21 individuals and 6 entities to the asset freeze list under regulation 2642. council implementing regulation (eu) 2025/959 (regulation 959) 20 may 2025 regulation 1542 on publication date adds 3 entities to the asset freeze list under regulation 1542. council decision (cfsp) 2025/931 20 may 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 932 above. council decision (cfsp) 2025/936 20 may 2025 decision 145 on publication date equivalent to those listed under regulation 933 above. council decision (cfsp) 2025/957 20 may 2025 decision 1484 on publication date equivalent to those listed under regulation 958 above. council decision (cfsp) 2025/963 20 may 2025 decision 2643 on the day following that of its publication date equivalent to those listed under regulation 964 above. council decision (cfsp) 2025/966 20 may 2025 decision 2643 on publication date equivalent to those listed under regulation 965 above. council decision (cfsp) 2025/960 20 may 2025 decision 1544 on publication date equivalent to those listed under regulation 959 above. council implementing regulation (eu) 2025/1438 (regulation 1438) 15 july 2025 regulation 1485 on publication date adds 5 individuals to the list of natural and legal persons, entities and bodies set out in annex iv to regulation 1485. council implementing regulation (eu) 2025/1444 (regulation 1444) 15 july 2025 regulation 2642 on publication date adds 9 individuals and 6 entities to the list of natural and legal persons, entities and bodies set out in annex i to regulation 2642. council decision (cfsp) 2025/1425 15 july 2025 decision 1484 on publication date equivalent to those listed under regulation 1438 above. council decision (cfsp) 2025/1443 15 july 2025 decision 2643 on publication date equivalent to those listed under regulation 1444 above. council regulation (eu) 2025/1472 (regulation 1472) 18 july 2025 regulation 765 on the day following that of its publication date prohibits the sale, supply, transfer or export to belarus of arms and related materiel of all types. further prohibits the procurement from belarus of arms and related materiel of all types. provides member states with an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in annex va to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in belarus or that the end-use of the items may be for belarusian entities. expands into a transaction ban the existing prohibition to provide specialised financial messaging services to certain belarusian credit institutions and their belarusian subsidiaries, which are relevant for the belarusian financial system, and which are already the subject of restrictive measures imposed by the eu. adds exemptions related to the functioning of diplomatic and consular representations of the eu and of the member states or of partner countries in belarus, and, to transactions made by nationals of a member state who are residents in belarus. adds a derogation for transactions which are strictly necessary for the divestment from belarus or for the wind-down of business activities in belarus. prohibits member states from recognising or enforcing any injunction, order, relief, judgment of a court other than a court of a member state or other court, arbitral or administrative decision issued in proceedings other than those in the member states pursuant to or derived from investor-state dispute settlement proceedings in connection with measures imposed under regulation 765. enables competent authorities or the eu, where applicable, to recover in proceedings before a court of a member state any damages caused, including legal costs and costs incurred in the event of non-compliance with the arbitral award by the other party, from those persons, entities or bodies and from persons, entities or bodies that own or control those persons, entities or bodies, as a consequence of an investor-state dispute settlement in connection with measures imposed under regulation 765, provided that all available legal remedies in the relevant jurisdiction have been exercised. enables member states to invoke any objection available to them in domestic or foreign proceedings for the recognition and enforcement of such awards when member states are confronted with arbitral awards rendered against them in investor-state dispute settlement proceedings in connection with measures imposed under regulation 765. extends the application of the forum necessitatis provision to article 8l. adds a new entity to the list of natural and legal persons, entities and bodies set out in annex ii to decision 2012/642/cfsp. expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including chemical precursors to energetic materials, spare parts for machine tools, additional computer numerical control (cnc) machines and constituent chemicals for propellants. expands the list of goods subject to export restrictions which might contribute to the enhancement of belarusian industrial capacities, such as machinery, chemicals, some metals and plastics. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus. council regulation (eu) 2025/1494 (regulation 1494) 18 july 2025 regulation 833 on the day following that of its publication date prohibits the sale, supply, transfer or export to russia of arms and related materiel of all types, and the procurement from russia of arms and related materiel of all types. adds 26 to the list of persons, entities and bodies supporting russia’s military and industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on unmanned aerial vehicles. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector, by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including additional computer numerical control machines and constituent chemicals for propellants. introduces an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in annex vii to regulation 833 to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in russia or that the end-use of the items may be for russian entities. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as machinery, chemicals, some metals and plastics. further extends the list of goods and technology subject to the prohibition on transit via the territory of russia. ends the temporary derogation granted to czechia for the supply of crude oil by pipeline from russia. imposes a prohibition on the purchase, import, or transfer, directly or indirectly into the eu, of petroleum products obtained in a third country from russian crude oil, as well as on the provision of related technical or financial assistance. introduces a list of partner countries which have a set of restrictive measures that are substantially equivalent to those imposed by the eu on imports of russian oil and petroleum products. introduces a derogation from the prohibition that can be granted by a member state that is not directly connected to the interconnected natural gas system of any other member state and that receives the first commercial supply of its first long-term natural gas supply contract after 20 july 2025 in order to ensure its energy supply. introduces an exemption from the transaction ban, provided that a competent authority has imposed a public trusteeship or similar public firewall measure or the competent authority has authorised a similar firewall measure. amends the conditions for imposing a transaction ban on persons, entities or bodies established outside russia that use the system for transfer of financial messages (spfs) of the central bank of russia or equivalent specialised financial messaging services set up by the central bank of russia. provides for an exemption from the transaction ban on certain ports for kazakh coal based on the eu’s commitment to prevent negative impacts on energy security of third countries around the globe. provides for an exemption from the transaction ban on certain airports with regard to civil nuclear capabilities and facilities. introduces restrictive measures banning any transaction that is directly or indirectly connected to the natural gas pipelines nord stream and nord stream 2 and that concerns the completion, operation, maintenance or use of the pipelines or parts of the pipelines. expands the transaction ban on third-country credit and financial institutions and crypto assets services providers to include entities that are significantly frustrating the purpose of the prohibitions in regulations 833 and 269 adds 2 entities to the list of third country financial institutions subject to that ban. expands into a transaction ban the existing prohibition on the provision of specialised financial messaging services to certain russian credit or financial institutions or other entities subscribing to financial messaging services or to russian subsidiaries of third-country credit or financial institutions. adds 22 credit or financial institutions and other entities to the list of legal persons, entities or bodies subject to that transaction ban. adds exemptions related to the functioning of diplomatic and consular representations of the eu and of the member states or of partner countries in russia and to transactions made by nationals of a member state who are residents in russia. adds a derogation for transactions which are strictly necessary for divestment from russia or for the wind-down of business activities in russia. provides for a dynamic automatic procedure to modify the price cap for russian crude oil depending on the average market price of russian crude oil. introduces a transaction ban targeting the rdif, its subsidiaries, its significant investments and anyone providing those entities with investment services or other financial services. adds 4 entities to the list of legal persons, entities and bodies, in which rdif has made significant investments, that are subject to the transaction ban. adds 105 vessels to the list of vessels set out in annex xvi to decision 512 which are banned from member states’ ports and locks, as well as from receiving a broad range of services related to maritime transport. imposes a prohibition on the provision of software with certain uses in the banking and financial sector. prohibits member states from recognising or enforcing any injunction, order, relief, judgment of a court other than a court of a member state or other court, arbitral or administrative decision issued in proceedings other than those in the member states pursuant to or derived from investor-state dispute settlement proceedings in connection with measures imposed under regulations 833 or 269. enables enable competent authorities or the eu, where applicable, to recover in proceedings before a court of a member state any damages caused, including legal costs and costs incurred in the event of non-compliance with the arbitral award by the other party, from those persons, entities or bodies and from persons, entities or bodies that own or control those persons, entities or bodies, as a consequence of an investor-state dispute settlement in connection with measures imposed under regulations 833 or 269, provided that all available legal remedies in the relevant jurisdiction have been exercised. enables member states to invoke any objection available to them in domestic or foreign proceedings for the recognition and enforcement of such awards when they are confronted with arbitral awards rendered against them in investor-state dispute settlement proceedings in connection with measures imposed under regulation 269 or 833. extends the application of the forum necessitatis provision to article 11e. council implementing regulation (eu) 2025/1469 (regulation 1469) 18 july 2025 article 8a(1) of regulation 765 on publication date adds 8 entities to the asset freeze list under regulation 765. council implementing regulation (eu) 2025/1476 (regulation 1476) 18 july 2025 regulation 269 on publication date adds 14 individuals and 41 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/1471 18 july 2025 decision 642 on the day following that of its publication date equivalent to those listed under regulation 1472 above. council decision (cfsp) 2025/1478 18 july 2025 decision 145 on publication date equivalent to those listed under regulation 1476 above. council decision (cfsp) 2025/1495 18 july 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1494 above. council implementing decision (cfsp) 2025/1461 18 july 2025 decision 642 on publication date equivalent to those listed under regulation 1469 above. council implementing regulation (eu) 2025/1894 (regulation 1894) 12 september 2025 regulation 269 on the day following that of its publication date adds 142 individuals and 134 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/1895 12 september 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 1894 above. council regulation (eu) 2025/2033 (regulation 2033) 23 october 2025 regulation 833 on the day following that of its publication date adds 45 entities to the list of legal persons, entities or bodies on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. this list includes certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on computer numerical controlled machine tools, on microelectronics, unmanned aerial vehicles, and other dual-use and advanced technology items. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides and alloys used in the manufacturing of military systems. introduces a new targeted derogation from the prohibition on purchasing, importing or transferring certain items -which generate significant revenues for russia and which are necessary for the operation, maintenance or repair of ultra-violet lamps used for the disinfection of drinking water. amends the derogation from the prohibition on purchasing, importing or transferring certain items which generate significant revenues for russia, and which are necessary for the operation, maintenance or repair of budapest metro line 3 cars. extends the prohibition to purchase, import or transfer certain items which generate significant revenues for russia to all acyclic hydrocarbons. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as salts and ores, articles of rubber, tubes, tyres, millstones and construction materials. extends the list of partner countries for importation of petroleum products. imposes a prohibition on the purchase, import, or transfer, directly or indirectly into the eu of liquified natural gas originating or exported from russia, as well as on the provision of related technical or financial assistance. introduces additional designations of vessels, amends one of the designation criteria and amends related provisions on prohibited services for designated vessels. removes certain energy-related exemptions from the transaction ban for two specific state-owned enterprises. expands the transaction ban that applies to legal persons, entities or bodies that are connecting to the system for transfer of financial messages of the central bank of the russian federation or equivalent specialised financial messaging services set up by the central bank of russia, to other payment services, such as the russian national payment card system or the fast payments system set up by the central bank of russia or by other russian entities. adds exemptions for transactions that are necessary for the functioning of diplomatic and consular representations of the eu and of the member states in third countries and for transactions made by nationals of a member state who are residents of a third country, for transactions that are necessary for existing contracts and the reception of payments, and for member states’ ethnic minorities in russia. expands the transaction ban on third-country credit and financial institutions and crypto-asset service providers to also include entities that provide payment services, and in particular entities that provide crypto-asset and payment services to listed entities. expands the transaction ban to cover equivalent entities if certain criteria are met. adds 8 new entities to the list in annex xlv to regulation 833. adds exemptions for transactions that are necessary for existing contracts and the reception of payments. extends the transaction ban to any ports and locks in third countries other than russia that are used for the transfer of unmanned arial vehicles or missiles or related technology or components thereof to russia, or for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices, or for the circumvention of other restrictive measures. prohibits any new participation in, the creation of joint ventures with, and the provision of financing to, any enterprise established in or operating through certain special economic, innovation or preferential zones, as well as prohibiting entering into new contracts with such enterprises prohibits the maintaining of any participation in, or of joint ventures or contracts with, any enterprise established in or operating through certain special economic, innovation or preferential zones. adds appropriate exemptions and derogations to prevent undesirable effects of those prohibitions. imposes restrictions on the provision of crypto-asset services, on the provision of certain payment services and on the issuing of electronic money to russia nationals, natural persons residing in russia, and legal persons, entities or bodies established in russia, in view of the importance of those services to the development of russia’s financial technology and e-commerce sectors and the potential use of crypto-asset services to circumvent restrictive measures. prohibits transactions involving certain crypto-assets, while also allowing for a limited period of time to enable the orderly termination of existing contracts. adds five credit or financial institutions to the list of legal persons, entities or bodies subject to a transaction ban. adds exemptions necessary for humanitarian purposes, for the export, sale, supply, transfer or transport of pharmaceutical, medical or agricultural and food products, to ensure access to judicial, administrative or arbitral proceedings in a member state, as well as for the recognition or enforcement of a judgment or an arbitration award rendered in a member state, for the reception of payments due by the legal persons, entities or bodies controlled by the russian government pursuant to contracts performed before 15 may 2022, and for the implementation of certain authorisations granted pursuant to regulation 269 and for member states’ ethnic minorities in russia. imposes further restrictions on the provision, to the government of russia or to legal persons, entities or bodies established in russia, of services that contribute to enhancing russia’s technological capabilities, namely the provision of certain commercial space-based services, certain artificial intelligence services, and high-performance computing and quantum computing services. expands the scope of current restrictions to cover not only technical testing and analysis, but also other services which form group 867 of the central products classification. restricts the provision of services directly related to tourism activities in russia. introduces a requirement for prior authorisation by the competent authority for any services provided to the government of russia which are not already subject to the restrictive measures set out in regulation 833. prohibits providing reinsurance for russian used aircraft or vessels during a period of five years following the sale or lease arrangement of those aircraft or vessels made after the entry into force of this regulation. establishes a prior notification mechanism for russian diplomats and consular officers, as well as for members of the administrative and technical staff or of the service staff of diplomatic missions or consular posts of russia, and for their family members within the schengen area and when traveling to a member state other than that of their accreditation. provides that member states willing to do so, may impose an authorisation requirement for travel to their territories of such individuals, based on visas or residence permits issued by another state. makes certain technical amendments including extending the deadlines applicable to certain derogations needed for divestments from russia. council regulation (eu) 2025/2037 (regulation 2037) 23 october 2025 regulation 269 on the day of its publication introduces an additional criterion for the listing of natural or legal persons, entities or bodies responsible for, supporting or implementing actions or policies contributing to the deportation, forced transfer, forced assimilation, including indoctrination, or militarised education of ukrainian minors. extends to two listed insurance companies the existing derogation related to payments constituting an indemnity or benefit provided further to the materialisation of a risk. includes definitions of ‘owning’ and ‘controlling’ a legal person, entity or body. clarifies the provision on the freezing of funds and economic resources of listed persons and the prohibition on making funds and economic resources available to such persons. council regulation (eu) 2025/2041 (regulation 2041) 23 october 2025 regulation (ec) 765 on the day following that of its publication date expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by adding items which include electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides and alloys used in the manufacturing of military systems. expands the list of goods subject to export restrictions which might contribute to the enhancement of belarusian industrial capacities, such as salts and ores, articles of rubber, tubes, tyres, millstones and construction materials. imposes further restrictions on the provision, to the republic of belarus, its government, its public bodies, corporations or agencies or to any natural or legal person, entity or body acting on their behalf or at their direction, of software with certain uses in the banking and financial sector and services that contribute to enhancing belarus’ technological capacities, namely the provision of certain commercial space-based services, certain artificial intelligence services, and high-performance computing and quantum computing services. expands the scope of current restrictions to cover not only technical testing and analysis, but also other services, which notably include, the following engineering related scientific and technical consulting services: geological, geophysical and other scientific prospecting, subsurface surveying, surface surveying and map-making services. introduces requirement for prior authorisation by the competent authority for any services provided to the republic of belarus, its government, its public bodies, corporations or agencies which are not already subject to the restrictive measures set out in 765. imposes restrictions on the provision of crypto-asset services, on the provision of certain payment services and on the issuing of electronic money to belarusian nationals, natural persons residing in belarus, and legal persons, entities or bodies established in belarus, in view of the importance of those services to the development of belarus’s financial technology and e-commerce sectors and the potential use of crypto-asset services to circumvent restrictive measures. adds exemptions necessary for humanitarian purposes, for the export, sale, supply, transfer or transport of pharmaceutical, medical or agricultural and food products, to ensure access to judicial, administrative or arbitral proceedings in a member state, as well as for the recognition or enforcement of a judgment or an arbitration award rendered in a member state. extends the prohibition to purchase, import or transfer certain items which allow belarus to diversify its sources of revenue to all acyclic hydrocarbons. makes certain technical amendments in the operative text and annexes to improve the accuracy and clarity of certain provisions of regulation 765 council implementing regulation (eu) 2025/2035 23 october 2025 regulation 269 on the day of its publication adds 22 individuals and 42 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2025/2039 (regulation 239) 23 october 2025 article 8a(1) of regulation (ec) 765/2006 on the day of its publication adds 2 individuals and 3 entities to the asset freeze list under regulation 765. council decision (cfsp) 2025/2032 23 october 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 2033 above. council decision (cfsp) 2025/2036 23 october 2025 decision 145 on the day of its publication equivalent to those listed under regulation 2037 above. council decision (cfsp) 2025/2040 23 october 2025 decision 642 on the day following that of its publication date equivalent to those listed under regulation 2041 above. council implementing decision (cfsp) 23 october 2025 decision 642 on the day of its publication equivalent to those listed under regulation 2039 above. council implementing regulation (eu) 2025/2356 (regulation 2356) 20 november 2025 regulation 1485 on the day of its publication adds 10 individuals the list of natural and legal persons, entities and bodies set out in annex iv to regulation 1485. council decision (cfsp) 2025/2357 20 november 2025 decision 1484 on the day of its publication equivalent to those listed under regulation 2356 above.

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CySEC calls for Stronger Governance and Reporting Standards across CIFs

on 24 october 2025, the cyprus securities and exchange commission (cysec) issued circular c736 to address compliance issues observed among cyprus investment firms (cifs) regarding the prudential supervision of investment firms law (law 165(i)/2021) and regulation (eu) 2019/2033 (ifr). below are the key points: prudential reporting: cifs must ensure timely and accurate submission of prudential and remuneration reports via cysec’s xbrl portal, adhering to article 54 of the ifr. compliance with prudential requirements: cifs are required to continuously monitor and meet prudential obligations under articles 9, 11, and 43 of the ifr, taking immediate corrective actions when deficiencies arise. data consistency: material discrepancies between prudential reports and other financial documents (e.g., audited statements) must be avoided. cifs should ensure accurate data mapping during report preparation and are urged to refer to commission implementing regulation (eu) 2021/2284 for guidance. remuneration policies: class 2 cifs must ensure compliance with sections 24 and 26 of law 165(i)/2021 regarding remuneration policies, including deferral of variable pay and adherence to eba guidelines. governance committees: cifs must establish risk and remuneration committees as per law 165(i)/2021, ensuring proper composition, gender balance, and compliance with governance standards. internal governance: cifs should enhance policies on conflicts of interest in the context of loans and other transactions with members of their management body and their related parties to align with the eba’s guidelines. liquid assets: cifs must ensure that items be accurately recorded as liquid assets under article 43(1) of the ifr. unencumbered short-term deposits should qualify as liquid assets only if they are unencumbered short-term deposits at a credit institution, therefore amounts held with electronic money institutions (emis) or payment service providers (psps) are excluded. cifs are advised to refer to eba q&a 2021 6299 for further guidance. prudential consolidation: cifs must regularly assess alterations to group structures to accurately assess whether entities qualify as financial institutions or union parent investment firms. entities that fall under those definitions must ensure compliance with ifr prudential consolidation requirements. audited financial statements: cifs must accurately disclose modified auditor opinions and pillar iii links by ensuring that the relevant form is completed fully and accurately. next steps: cifs are urged to review their practices to ensure full compliance with applicable laws, regulations, and guidelines. cysec will continue monitoring and may impose sanctions for non-compliance. for further details, cifs are encouraged to consult the full circular here

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Update to UK Sanctions on Russia-Ukraine-Belarus (up to 28 November 2025)

further to our blog post on uk russia sanctions, please find below an updated table of sanctions. table.instrument-table { table-layout: auto; border-collapse: collapse; width: 100%; max-width: 100%; margin-left: auto; margin-right: auto; margin-bottom: 10px; border: 1px solid #000000; overflow-x: auto; } table.instrument-table th, table.instrument-table td { border: 1px solid #000000; padding: 5px; vertical-align: top; } table.instrument-table thead tr { color: #ffffff; background-color: #3a5dae; } table.instrument-table tbody tr:nth-child(even) { background-color: #f1f1f1; /* light grey */ } table.instrument-table h5 { font-size: 1.15em; margin: 0; } table.instrument-table p { font-size: 14px; color: #000000; margin: 0; line-height: 1.6; } table.instrument-table a { color: inherit; text-decoration: underline; } table.instrument-table li { font-size: 14px; color: #000000; padding-top: 2px; line-height: 1.6; } table.instrument-table ul { list-style-type: square; } # name of instrument date published amends or implements? comes into force summary of key provisions 1 the russia (sanctions) (eu exit) (amendment) regulations 2022 10 february 2022 amends the russia (sanctions) (eu exit) regulations 2019 (2019 uk-russia regulations) 10 february 2022 the amendments broaden the categories of people and entities which are capable of being designated under the sanctions regime in the 2019 regulations. no new designations have actually occurred and the motivation for the amendments is of course the current threat of invasion by russia into ukraine’s sovereign territory. see further our blog post here. 2 financial sanctions notice 22 february 2022 implemented under the 2019 uk-russia regulations 22 february 2022 the following are added to the uk consolidated list and are subject to an asset freeze: gennadiy timchenko boris romanovich rotenberg igor arkadyevich rotenberg bank rossiya black sea bank for development and reconstruction jsc genbank is bank pjsc promsvyazbank as a result, uk and bots individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and 2individuals. additionally, the designated individuals are banned from entering the uk. 3 financial sanctions notice 24 february 2022 implemented under the 2019 uk-russia regulations 24 february 2022 the following are added to the uk consolidated list and are subject to an asset freeze: kirill shamalov petr fradkov denis bortnikov yury slyusar elena aleksandrovna georgieva rostec uralvagonzavod tactile missile corporation united aircraft corporation united shipbuilding corporation as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. additionally, the designated individuals are banned from entering the uk. 4 financial sanctions notice (2) 24 february 2022 implemented under the 2019 uk-russia regulations 24 february 2022 additionally makes the following entities, which were subject to sectoral sanctions, additionally subject to asset freeze: vtb bank (but subject to a general licence (gl) for wind down) uralvagonzavod united aircraft corporation 5 uk government announcement 24 february 2022 [to be implemented via amendments to 2019 uk-russia regulations] on-going the following further sanctions and measures announced by the uk government include: new legislation that aims to exclude all major russian banks from the uk banking system. this means they will not be able to clear payments through the uk nor will they be able to access gbp new legislation also seeks to freeze the assets of all major russian banks, including vtb bank obstructing major russian companies and the state from the uk markets (financing), also through the introduction of new legislation 100 new individuals or entities will be added to the uk’s sanctions list aeroflot will be banned from landing in the uk all dual use export licences to cover components which can be used for military purposes have been suspended with immediate effect the uk will stop exports of high-tech items and oil refinery equipment in the next few days there will be a limit of £50,000 on deposits russians can make into a uk bank account removing russia out of the swift international payment system, which has been supported by the european union and the us similar financial sanctions will be extended to belarus for its role in the assault on ukraine. 6 financial sanctions notice 25 february 2022 implemented under 2019 uk-russia regulations 25 february 2022 the following are added to the consolidated list and are now subject to an asset freeze: vladimir putin sergei lavrov as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. additionally, the designated individuals are banned from entering the uk. 7 general licence int/2022/1272278 (vtb) 25 february 2022 issued under regulation 64 of 2019 uk-russia regulations takes effect from 25 february 2022 expires on 27 march 2022 importantly, on 25 february 2022, the uk’s office of financial sanctions implementation announced the publication of a new russia-related general licence allowing for a 30 day wind down of positions involving vtb bank. general licence int/2022/1272278 provides that any person may wind down any transaction to which it is a party which involve vtb bank or vtb capital plc (and any entity owned or controlled by vtb capital plc incorporated in the uk) , including the closing out of any positions. the gl does not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting will result in funds or economic resources being dealt with or made available in breach of the 2019 uk-russia regulations, save for the specific permission mentioned above. the gl will expire on 27 march 2022. 8 russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2022 28 february 2022 amends the 2019 uk-russia regulations 1 march 2022 existing restrictions on dealing with certain financial instruments and providing loans and credit are amended to extend the sanctions prohibitions to a broader range of transferable securities and money market instruments and loans and credit. further restrictions on correspondence banking relationships and processing of sterling payments are also introduced. introduction of power for the secretary of state to designate persons for the purpose of that provision. the regulations provide for exceptions to, and for licensing powers in relation to, those prohibitions. in particular, there is provision to make clear that a licence may authorise acts which would otherwise be prohibited by any of the regulations for a particular period beginning with the coming into force of the prohibition, or the date of any designation made for the purposes of those provisions. this would allow a period for persons affected to arrange their affairs to comply. 9 russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2022 28 february 2022 amends the 2019 uk-russia regulations 1 march 2022 these regulations provide for significantly enhanced trade sanctions measures in relation to russia: prohibitions on the export, supply and delivery and making available of military goods are extended to include dual use goods and"critical industry" goods prohibitions on the making available and transfer of military technology are extended to include dual use technology and critical industry technology related prohibitions on the provision of technical assistance, financial services, funds and brokering services are also extended in relation to dual use goods and technology and critical industry goods and technology a number of exceptions from the trade prohibitions on critical-industry goods and technology are provided for as well as licensing arrangements. 10 uk statement on further economic sanctions targeted at the central bank of the russian federation 28 february 2022 [to be implemented via amendments to 2019 uk-russia regulations] on-going additional measures were announced on 28 february 2022 which will introduce a prohibition on uk persons undertaking financial transactions involving the central bank of russia, the russian national wealth fund and the ministry of finance of the russian federation and the uk government announced that it will immediately take all necessary steps to bring into effect restrictions. other points to note include: restrictions on russian financial institutions – vtb bank was designated by the uk last week, along with five other russian banks and it is not yet known what additional financial institutions may be subjected to restrictions restrictions to prevent russian companies from issuing transferable securities and money market instruments in the uk, in addition to the restrictions on the russian state raising sovereign debt powers to prevent designated banks from accessing sterling and clearing payments through the uk additional trade restrictions, including a prohibition on the export of certain high-end critical technical equipment and components in sectors including electronics, telecommunications and aerospace. the announcement reiterated that trade restrictions applicable to crimea will be extended to apply to donetsk and luhansk. 11 financial sanctions notice 28 february 2022 implemented under 2019 uk-russia regulations 28 february 2022 the following persons have been added to the uk asset freeze list: veb.rf bank otkritie financial corporation pjsc pjsc sovcombank as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. 12 the russia (sanctions) (eu exit) (amendment) (no. 4) regulations 2022 1 march 2022 amends 2019 uk-russia regulations 1 march 2022 the regulations prohibit russian ships, and other ships specified by the secretary of state, from entering ports in the uk there is a notification and publicity requirement where the specification power is used. the regulations provide the secretary of state with a power to control the movement of russian ships or specified ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are. the regulations also confer powers on the secretary of state and harbour authorities to detain russian ships or specified ships at ports or anchorages. the registration of ships on the uk ship register is prohibited where they are owned, controlled, chartered or operated by a designated person or persons connected with russia, or where they are a specified ship. 13 financial sanctions notice 1 march 2022 implemented under 2019 uk-russia regulations 1 march 2022 the following entity is subject to enhanced restrictive measures: pjsc sberbank whilst not subject to an asset freeze, it is subject to a prohibition on correspondent banking and sterling clearing. 14 financial sanctions notice 1 march 2022 implemented under 2019 uk-russia regulations 1 march 2022 the following persons have been added to the uk asset freeze list: andrei burdyko victor vladimirovich gulevich sergei simonenko andrey zhuk jsc 558 aircraft repair plant jsc integral as a result, uk and bot individuals and entities are now prohibited from any dealings with, or providing any funds to or for the benefit of, directly or indirectly, any of the russian banks and individuals. additionally, the designated individuals are banned from entering the uk. 15 the russia (sanctions) (eu exit) (amendment) (no. 5) regulations 2022 1 march 2022 amends 2019 uk-russia regulations 1 march 2022 prohibits the provision of financial services for the purpose of foreign exchange reserve and asset management to: the central bank of the russian federation the national wealth fund of the russian federation the ministry of finance of the russian federation an entity owned or controlled by, or acting on behalf/at the direction of, the above 3 entities 16 russia: regulatory authorities – prudential supervision or financial stability (notice) general license int/2022/1280976 1 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 1 march 2022 the licence pertains to vtb capital plc and any entity owned or controlled by vtb capital plc incorporated in the united kingdom. the licence relates to prudential supervision or protecting, maintaining or enhancing the stability of the financial system of the united kingdom. the licence takes effect from 1 march 2022 and expires on 1 march 2023. 17 russian banks – uk subsidiaries – basic needs, routine holding and maintenance and the payment of legal fees" (notice) general license int/2022/1280876 1 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 1 march 2022 the licence pertains to vtb capital plc and any entity owned or controlled by vtb capital plc incorporated in the united kingdom. the licence allows for the basic needs of uk subsidiaries and routine holding and maintenance of uk subsidiaries frozen funds or economic resources and the payment of legal fees. notifications requirements will need to be complied with. record keeping requirements will also need to be complied with. the licence took effect from 1 march 2022 and expires on 1 march 2023. 18 financial sanctions notice 3 march 2022 implemented under 2019 uk-russia regulations 3 march 2022 the following persons have been added to the asset freeze and travel ban list: alisher usmanov igor shuvalov 19 wind down of positions involving various designated banks general license int/2022/1295476 4 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 4 march 2022 the designated persons under the licence are: bank otkritie promsvyazbank bank rossiya sovcombank vnesheconombank (veb) subsidiaries (entities owned or controlled) of any of the above are also within scope of the licence. the licence allows persons to wind down any transactions to which the person is a party involving any of the designated persons (including jscb novikombank) and their subsidiaries. the licence takes effect from 4 march and expires on 3 april 2022. 20 general licence – wind down of positions sberbank general license int/2022/1298776 4 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 4 march 2022 the designated person under the licence is pjsc sberbank, including any subsidiary (an entity owned or controlled by pjsc sberbank). the licence allows that a person may provide financial services to sberbank for the purposes of winding down that activity. the licence takes effect from 4 march and expires on 3 april 2022. 21 financial sanctions notice 4 march 2022 implemented under 2019 uk-russia regulations 4 march 2022 the notice is to issue a correction to an entry on the consolidated list brining the entry into line with the uk sanctions list. igor ivanovich shuvalov (group id: 14209) is still subject to an asset freeze. 22 updated russia guidance 4 march 2022 guidance for the financial and investment restrictions in russia (sanctions) (eu exit) regulations 2019 4 march 2022 the office of financial sanctions is the competent authority responsible for improving the understanding, implementation and enforcement of financial sanctions in the uk. this guidance sets out an overview of the sanctions regime on russia to date. 23 general licence – wind down of positions involving vtb general license int/2022/1272278 7 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 7 march 2022 the designated person under the licence is vtb bank and subsidiary entity owned or controlled by vtb bank. the licence allows that a person may provide financial services to vtb bank for the purposes of winding down that activity. the licence took effect from 25 february and expires on 27 march 2022. 24 the russia (sanctions) (eu exit) (amendment) (no. 6) regulations 2022 8 march 2022 amends 2019 uk-russia regulations 8 march 2022 these regulations provide for new aviation and trade sanctions measures in relation to russia. the regulations confer powers on the secretary of state, air traffic control and airport operators to prevent russian aircraft from entering the airspace, landing in or requiring aircraft to leave the airspace of the united kingdom. an exception from the prohibitions is when the lives of persons and the safety of the aircraft are in danger. 25 general licence: provision of navigational data to civilian aircrafts for flight safety general licence int/2022/1322576 9 march 2022 this licence is granted under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 (the belarus regulations). 9 march 2022 this licence pertains to provision of navigational data to civilian aircrafts for flight safety. records must be kept by flight data providers for up to 6 years. the licence takes effect on 9 march 2022 and is of indefinite duration. 26 financial sanctions notice 10 march 2022 implemented under 2019 uk-russia regulations 10 march 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: roman arkadyevich abramovich igor ivanovich sechin oleg vladimirovich deripaska dmitri alekseevich lebedev alexei borisovich miller andrei leonidovich kostin nikolai petrovich tokarev 27 general licence – football matches general licence int/2022/1327076 10 march 2022 this licence is granted under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 10 march 2022 this licence pertains to football matches and covers, who can be paid by the clubs and for what purposes. persons will be required under this licence to keep accurate, complete and readable records of any activity purporting to have been permitted under the licence with a value exceeding £5,000 for a minimum of 6 years. the licence takes effect from 10 march 2022 and expires on 31 may 2022. 28 financial sanctions notice 11 march 2022 implemented under 2019 uk-russia regulations 11 march 2022 386 individuals have been designated on the uk sanctions list and are now subject to an asset freeze. 29 financial sanctions notice 15 march 2022 implemented under 2019 uk-russia regulations 15 march 2022 350 individuals have been designated on the uk sanctions list and are now subject to an asset freeze. the following entries have been amended and are still subject to an asset freeze: anatoly borisovich vyborny aleksei mikhailovich chaliy 30 financial sanctions notice 15 march 2022 implemented under 2019 uk-russia regulations 15 march 2022 the following entries have been designated on the uk sanctions list and are now subject to an asset freeze: armen sumbatovich gasparyan suleyman abusaidovich kerimov tigray organesovich khudaverdyan dmitry yevgenevich kulikov alexey viktorovich kuzmichev alexander alexandrovich mikheev vladimir valerievich rashevsky viktor filippovich rashnikov andrey valerievich ryumin marina vladimirovna sechina artyom grigoryevich sheynin alexander nikolayevich shokhin rosneft aero jsc zelenodolsk shipyard the following entries have been amended and are still subject to an asset freeze: yulia vasilievna ogloblina anatoly vladimirovich voronovsky mikhail nikolaevich berulava oleg dmitrievich dimov sergei mikhailovich sokol tatyana ivanovna dyakonova dmitri alekseevich lebedev anatoly alexandrovich wasserman 31 financial sanctions notice 18 march 2021 implemented under 2019 uk-russia regulations 18 march 2021 the following entries have been corrected and are still subject to an asset freeze: fridman mikhail maratovic aven petr olegovich khan german borisovich tatarchenko denis sergeyevich nezhdanova yevgeniya vitalyevna ignatova ekaterina sergeevna shuvalova maria igorevna kolokoltsev vladimir puchkov andrey sergeevich shchegolev igor olegovich enberg liliya arkadyevna rotenberg roman borisovich shuvalov evgeny igorevich prigozhin pavel evgenyevich krans maksim iosifovich solovyov yuri alekseyevich rotenberg pavel arkedyevich rashnikov viktor filippovich kravchenko vladimir kasimirovich lobach tatyana kiriyenko vladimir sergeevich ulyutina galina volfovich aleksandr grigorievich bolotova maiya nikolaevna 32 general licence – wind down of derivatives, repurchase, and reverse repurchase transactions general licence int/2022/1381276 22 march 2022 implemented under 2019 uk-russia regulations 22 march 2021 for the purposes of this general licence the entities referred to consist of the: central bank of the russian federation (cbr) national wealth fund of the russian federation (nwf) ministry of finance of the russian federation (mf) under general licence int/2022/1381276 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. a person or relevant institution, can carry out any activity reasonably necessary to effect this. 33 updated financial sanctions general guidance 22 march 2022 22 march 2022 new paragraph (4.14) added to the ownership and control subject and clarifies ofsi's position on aggregation and reads as follows: "when making an assessment on ownership and control, ofsi would not simply aggregate different designated persons’ holdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated parties or one party controls the rights of another. consequently, if each of the designated person's holdings falls below the 50% threshold in respect of share ownership and there is no evidence of a joint arrangement or that the shares are held jointly, the company would not be directly or indirectly owned by a designated person. it should be noted that ownership and control also relates to holding more than 50% of voting rights, the right to appoint or remove a majority of the board of directors and it being reasonable to expect that a designated person would be able in significant respects to ensure that the affairs of a company are conducted in accordance with their wishes. if any of these apply, the company could be controlled by a designated person." 34 financial sanctions notice belarus 24 march 2021 implemented under 2019 belarus (sanctions) (eu exit) regulations 24 march 2022 the following entries have been added to the consolidated list and are subject to an asset freeze: bank dabrabyt joint stock company cjsc belbizneslizing ( industrial-commercial private unitary enterprise minotor-service jsc transviaexport airlines limited liability company belinvest-engineering ojsc kb radar-managing company holding radar system 35 financial sanctions notice russia 24 march 2022 implemented under 2019 uk-russia regulations 24 march 2022 33 individuals and 26 entities have been designated on the uk sanctions list and are now subject to an asset freeze. 36 general licence – wind down of positions involving various designated banks general license int/2022/1424276 24 march 2022 implemented under 2019 uk-russia regulations 24 march 2022 under this license, the designated persons (dps) are: alfa bank jsc gazprombank rosselkhozbank smp bank ural bank for reconstruction and development subsidiaries of the dps the gl permits a person (other than the dps or a subsidiary) to wind down any transactions to which it is party including the closing out of positions. a person, relevant institution, or the dps or a subsidiary, can carry out any activity reasonably necessary to effect this. 37 general licence – wind down of positions involving bank dabrabyt general license int/2022/1424277 24 march 2022 implemented under 2019 belarus (sanctions) (eu exit) regulations 24 march 2022 this license allows a person to wind down any transactions to which it is party including the closing out of positions with bank dabrabyt joint stock company or its subsidiaries. 38 amended general licence - wind down of derivatives, repurchase, and reverse repurchase transactions with the central bank of the russian federation, national wealth fund of the russian federation and ministry of finance of the russian federation general license int/2022/1381276 24 march 2022 implemented under 2019 uk-russia regulations 24 march 2022 the amendment clarifies that: "under general licence int/2022/1381276 a person may provide financial services for the purposes of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 1 march 2022 with the cbr, the nwf or the mf or those persons set out in regulation 18a d to e of the russia regulations. a person or relevant institution can carry out any activity reasonably necessary to effect this." 39 financial sanctions notice 25 march 2022 implemented under 2019 uk-russia regulations 25 march 2022 the following entry has been amended and is still subject to an asset freeze: sovcomflot also the following entries have been corrected: oleg yurievich tinkov eugene markovich shvidler 40 general licence – continuation of business and basic needs of gefco uk subsidiaries general license int/2022/1438977 note: this has since been revoked, see row 54 below for more details. 25 march 2022 implemented under 2019 uk-russia regulations 25 march 2022 under this license the designated entity is russian railways. the joint venture is gefco, a joint venture owned by russian railways and stellantis, gefco s.a rue jean jaures, 20-22, 92800 puteaux, france. a subsidiary is any entity owned or controlled by the designated entity, including: gefco uk ltd gefco forwarding uk auto xp limited xp tech limited under this licence a person may continue business operations involving the joint venture or its subsidiaries including, but not limited to: payments to or from the joint venture or its subsidiaries under any obligations or contracts; payments to or from any third party necessary to the continuation of any obligations or contracts. 41 general licence – wind down of positions involving sovcomflot general license int/2022/1469378 29 march 2022 implemented under 2019 uk-russia regulations 29 march 2022 under this license the designated entity is sovcomflot. a subsidiary is any entity owned or controlled by the designated entity. this licence allows a person (other than the designated entity or a subsidiary) to wind down any transactions to which it is party involving the designated entity or a subsidiary including the closing out of any positions. 42 the russia (sanctions) (eu exit) (amendment) (no. 7) regulations 2022 30 march 2022 amends 2019 uk-russia regulations 30 march 2022 these amendments introduce a power to designate persons by description, extend existing finance, trade and shipping sanctions measures in relation to crimea and sevastopol to the non-government controlled areas of the donetsk and luhansk oblasts of ukraine. the amendments introduce prohibitions on technical assistance relating to aircraft and ships, for the purposes set out in regulation 4 of the 2019 regulations. 43 updated russia guidance 31 march 2022 amends 2019 uk-russia regulations 31 march 2022 this guidance has been updated to reflect extending the financial restrictions in place to all non-government controlled ukrainian territory. 44 financial sanctions notice 31 march 2022 implemented under 2019 uk-russia regulations 31 march 2022 14 entries (12 individuals and 2 entities) have been added to the consolidated list and are now subject to an asset freeze. 45 financial sanctions notice 31 march 2022 implemented under 2019 uk-russia regulations 31 march 2022 under this license, the following entities have been added to the consolidated list and are now subject to an asset freeze. photon pro llp majory llp djeco group lp 46 general licence – payments by the central bank of the russian federation, the national wealth fund of the russian federation, or the ministry of finance of the russian federation related to debt issued by them before 1 march 2022. general license int/2022/1495176 1 april 2022 implemented under 2019 uk-russia regulations 1 april 2022 under this licence, a person may provide financial services for the purposes of the receipt and onward transfer of non-rouble denominated interest/coupon or maturity/principal payments from the central bank of the russian federation, the national wealth fund of the russian federation, or the ministry of finance of the russian federation (or those persons set out in regulation 18a (2) (d) - (e) of the russia regulations) in connection with debt issued by them before 1 march 2022. a person or relevant institution can carry out any activity reasonably necessary to effect this. 47 financial sanctions notice 4 april 2022 implemented under 2019 uk-russia regulations 4 april 2022 this entry has been amended and is still subject to an asset freeze: andrey anatolyevich turchak 48 financial sanctions notice 5 april 2022 implemented under 2019 uk-russia regulations 5 april 2022 this entry has been amended and is still subject to an asset freeze: wagner group 49 financial sanctions notice 6 april 2022 implemented under 2019 uk-russia regulations 6 april 2022 10 entries have been added to the consolidated list and are now subject to an asset freeze: individuals listed: ivanov sergei sergeivich rotenberg, boris borisovich akimov, andrey igorevich dyukov, alexander valeryevich kogogin, sergey anatolyevich guryev, andrey grigoryevich mikhelson, leonid viktorovich kantor, viatcheslav entities listed: credit bank of moscow pjsc sberbank (public joint-stock company sberbank) the following entries have been amended and are still subject to an asset freeze: gazprombank russian agricultural bank public joint stock company"united aircraft corporation jsc research and production corporation uralvagonzavod veb.rf vtb bank (public joint-stock company) 50 general licence –wind down of positions involving credit bank of moscow general license int/2022/1544176 6 april 2022 implemented under 2019 uk-russia regulations 6 april 2022 under this general licence 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. 51 general licence: asset freeze, correspondent banking relationships & processing amended general license int/2022/1277877 6 april 2022 implemented under 2019 uk-russia regulations 6 april 2022 this general licence has been 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. 52 financial sanctions notice 8 april 2022 implemented under 2019 uk-russia regulations 8 april 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: katerina vladimirovna tikhonova maria vladimirovna vorontsova yekaterina sergeyevna vinokurova further, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: evgeny alekseevich fedorov 53 financial sanctions notice 11 april 2022 implemented under 2019 uk-russia regulations 11 april 2022 the following entries have been amended and are still subject to an asset freeze: evgeny alekseevich fedorov tigran organesovich khudaverdyan katerina vladimirovna tikhonova 54 general licence – continuation of business and basic needs of gefco uk subsidiaries revoked general license int/2022/1438977 12 april 2022 implemented under 2019 uk-russia regulations 12 april 2022 this general license has been 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. 55 financial sanctions notice russia 13 april 2022 implemented under 2019 uk-russia regulations 13 april 2022 206 entries have been added to the consolidated list and are now subject to an asset freeze. 56 financial sanctions notice belarus 13 april 2022 implemented under 2019 belarus (sanctions) (eu exit) regulations 13 april 2022 9 individuals have been corrected to the consolidated list and are still subject to an asset freeze: azarenok grigoriy yurievich eismont natalia nikolayevna ipatau vadzim dzmitryevich hustyr yulia chaslavauna kalinousky siarhei aliakseevich kasyanchyk alina sergeevna lukashenko viktor aliaksandravich sakalouski ivan yurievich yarmoshina lidzia mihailauna 57 financial sanctions notice 14 april 2022 implemented under 2019 uk-russia regulations 14 april 2022 the following individuals have been added to the consolidated list and are now subject to an asset freeze: eugene tenenbaum david davidovich 58 the russia (sanctions) (eu exit) (amendment) (no. 8) regulations 2022 14 april 2022 amends 2019 uk-russia regulations 14 april 2022 this instrument provides for a number of trade restrictions. these include: to prohibit the export, supply and delivery, making available and transfer of quantum computing and advanced materials-related goods and technology to, or for the use in, russia, or to a person connected with russia (as well as related technical assistance, financial services, funds and brokering services); to prohibit the export, supply and delivery, making available and transfer of oil refining goods and technology (including oil catalysts) to, or for use in, russia, or to a person connected with russia (as well as, where appropriate, related technical assistance, financial services, funds and brokering services). to prohibit the export of export, supply, delivery, making available and transfer of certain luxury goods, to, or for use in, russia, or to a person connected with russia. 3 7.7 this instrument also amends the 2019 regulations to introduce a new prohibition on the import, acquisition, supply and delivery of certain iron and steel products originating in or consigned from russia. the purpose of this measure is to limit russia’s exporting capability in a major market. 7.8 the instrument also makes amendments to the 2019 regulations to provide for exceptions from these measures, licensing and enforcement, including the expansion of criminal offences. 59 notice nte 2022/14: introduction of additional sanctions against russia 14 april 2022 implemented under 2019 uk-russia regulations 14 april 2022 this notice is giving guidance on the new trade sanctions on russia by the newly issued russia (sanctions) (eu exit) (amendment) (no. 8) regulations 2022. see line 58. 60 notice 2953: russia import sanctions 14 april 2022 implemented under 2019 uk-russia regulations 14 april 2022 updated notice to provide an overview of the import prohibitions on certain goods imported into the uk and sets out the licensing process for traders looking to import goods subject to prohibitions 61 financial sanctions notice russia 21 april 2022 implemented under 2019 uk-russia regulations 21 april 2022 26 entries have been added to the consolidated list and are now subject to an asset freeze and 30 entries have been amended and are still subject to an asset freeze. 62 general licence: gazprombank energy payments general license int/2022/1630477 21 april 2022 implemented under 2019 uk-russia regulations 21 april 2022 under this general licence a person may continue to make payments to gazprombank or a subsidiary under a contract entered into prior to the date of this licence for the purpose of making gas available for use in the european union and a person, relevant institution, or gazprombank, or a subsidiary can carry out any activity reasonably necessary to effect this including the opening and closing of bank accounts. a person making payments under this licence must keep accurate, complete and readable records,on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years. 63 general licence - russian banks – uk subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments amended general license int/2022/1280876 22 april 2022 implemented under 2019 uk-russia regulations 22 april 2022 this general licence has been amended to also include sberbank cib (uk) ltd. 64 financial sanctions notice 26 april 2022 implemented under 2019 uk-russia regulations 22 april 2022 195 entries have been amended and 2 entries corrected under the russia financial sanctions regime and remain subject to an asset freeze. 65 general licence: law enforcement and regulatory authorities asset recovery general licence - int/2022/1679676 27 april 2022 implemented under 2019 uk-russia regulations 27 april 2022 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. 66 the russia (sanctions) (eu exit) (amendment) (no. 9) regulations 2022 29 april 2022 amends 2019 uk-russia regulations 29 april 2022 this instrument is made under the sanctions and anti-money laundering act 2018 (‘the sanctions act’) to make amendments to the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (‘the 2019 regulations’). these amendments will introduce new trade sanctions measures relating to internet services and online media services, for the purposes set out in regulation 4 of the 2019 regulations. this instrument amends part 5 (trade) of the 2019 regulations, which contains trade sanctions measures, and makes related consequential amendments. this instrument provides for a number of restrictions in the form of trade in services sanctions. it introduces requirements that: social media services, including video sharing platforms, must take reasonable steps to prevent content that is generated directly on the service, or uploaded to or shared on the service, by a designated person being encountered by a user of the service in the united kingdom. internet access services, including fixed and wireless broadband providers, must take reasonable steps to prevent users of the service in the united kingdom from accessing websites provided by a designated person. this will likely take the form of url blocking. application stores, including those on smartphones, must take reasonable steps to prevent users of the application store in the united kingdom from downloading or otherwise accessing an application provided by a designated person. the instrument confers powers on the secretary of state to designate persons to whom these online restrictions will apply. the instrument also confers on the office of communications (ofcom) the power to impose civil monetary penalties on a person who fails to comply with the new trade sanctions. failing to comply with the new sanctions is also a criminal offence. 67 financial sanctions notice 04 may 2022 implemented under 2019 uk-russia regulations 04 may 2022 63 entries have been added to the consolidated list and are now subject to an asset freeze. the following 2 entries have been amended and are still subject to an asset freeze: rossiya segodnya tv-novosti 68 general licence – continuation of business of evraz plc’s north american subsidiaries general licence - int/2022/1710676 05 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 05 may 2022 under general licence int/2022/1710676, a person may continue business operations involving the north american subsidiaries of evraz including but not limited to payments to or from the north american subsidiaries under any obligations or contracts; payments to or from any third party under any obligations or contracts; and receipt of payments made by the north american subsidiaries for audit services. evraz north america plc is also permitted to pay for the audit services referred to in the previous sentence. 69 financial sanctions notice 05 may 2022 implemented under 2019 uk-russia regulations 05 may 2022 the following entry has been added to the consolidated list and is now subject to an asset freeze: evraz plc 70 financial sanctions notice 09 may 2022 implemented under 2019 uk-russia regulations 09 may 2022 88 entries have been amended on the consolidated list and still subject to an asset freeze. 71 general licence – amsterdam trade bank n.v – winding down, basic needs and insolvency related payments general licence - int/2022/1678476 12 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 12 may 2022 under general licence int/2022/1678476, there are provisions relating to winding down, basic needs and insolvency related payments in connection with amsterdam trade bank n.v 72 financial sanctions notice 13 may 2022 implemented under 2019 uk-russia regulations 13 may 2022 12 entries have been added to the consolidated list and are now subject to an asset freeze. furthermore, 10 entries have been amended and remain subject to an asset freeze. 73 financial sanctions notice 19 may 2022 implemented under 2019 uk-russia regulations 19 may 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: jsc rossiya airlines jsc ural airlines pjsc aeroflot 74 general licence – russian travel 23 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 23 may 2022 under this licence, subject to the conditions below: a united kingdom person may purchase tickets from a designated person or any subsidiary for flights or rail journeys originating in, or within, russia. a united kingdom person, relevant institution or designated person may carry out any activity reasonably necessary to effect the purchase of tickets for flights or rail journeys in accordance with paragraph above. 75 financial sanctions notice 24 may 2022 implemented under 2019 uk-russia regulations 24 may 2022 63 entries have been amended and are still subject to an asset freeze. 76 financial sanctions notice belarus 27 may 2022 implemented under 2019 belarus (sanctions) (eu exit) regulations 27 may 2022 6 entries have been amended under the belarus regime and are still subject to an asset freeze. 77 financial sanctions notice russia 27 may 2022 implemented under 2019 uk-russia regulations 27 may 2022 299 entries have been amended under the russia regime and are still subject to an asset freeze. 78 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 may 2022 under general licence int/2022/1875276, business operations involving the provision of civilian telecommunication services that include zao transtelecom company, can continue subject to the conditions contained in the licence. the licence also permits business operations related to news media services to continue subject to certain conditions. 79 general licence – russia designated persons – charities and interim managers and trustees general licence - int/2022/1834876 30 may 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 may 2022 general licence – int/2022/1834876, allows for interim managers and trustees to act as receiver(s) and manager(s) in respect of the property and affairs of a charity, as specified in this general licence. the full details of the permissions and usage requirements can be found within the general licence, here and the publication notice here. 80 guidance trading under sanctions with russia 08 june 2022 implemented under 2019 uk-russia regulations 08 june 2022 this guidance is issued to advise what import and export restrictions apply due to sanctions for uk companies when trading with russia. 81 general licence – funds of non-designated third parties involving designated credit or financial institutions general licence - int/2022/1919908 10 june 2022 implemented under regulation 64 of 2019 uk-russia regulations 10 june 2022 under general licence int/2022/1919908: subject to the conditions set out in the licence a person may make use of the retail banking services of a designated credit or financial institution provided that the payments made or received are intended for the personal use of a person; during the period from the date of issue to the date of expiry (inclusive), a person may only make payments in accordance with paragraph 4.1 of the licence provided that the total value of such payments made by the person does not exceed £50,000; and a relevant institution may process payments made in accordance with the permissions above provided that the total value of such payments processed by that relevant institution during the period from the date of issue to the date of expiry (inclusive) in respect of a person does not exceed £50,000. reporting requirement - general licence int/2022/1919908 includes a reporting requirement that within 14 days of processing a payment in accordance with paragraphs 4.1 and 4.3 of the licence, a relevant institution must report to hm treasury, with details and supporting evidence of: the amount(s) processed; the payment route used; and the date on which the funds were processed. 82 guidance russia sanctions: notes on designations data 10 june 2022 implemented under 2019 uk-russia regulations 10 june 2022 this guidance note is published to explain how the uk government collates this data on designations and what it means. 83 financial sanctions notice 14 june 2022 implemented under 2019 uk-russia regulations 14 june 2022 39 entries have been amended to the consolidated list and are still subject to an asset freeze. further information can be found in the annex of the notice. 84 financial sanctions notice 16 june 2022 implemented under 2019 uk-russia regulations 16 june 2022 12 entries have been added to the consolidated list and are now subject to an asset freeze. further information can be found in the annex of the notice. 85 the russia (sanctions) (eu exit) (amendment) (no.10) regulations 2022 22 june 2022 amends 2019 uk-russia regulations 23 june 2022 the regulations and the notice 2022/18 adopted further trade sanctions, that include; prohibitions on the export, supply and delivery, making available and transfer (as well as related technical assistance, financial services, funds and brokering services) of: internal repression goods and technology goods and technology relating to chemical and biological weapons maritime goods and technology additional oil refining goods and technology additional critical industry goods and technology prohibitions on the export to, or for use in russia of jet fuel and fuel additives, as well as prohibitions on the making available, export, and supply, directly or indirectly, of such products to russia or for use in russia (as well as related technical assistance, financial services, funds, and brokering services). prohibitions on the export to, or for use in, russia, of sterling or eu denominated banknotes; as well as prohibitions on the making available, supply, or delivery of such banknotes to a person connected with russia; and on the making available of such banknotes for use in russia. some of the above prohibitions will relate to russia, and the non-government controlled ukraine territories. prohibitions on the import, acquisition or supply and delivery of revenue generating goods that originate in or are consigned from russia (as well as related technical assistance, financial services, funds, and brokering services. prohibitions on the provision of technical assistance, and financial services, funds, and brokering services relating to iron and steel imports. 86 financial sanctions notice 24 june 2022 implemented under 2019 uk-russia regulations 24 june 2022 58 entries have been amended and 1 entry corrected and remain subject to an asset freeze. further information can be found in the annex of the notice. 87 financial sanctions notice 29 june 2022 implemented under 2019 uk-russia regulations 29 june 2022 13 entries have been added and are now subject to an asset freeze. 1 entry has also been corrected under and remains subject to an asset freeze. 88 general licence – wind down of positions involving rosbank general licence - int/2022/1968500 30 june 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 june 2022 general licence int/2022/1968500 allows for a 30 day wind down period of positions involving rosbank pjsc (rosbank) or any entity owned or controlled by rosbank. 89 financial sanctions notice 4 july 2022 implemented under 2019 uk-russia regulations 4 july 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: aleyona anatolyevna chuguleva yuriy sergeyevich fedin darya aleksandrovna dugina yevgeniy eduardovich glotov aelita leonidovna mamakova mikhail anatolyevich sinelin united world international furthermore, 45 entries have been amended and 1 entry corrected under the russia regime. further information can be found in the annex to this notice. 90 general licence – financial services regarding wind down of derivatives, repurchase, and reverse repurchase transactions with the national bank of belarus, and ministry of finance of belarus. general licence - int/2022/1976232 5 july 2022 regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 ("the belarus regulations") 5 july 2022 this general licence allows a period of until 04 august 2022 for a person to provide financial services for the purpose of winding down any derivatives, repurchase, and reverse repurchase transactions entered into prior to 05 july 2022 involving: national bank of belarus (nbb); ministry of finance of belarus (mf); and those persons set out in regulation 15ca c to d of the belarus regulations. 91 general licence: transferable securities, money-market instruments, loans and credit arrangements general licence - int/2022/1976332 5 july 2022 regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 (the belarus regulations) 5 july 2022 this general licence allows for a 7-day wind down period in respect of, category c loans (as defined by regulation 15b (5)) as well as transferable securities and money market instruments (as defined by regulation 15a (2c)). 92 financial sanctions notice 5 july 2022 implemented under 2019 uk-russia regulations 5 july 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: denis yakovlevich gafner valeriya kalabayeva the following entries have been removed from the consolidated list and are no longer subject to an asset freeze: yakov vladimirovich rezantsev galina ulyutina the following entries have been amended and are still subject to an asset freeze: aleksandra aleksandrovna kamyshanova yevgeniya vitalyevna nezhdanova valeriy ivanovich pogrebenkov 93 financial sanctions notice belarus 7 july 2022 implemented under 2019 uk-belarus regulations 7 july 2022 the following entity has been amended under the belarus regime and remains subject to an asset freeze: llc synesis 94 general licence: humanitarian activity general licence - int/2022/1947936 7 july 2022 implemented under regulation 64 of 2019 uk-russia regulations 7 july 2022 under general licence int/2022/1947936 relevant persons seeking to undertake humanitarian activity in relation to the conflict in ukraine do not need to apply for individual licences from ofsi, but instead can rely on the permissions within this general licence. 95 financial sanctions notice 12 july 2022 implemented under 2019 uk-russia regulations 12 july 2022 16 entries have been amended and 2 entries corrected under the russia financial sanctions regime and remain subject to an asset freeze. 96 financial sanctions notice belarus 12 july 2022 implemented under 2019 uk-belarus regulations 12 july 2022 6 entries have been amended under the belarus financial sanctions regime and remain subject to an asset freeze. 97 financial sanctions notice 15 july 2022 implemented under 2019 uk-russia regulations 15 july 2022 the following entries have been removed from the consolidated list and are no longer subject to an asset freeze: didier casimiro zeljko runje the following entries have been amended under the russia regime and remain subject to an asset freeze: sergei ivanovich saenko vladimir leonidovich sivkovich oleg anatolyevich voloshyn alrosa 98 russia (sanctions) (eu exit) (amendment) (no. 11) regulations 2022 15 july 2022 amends 2019 uk-russia regulations 15 july 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) ("the 2019 regulations"). regulations 3 to 8 and 12(2) to (5) and (8) amend part 5 of the 2019 regulations relating to trade, and both amend existing schedules and insert new ones. new restrictions are imposed in relation to trade in: maritime goods and maritime technology in certain circumstances (regulation 5); military goods and technology with non-government controlled ukrainian territory (as specified in new chapter 2a of part 5); defence and security goods and technology (as specified in parts 2 to 4 of new schedule 3c); interception and monitoring services; banknotes; jet fuel and fuel additives (as specified in an addition to part 8 of schedule 2a); and goods which generate significant revenues for russia (as specified in new schedule 3d). as a result of those amendments: regulation 3 amends the definitions of"critical-industry goods","critical-industry technology","restricted goods" and"restricted technology" for the purposes of part 5 of the 2019 regulations; regulation 7 inserts additional prohibitions in chapter 4c of part 5 of the 2019 regulations relating to trade in ancillary services relating to iron and steel goods and makes consequential amendments; regulation 9 extends prohibitions in part 5 of the 2019 regulations in relation to trade in certain items with non-government controlled ukrainian territory; regulation 12(6) adds further things to the list of oil and refining goods and technology in schedule 2d and regulation 12(7) adds further things to the list of energy-related goods in schedule 3 in respect of which trade is prohibited. regulation 10 amends part 7 of the 2019 regulations to create exceptions to some of the new prohibitions. regulation 11 makes consequential amendments in relation to offences. regulation 13 revokes the russia (sanctions) (eu exit) (amendment) (no. 10) regulations 2022 (s.i. 2022/689). 99 the russia (sanctions) (eu exit) (amendment) (no. 12) regulations 2022 19 july 2022 amends 2019 uk-russia regulations 19 july 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) ("the 2019 regulations"). these regulations add new financial sanctions to part 3 (finance) of the 2019 regulations. the amendments insert restrictions regarding investments (and services directly related to those investments) in respect of land located in russia, persons connected with russia, relevant entities, joint ventures, opening a representative office or establishing a branch or subsidiary located in russia. these regulations provide for exceptions to, and licensing powers in relation to, these new provisions. 100 general licence – investments in relation to russia general licence - int/2022/2002560 19 july 2022 implemented under regulation 64 of 2019 uk-russia regulations 19 july 2022 this general licence int/2022/2002560 allows for a 7-day wind down period in respect of the outward investment ban outlined in the amendment 12 regulations. this licence takes effect from 19 july 2022 and expires on 26 july 2022. 101 the russia (sanctions) (eu exit) (amendment) (no. 13) regulations 2022 18 july 2022 amends 2019 uk-russia regulations 18 july 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c.13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) ("the 2019 regulations"). part 2 makes amendments to the designation criteria in regulation 6 of the 2019 regulations: first, to specify additional activities for which a person may be designated; second, to make minor amendments to the definition of"being involved in obtaining a benefit from or supporting the government of russia"; and third, to broaden the interpretation of being"associated with" a designated person. part 3 provides for a new exception from trade sanctions measures for humanitarian assistance activity in non-government controlled areas of the donetsk and luhansk oblasts. part 4 makes provision to correct or resolve a number of issues arising from the 2019 regulations or amendments made to them: first, to expand upon the definition of ownership in relation to ships and aircraft; and second, to correct drafting errors or omissions in regulations 76, 78 and 94. 102 russia guidance updated 19 july 2022 implements under 2019 uk-russia regulations 19 july 2022 the guidance has a new section on investments in russia on page 5 to 6. it also updates the faqs section on page 8 to 11 to reflect the russia financial sanctions that have come into force since the russian invasion of ukraine. 103 the sanctions (eu exit) (miscellaneous amendments) regulations 2022 and the sanctions (eu exit) (miscellaneous amendments) (no.2) regulations 2022 19 july 2022 30 august 2022 these regulations extend the definition of ‘relevant firms’ that have financial sanctions reporting obligations to include cryptoasset exchange providers and custodian wallet providers. there is a requirement for 'relevant firms', as defined in sanctions regulations, to notify ofsi of certain information as soon as practicable when encountering a designated person in the course of their business. this requirement applies to relevant firms in the uk or under uk jurisdiction including people working for them. chapter 5 of ofsi's general guidance covers reporting obligations. for further information on reporting obligations, including how to report to ofsi can be found here. 104 financial sanctions notice 20 july 2022 implemented under 2019 uk-russia regulations 20 july 2022 the following entries have been amended under the russia regime and remain subject to an asset freeze: irina sergeyevna bubnova sergei sergeivich ivanov natalya petrovna skorokhodova djeco group lp majory llp photon pro llp 105 the russia (sanctions) (eu exit) (amendment) (no. 14) regulations 2022 21 july 2022 amends 2019 uk-russia regulations 21 july 2022 these regulations amend part 5 of the 2019 regulations, on trade, and insert related schedules. new restrictions are imposed in relation to trade in: professional and business services (as specified in new regulation 54b); miscellaneous essential goods required for the functioning of the russian economy (as specified in new schedule 3e); oil and oil products means (as specified in new schedule 3f); gold (as specified in new schedule 3g); coal and coal products (as specified in new schedule 3h). the goods specified in new schedules 3e, 3f, 3g and 3h are specified by reference to commodity codes which are set out in the tariff of the united kingdom. provision in also made in relation to energy related goods, supplementing existing provision in chapter 4 of part 5. provision is also made in relation to the giving of technical assistance to certain aircraft situated at uk airports. the remainder of the provisions in these regulations relate to trade exceptions and enforcement. 106 general licence: payment to uk insurance companies for building and engineering insurance 22 july 2022 russia (sanctions) (eu exit) regulations 2019 regulations 11 to 15 22 july 2022 under the general licence, individuals or entities designated under the uk sanctions regimes are permitted to make payments to uk insurers for insurance premiums and broker commissions relating to the provision of building and engineering insurance cover provided to uk properties. the licence also permits uk insurers to make payments to uk designated persons due as a result of a successful claim made against an insurance policy provided by the uk insurer or refunds due as a result of any over payments made pursuant to this licence. the general licence is applicable across multiple regimes. these are detailed in annex 1. 107 financial sanctions notice 26 july 2022 implemented under 2019 uk-russia regulations 26 july 2022 42 entries have been added to the consolidated list and are now subject to an asset freeze. further information can be found in the annex to this notice. the following entry has been corrected on the consolidated list and remains subject to an asset freeze: vadim anatolyevich lukashevich 108 general licence – wind down of positions involving rosbank general licence - int/2022/1968500 30 july 2022 implemented under regulation 64 of 2019 uk-russia regulations 30 july 2022 general licence int/2022/1968500 extended for a period of 2 months to the 30 september, allowing for the winding down of positions involving rosbank. 109 financial sanctions notice 2 august 2022 implemented under 2019 uk-russia regulations 2 august 2022 the following entries have been added to the russia regime and are now subject to an asset freeze: didier casimiro zeljko runje the following entry has been removed under the russia regime and is no longer subject to an asset freeze: olga ayziman 18 entries have been amended and are still subject to an asset freeze. further information can be found in the annex to this notice. 110 financial sanctions notice 9 august 2022 implemented under 2019 uk-russia regulations 9 august 2022 27 entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze. further information can be found in the annex to this notice. 111 general licence – mongolia energy payments general licence - int/2022/2085212 15 august 2022 implemented under regulation 64 of 2019 uk-russia regulations 15 august 2022 general licence int/2022/2085212 issued under the russia sanctions regulations allowing payments to sanctioned russia banks for the purpose of making energy available for use in mongolia. under this general licence a person may continue to make payments to certain sanctioned banks and subsidiaries for the purpose of making energy available for use in mongolia, and a person, relevant institution, sanctioned bank or subsidiary can carry out any activity reasonably necessary to effect this. 112 general licence: permitted payments to uk insurance companies general licence - int/2022/2009156 22 july 2022 amended 17 august 2022 uk autonomous sanctions regulations 22 july 2022 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. general licence int 2022/2009156 has been amended to include within permitted payments: terrorism insurance property owners' liability insurance claims preparation insurance this licence took effect on 22 july 2022, has been amended 17 august 2022 and is of indefinite duration. 113 general licence – continuation of business of evraz plc’s north american subsidiaries 5 may 2022 amended 18 august 2022. implemented under regulation 64 of 2019 uk-russia regulations 5 may 2022 this general license allows the continued business operations of evraz' north american subsidiaries. 114 general licence: crown servants, contractors, & their family members general licence - int/2022/1845976 19 august 2022 implemented under regulation 64 of 2019 uk-russia regulations 19 august 2022 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. 115 general licence – bank fees general licence - int/2022/2104808 22 august 2022 implemented under regulation 64 of 2019 uk-russia regulations 22 august 2022 under general licence int/2022/2104808, a bank is allowed to take payment of bank fees from frozen accounts. this licence takes effect from 22 august 2022 and is of indefinite duration. 116 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments general licence - int/2022/1280876 01 march 2022 amended on 22 august 2022. implemented under regulation 64 of 2019 uk-russia regulations 01 march 2022 ofsi has 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. 117 financial sanctions notice 23 august 2022 implemented under 2019 uk-russia regulations 23 august 2022 42 entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze. . further information can be found in the annex to this notice. the following entry has been removed from the russia regime and is no longer subject to an asset freeze: mikhail vladimirovic razvozhayev 118 financial sanctions notice 16 september 2022 implemented under 2019 uk-russia regulations 16 september 2022 1 entry has been added to and 3 entries removed from the russia financial sanctions regime. further information can be found in the annex to this notice. 119 russia guidance 21 september 2022 russia (sanctions) (eu exit) regulations 2019 21 september 2022 ofsi has updated its russia guidance adding 3 new questions. questions 24 to 26 further clarify how to use the food security licensing provision in the russia (sanctions) (eu exit) regulations 2019, particularly with regard to providing insurance. 120 financial sanctions notice 26 september 2022 implemented under 2019 uk-russia regulations 26 september 2022 92 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. 3 entries have been amended and 1 entry corrected under the russia financial sanctions regime and remain subject to an asset freeze. further information can be found in the annex to this notice. 121 financial sanctions notice 30 september 2022 implemented under 2019 uk-russia regulations 30 september 2022 the following entry has been added to the consolidated list and is now subject to an asset freeze: elvira sakhipzadovna nabiullina the following entries have been corrected and are still subject to an asset freeze: alexey ivanovich isaykin alexander dmitrievich kharichev 122 financial sanctions notice 4 october 2022 implemented under 2019 uk-russia regulations 4 october 2022 the following entry has been added to the russia regime and is now subject to an asset freeze: sergei vladimirovich yeliseyev 123 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments general licence - int/2022/1280876 6 october 2022 implemented under regulation 64 of 2019 uk-russia regulations 6 october 2022 general licence int/2022/1280876 was further amended to include payments related to insolvency proceedings under the german banking act. 124 general licence – london court of international arbitration (lcia) arbitration costs general licence - int/2022/1552576 17 october 2022 implemented under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 and under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 17 october 2022 under general licence int/2022/1552576, designated persons (dps), companies controlled by dps or their legal representatives are allowed to make payments to the london court of international arbitration (lcia) to cover their arbitration costs. general licence int/2022/1552576 also permits the lcia to direct and receive such payments to use them to pay for arbitration costs and relevant institutions to process those payments. this licence takes effect from 17 october 2022 and is of indefinite duration. 125 financial sanctions notice 20 october 2022 implemented under 2019 uk-russia regulations 20 october 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: saeed aghajani mohammad bagheri seyed hojjatollah qureishi shahed aviation industries the following entry has been amended on the consolidated list and remains subject to an asset freeze: oleksandr saulenko 126 general licence: loans and securities amendment general licence - int/2022/2307324 28 october 2022 implemented under regulation 64 of 2019 uk-russia regulations 28 october 2022 general licence int/2022/2307324 is a 7-day wind down licence, which will allow the granting of category 5 loans until 23:59 on 5 november. 127 general licence: securing energy for europe general licence - int/2022/ 2305324 28 october 2022 implemented under regulation 64 of 2019 uk-russia regulations 28 october 2022 under general licence int/2022/2305324, persons may grant category 5 loans to saving energy for europe gmbh, otherwise known as gazprom germania, and its subsidiaries, including sefe marketing & trading limited and sefe energy limited. this licence takes effect from 23:59 on 28 october 2022 and expires on 29 october 2023. when assessing the potential for renewal of general licence int/2022/2305324 ofsi will consider the potential implications of this decision for the uk’s energy security. 128 ofsi issues a legal fees general licence general licence - int/2022/2252300 28 october 2022 implemented under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 and under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 28 october 2022 under general licence int/2022/2252300, provided that one of the sets of conditions in one of parts a or b of the general licence are complied with in full, any person or relevant institution may receive payments from a dp; make payments (directly or indirectly) for or on behalf of a dp; make payments for the benefit of a dp; process payments which relate to a dp; and any person or relevant institution may carry out any other act which is reasonably necessary to give effect to this. any activity conducted under general licence int/2022/2252300 must be reported to hm treasury within 7 days, with the details and supporting evidence requested in part a or part b. the reporting forms referenced at 9.4 of part a and 11.5 of part b of general licence int/2022/2252300 may be downloaded from the ofsi website here. 129 the russia (sanctions) (eu exit) (amendment) (no. 15) regulations 2022 russia sanctions - guidance 28 october 2022 amends 2019 uk-russia regulations 28 october 2022 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855). regulation 3 prohibits the making of a new category of loan to certain persons and regulation 7 makes a consequential amendment enabling an exception from that prohibition. regulation 4 inserts and amends definitions relating to the new and revised trade prohibitions. regulation 5 creates new trade prohibitions in the 2019 regulations relating to gold jewellery and to certain processed gold. regulation 8(2) and (3) creates exceptions to those prohibitions. regulations 9 and 10 make consequential amendments and regulation 11(9) amends the list of gold and gold products in order to define the items for which trade in gold jewellery is prohibited. regulation 6 makes provision concerning the prohibition of imports of liquefied natural gas and the export of russia’s vulnerable goods (set out in regulation 11(10) and schedule 2) to russia. regulation 8(4) prescribes an exception to the russia’s vulnerable goods prohibition. regulation 11(2) to (4) makes minor clarificatory amendments to the lists of critical-industry goods and critical-industry technology. regulation 11(5) adds items to the list of oil refining goods and technology and regulation 12(7) adds items to the list of revenue generating goods. regulation 11(6) makes a minor clarificatory amendment to the list of quantum computing and advanced materials goods and technology. regulation 11(8) and schedule 1 insert additional goods as g7 dependency and further goods. regulation 12 and schedule 3 correct errors made in previous regulations amending the 2019 regulations. 130 financial sanctions notice 2 november 2022 amends 2019 uk-russia regulations 2 november 2022 the following entries have been added to the consolidated list and are now subject to an asset freeze: alexander grigoryevich abramov alexander vladimirovich frolov airat mintimerovich shaimiev albert kashafovich shigabutdinov 3 entries have also been amended under the russia regime and remain subject to an asset freeze. further information can be found in the notice, here. 131 general licence – truphone general licence - int/2022/2339452 2 november 2022 implemented under regulation 64 of 2019 uk-russia regulations 2 november 2022 general licence int/2022/2339452. this allows truphone limited to continue to make or receive payments for the purposes of continuing to provide telecommunication services. further information can be found in the notice, here. 132 general licence – transactions related to agricultural commodities including the provision of insurance and other services general licence - int/2022/2349952 4 november 2022 implemented under regulation 64 of 2019 uk-russia regulations 4 november 2022 general licence int/2022/2349952 issued to allow, subject to certain conditions, transactions related to agricultural commodities including the provision of insurance and other services. 133 the russia (sanctions) (eu exit) (amendment) (no. 16) regulations 2022 explanatory memorandum 4 november 2022 amends 2019 uk-russia regulations 5 december 2022 these amendments will apply to a uk person anywhere in the world or any person in the uk and uk territorial waters (henceforth “affected persons”). the amendments will ban the supply or delivery by ship of 2709 and 2710 oil and oil products from a place in russia to a third country, or from one third country to another third country, as well as the provision of related ancillary services (including brokering services and financial assistance).1 2 the purpose of the amendments will be to encourage russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine, as stated in regulation 4 of the 2019 regulations. 134 the russia (sanctions) (overseas territories) (amendment) (no. 3) order 2022 10 november 2022 russia (sanctions) (overseas territories) order 2020 10 november 2022 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (the principal order). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the russia sanctions regulations) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have been recently amended by the russia (sanctions) (eu exit) (amendment) (no. 11) regulations 2022 (s.i. 2022/792), the russia (sanctions) (eu exit) (amendment) (no. 12) regulations 2022 (s.i. 2022/801), the russia (sanctions) (eu exit) (amendment) (no. 13) regulations 2022 (s.i. 2022/814) and the russia (sanctions) (eu exit) (amendment) (no. 14) regulations 2022 (s.i. 2022/850) (the amending regulations). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations. 135 financial sanctions notice 11 november 2022 amends 2019 uk-russia regulations 11 november 2022 one entry has been amended and is still subject to an asset freeze: eugene markovich shvidler. further information can be found in the notice, here. 136 general licence – truphone general licence - int/2022/2339452 2 november 2022 amended 17 november 2022. implemented under regulation 64 of 2019 uk-russia regulations 17 november 2022 ofsi has also amended general licence int/2022/2339452 for truphone telecommunications services. details of the amendments can be found in the publication notice. 137 general licence: payment to energy companies for gas and/or electricity general licence - int/2022/2300292 17 november 2022 this licence is granted under all uk autonomous sanctions regulations listed in annex i of this licence 17 november 2022 ofsi issued general licence int/2022/2300292 under all uk autonomous sanctions regulations (see annex 1 of the general licence for the list of relevant regulations) which allows for payment to utility companies for gas and electricity by uk designated persons who own or rent properties in the uk. 138 financial sanctions notice 30 november 2022 amends 2019 uk-russia regulations 30 november 2022 22 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. further information can be found in the annex to this notice, here. 139 general licence – oil price cap general licence - int/2022/2469656 4 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 4 december 2022 oil services ban and price cap information. 140 general licence – winddown general licence - int/2022/2470256 4 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 4 december 2022 oil services ban and price cap information. 141 general licence – correspondent banking and payment processing general licence - int/2022/2470056 5 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 5 december 2022 oil services ban and price cap information. further information can be found here. 142 general licence – oil price cap: exempt projects and countries 5 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 5 december 2022 oil services ban and price cap information. further information can be found here. 143 uk maritime services prohibition and oil price cap guidance 5 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 5 december 2022 guidance for the uk ban on the provision of maritime transportation of, and associated services for the maritime transportation of, certain russian oil and oil products. further information and reporting forms issued can be found here. 144 financial sanctions notice 9 december 2022 amends 2019 uk-russia regulations 9 december 2022 the following entry has been added to the consolidated list and is now subject to an asset freeze: ramil rakhmatulovich ibatullin the following entries have been corrected and are still subject to an asset freeze: maxim alexandrovich loktev igor anatolievich yegorov denis valentinovich manturov 145 financial sanctions notice 13 december 2022 amends 2019 uk-russia regulations 13 december 2022 16 entries have been added and 1 entry amended to the consolidated list and are subject to an asset freeze. further information can be found in the annex to this notice, here. 146 general licence: trade 5 - financial prohibitions - 7 day winddown general licence - int/2022/2448692 15 december 2022 implemented under regulation 64 of 2019 uk-russia regulations 15 december 2022 general licence int/2022/2448692 allows for a 7 day wind down period in respect to financial prohibitions in regulations 16, 17 and 18b of the russia regulations. the general licence takes effect from 00:01 on 16 december 2022 and expires at 23:59 on 22 december 2022. 147 russia (sanctions) (eu exit) (amendment) (no. 17) regulations 2022 16 december 2022 amends 2019 uk-russia regulations 16 december 2022 the russia (sanctions) (eu exit) (amendment) (no. 17) regulations 2022 prohibit the provision of trust services: to or for the benefit of a person connected with russia unless pursuant to an ongoing arrangement pursuant to which that person provided those services to or for the benefit of the person connected with russia immediately prior to 16 december 2022 to or for the benefit of a person designated for the purposes of regulation 18c (trust services) amendments have also been made to restrictions on transferable securities and money-market instruments, loan and credit arrangements, and investments in russia. these amendments have been designed to prohibit new investments in russia via third countries. ofsi has updated its russia guidance to reflect these measures. 148 general licence – oil price cap general licence - int/2022/2469656 4 december 2022 amended on 3 february 2023. implemented under regulation 64 of 2019 uk-russia regulations 3 february 2023 the uk, in partnership with the g7 countries, australia and the european union, has already implemented a price cap on russian crude oil trade by firms shipping oil to third countries. this cap was set at usd$60 per barrel, and came into effect on 5 december 2022. it was also agreed that a price cap would come into effect for russian refined oil products from 5 february 2023, and the uk and its price cap coalition partners have agreed that this cap will be determined by categorisation of refined oil products as follows: products categorised as ‘premium to crude’ will be subject to the premium to crude price cap. all other products are categorised as ‘discount to crude’ and will be subject to the discount to crude price cap review. as with the 5 december oil price cap, ofsi has issued a general licence to implement the caps for oil products. as with the existing price cap for oil, the level of both caps will be kept under review. 149 general licence – refined oil products winddown general licence - int/2023/2660772 3 february 2023 implemented under regulation 64 of 2019 uk-russia regulations 3 february 2023 ofsi has issued a further wind-down general licence for oil products. this will permit contracts to ship russian oil products traded at a price above the relevant cap where the products were loaded before 5 february 2023, and are unloaded at the destination port by 1 april 2023. 150 uk maritime services prohibition and oil price cap industry guidance 5 february 2023 amends 2019 uk-russia regulations 5 february 2023 ofsi has released updated guidance on the maritime services prohibition and the oil price cap, which provides full detail of the implementation of the price caps, ofsi’s approach to enforcement, and the requirements on involved persons. this has been reviewed and updated to reflect requests for clarification and additional details for refined oil products. bespoke forms for required reporting, reporting suspected breaches, and specific license applications are available here. hm treasury will organise teach-ins for interested stakeholders over the next few weeks. 151 financial sanctions notice 8 february 2023 amends 2019 uk-russia regulations 8 february 2023 8 individuals and 7 entities have been added to the russia financial sanctions regime and are now subject to an asset freeze. further information can be found in the annex to this notice. 152 financial sanctions notice 24 february 2023 amends 2019 uk-russia regulations 24 february 2023 92 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. furthermore, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: nigina zairova further information can be found in the annex to this notice. 153 financial sanctions notice 10 march 2023 amends 2019 uk-russia regulations 10 march 2023 the following entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze: oleg nikolaevich evtushenko vitaly anatolyvich markelov yuri alexandrovich olenin roman pakhomov andrei yuvenalyevich petrov alexander sergeevich prokopiev ilya vasilevich rebrov furthermore, 14 entries have also been corrected under the russia regime and remain subject to an asset freeze. the relevant notice can be found here. 154 financial sanctions notice 17 march 2023 amends 2019 uk-russia regulations 17 march 2023 the following entry has been amended under the russia regime and remains subject to an asset freeze: igor viktorovich makarov the following entry has been removed from the russia regime and is no longer subject to an asset freeze: brian mcdonald furthermore, the following duplicate entry has been removed from the russia regime and remains subject to an asset freeze under the belarus regime: minsk wheel tractor plant further information can be found in the annex to this notice, here. 155 general licence – publication notice – trust services sanctions general licence - int/2023/2589788 21 march 2023 amends 2019 uk-russia regulations 21 march 2023 ofsi has issued general licence int/2023/2589788 under regulation 64 of the russia (sanctions) (eu exit) regulations 2019. under this general licence, persons may wind down the provision of trust services to a designated person. the permissions under this general licence apply to persons from the date of designation and will expire at 23:59 on the 90th calendar day from taking effect for the purposes of regulation 18c. note that the expiry date will differ depending on the date for each designation. it may be varied, revoked, or suspended by hm treasury at any time. any persons intending to use the general licence should first consult the copy of the licence and refer to ofsi’s general guidance. persons using the general licence must report to ofsi within 30 calendar days of undertaking any activity. the relevant reporting form can be found here. ofsi has also published a blog and updated its russia guidance to include further information on prohibitions on trust services. 156 financial sanctions notice 22 march 2023 amends 2019 uk-russia regulations 22 march 2023 all persons currently designated under the russia regime (1,730 entries) have been amended on the consolidated list and are now subject to trust services sanctions. 7 entries have also been updated to reflect existing further restrictions. the 'other information' field for all entries has been amended to provide details of further financial restrictions, and the date trust services sanctions were imposed. all entries remain subject to an asset freeze and no further changes have been made to the consolidated list. further details can be found in the notice. 157 financial sanctions notice 22 march 2023 amends 2019 uk-russia regulations 22 march 2023 the following duplicate entry has been removed from the consolidated list. the original entry (sergei borisovich korolyov) remains on the consolidated list under the russia regime and the individual is still subject to an asset freeze: sergey borisovich korolev the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: alexey viktorovich kuzmichev 158 general licence – bond amendments and restructurings for non-designated persons general licence - int/2023/2824812 28 march 2023 implemented under regulation 64 of 2019 uk-russia regulations 28 march 2023 on 28 march 2023, ofsi issued general licence int/2023/2824812 under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 (“the russia regulations”) to allow, subject to certain conditions, transactions related to bond amendments and restructurings for non-designated persons. further details can be found in the general licence, here. 159 financial sanctions notice 12 april 2023 amends 2019 uk-russia regulations 12 april 2023 14 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze. furthermore, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze: nikolay ivanovich bortsov. ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice here. 160 financial sanctions notice 13 april 2023 amends 2019 uk-russia regulations 13 april 2023 the following entries has been amended under the russia financial sanctions regime and remain subject to an asset freeze: tatiana vladimirovna evtushenkova felix vladimirovich natalia nikolayevna evtushenkova nariman gadzhievich gadzhiev ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice here. 161 financial sanctions notice 21 april 2023 amends 2019 uk-russia regulations 21 april 2023 the following entries have been added to the consolidated list under the russia financial sanctions regimes and are now subject to an asset freeze. andrey andreevich zadachin denis vladmirovich kolesnikov elena anatolievna lenskaya ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice, here. 162 the russia (sanctions) (eu exit) (amendment) regulations 2023 statutory instruments 2023 no. 440 - sanctions 21 april 2023 amends 2019 uk-russia regulations 21 april 2023 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations). regulations 3 to 8 amend part 5 (which makes provision in respect of trade) of the 2019 regulations. regulation 3 specifically inserts a new chapter 4ca which makes specific provision prohibiting the importation of iron and steel products, containing iron or steel originating in russia, that have been processed in a third-country. regulation 4 amends chapter 4g which makes provision for revenue generating goods. in doing so, it recasts the former schedule 3d, and makes consequential amendments to regulations 46r to 46x. regulation 5 inserts a new chapter 4ga which also makes provision in respect of revenue generating goods and introduces a new schedule 3da which specifies certain revenue generating goods. no good appears in both schedule 3d and schedule 3da. regulation 6 makes remedial amendments to chapter 4i which relates to oil and oil products. regulations 7 and 8 make similar provision in relation to gold (chapter 4j) and coal and coal products (chapter 4k) respectively. regulation 9, 10 and 11 amend part 7 (which makes provision for exceptions and licences) of the 2019 regulations. the amendments include provision relating to the acquisition of otherwise prohibited goods for the purpose of the function of a united kingdom diplomatic mission in russia, and the acquisition of certain goods by united kingdom nationals situated in russia for use in russia. regulations 12 and 13 make provision in relation to enforcement of the 2019 regulations. the remainder of the regulations amend certain schedules to the 2019 regulations, some of which changes are remedial, whilst others, such as the insertion of schedule 3da, are entirely new. 163 general licence - legal services general licence - int/2023/2954852 28 april 2023 implemented under regulation 64 of 2019 uk-russia regulations 28 april 2023 on friday 28 april 2023, general licence int/2022/2252300 expired. at 00:01 hours on saturday 29 april 2023, a new general licence was issued covering legal services - general licence int/2023/2954852 (the general licence). the general licence and its reporting forms can be found here on gov.uk. those intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements as these do not mirror those of general licence int/2022/2252300. to accompany this update, ofsi has published a blog detailing the amendments to the general licence. the blog can be found here on gov.uk. 164 general licence – continuation of business of evraz plc’s north american subsidiaries general licence - int/2022/1710676 4 may 2023 implemented under regulation 64 of 2019 uk-russia regulations 4 may 2023 general licence int/2022/1710676 has been amended. the definition of the “north american subsidiaries” has been amended to clarify that the subsidiary companies of evraz north america plc, evraz inc. na and evraz inc. na – canada are covered by general licence int/2022/1710676. 165 ofsi licensing: travel guidance guidance on travel allowance for licence applications 12 may 2023 implemented under 2019 uk-russia regulations 12 may 2023 ofsi has published a new guidance to applicants of licences to release frozen funds for travel and associated expenses. it provides guidance on ofsi’s expected standard of reasonableness regarding the use of funds and economic resources for travel and expenses. 166 financial sanctions notice 16 may 2023 amends 2019 uk-russia regulations 16 may 2023 the following entry has been amended under the russia financial sanctions regime: roman nikolaevich lepa ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further details can be found in the notice here. 167 financial sanctions notice 19 may 2023 amends 2019 uk-russia regulations 19 may 2023 86 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust service sanctions. the following entries have been removed from the consolidated list and are no longer subject to an asset freeze or trust services sanctions: nikolay yurievi petrunin kyrylo sergiyovich stremousov vladimir nikolayevich sungorkin further details can be found in the notice here. 168 financial sanctions notice 22 may 2023 amends 2019 uk-russia regulations 22 may 2023 the following entries have been amended and are still subject to an asset freeze and trust services sanctions: ilya iosifovich klebanov valery pavlinovich shantsev afk sistema the non-latin script language for the following entry has been updated. no material changes have been made to the consolidated list in html/pdf format: vladimir nikolaevich lepin further details can be found in the notice, here. 169 general licence – prior obligations general licence - int/2023/3024200 22 may 2023 implemented under regulation 64 of 2019 uk-russia regulations 22 may 2023 ofsi has issued a new general licence to enable the payment of funds or economic resources from a designated person to a uk person to satisfy contractual obligations that arose pre-designation. the general licence and its reporting forms can be found here. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. 170 general licence – london court of international arbitration (lcia) arbitration costs general licence - int/2022/1552576 5 june 2023 implemented under regulation 32 of the uk - belarus regulations of 2019 and regulation 64 of the 2019 uk-russia regulations 5 june 2023 general licence int/2022/1552576 was amended to allow: designated person (dp) representatives to pay funds to the london court of international arbitration (lcia) to cover arbitration costs (dp representative is a non-dp who is a party to an lcia arbitral proceedings, and acts in lieu of, or for the benefit of a dp) dps or dp representatives to transfer funds to their legal representatives for onward payment to the lcia to cover arbitration costs non-dp arbitral parties to pay substitute deposit(s) to the lcia 171 general licence – transactions related to agricultural commodities including the provision of insurance and other services general licence - int/2022/2349952 6 june 2023 implemented under regulation 64 of 2019 uk-russia regulations 6 june 2023 general licence int/2022/2349952 was amended to allow the grain and feed trade association (gafta) to receive funds and economic resources from any person, including designated persons, in connection with the direct and indirect provision of services related to contracts for the trade in agricultural commodities, by or on behalf of gafta. 172 republic of belarus (sanctions) (eu exit) (amendment) regulations 2023 9 june 2023 amending the republic of belarus (sanctions) (eu exit) regulations 2019 9 june 2023 the 2019 belarus regulations are being amended in june 2023 to target exports from belarus that fund lukashenko’s regime and to target the circumvention of sanctions against russia. the belarusian regime continues to openly facilitate russia’s illegal invasion of ukraine. belarus also continues to provide diplomatic support to russia and their economies are closely integrated. the measures imposed and amended by the amendment regulations include the following: changes to designation criteria. this will allow the fcdo to more effectively target persons that are involved in supporting russia’s invasion of ukraine. this includes persons with the ability to nominate, appoint or remove a director or members of management and supervisory bodies of relevant entities and persons that work for, or are affiliated to, belarusian authorities. amendments to the dealing with transferable securities or money market instruments measure. new measures relating to internet services and social media. the prohibition of exports of machinery; banknotes; and precursor materials for chemical and biological weapons and technology. the prohibition of imports of cement, rubber, wood and gold. a ban on ancillary services for all prohibited goods, including technical assistance and financial and brokering services. these further sanctions align with hmg’s strategic approach in response to russia’s illegal invasion of ukraine by deterring the belarusian regime from supporting or enabling russian actions that are destabilising ukraine and demonstrating that the uk strongly condemns belarus’ role in facilitating russia’s invasion of ukraine. the press release can be accessed here. 173 the now-revoked general license - int/2022/2305324 14 june 2023 revoking the general licence implemented under regulation 64 of the 2019 uk-russia regulations 14 june 2023 on 14 june 2023, the securing energy for europe general licence (gl) int/2022/2305324 was revoked. the nationalisation of gazprom germania (renamed securing energy for europe) means that gazprom’s uk subsidiaries are no longer in scope of the credit restrictions originally introduced by the russia (sanctions) (eu exit) (amendment) (no. 15) regulations 2022, which this gl was designed to lift. ofsi no longer considers there to be a need for this gl. 174 general licence – oil price cap: trading in derivatives and futures general licence - int/2023/3074680 14 june 2023 implemented under regulation 64 of 2019 uk-russia regulations 14 june 2023 ofsi issued general licence int/2023/3074680. this general licence permits trading in derivatives and futures related to the supply or delivery by ship of russian oil and oil products which would otherwise breach the prohibition in regulation 46z9c of the russia regulations. 175 updated guidance for the maritime services ban and oil price cap 14 june 2023 implemented under regulation 64 of 2019 uk-russia regulations 14 june 2023 osfi published updated guidance for the maritime services ban and oil price cap, to provide additional clarity and detail on the following: wind-down periods: we are confirming that ofsi will introduce a 45-day wind-down period for any future changes to the oil price cap trading in derivatives and futures: trading in derivatives and futures is now exempt from the oil price cap “as soon as reasonably practicable”: clarification has been added on ofsi’s view of what is considered to be taking the required steps to withdraw contracted services “as soon as reasonably practicable” in the event of a suspected breach. bespoke reporting forms for required reporting, reporting suspected breaches, and specific licence applications can be found here. any reporting or queries should be directed to oilpricecap.ofsi@hmtreasury.gov.uk. 176 the russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2023 no. 665 19 june 2023 amendments to the 2019 uk-russia regulations 20 june 2023 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) (the act) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations) (as amended). under section 1 of the act, the secretary of state may make sanctions regulations for a purpose within subsection (2). in addition to the current purpose stated in regulation 4 (encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine), the secretary of state considers that the 2019 regulations are also appropriate for promoting the payment of compensation by russia for losses suffered by ukraine as a result of russia’s full-scale invasion of ukraine on or after 24 february 2022. regulation 4 of the 2019 regulations is amended to refer to this additional purpose. regulation 3 removes the existing definition of non-government controlled areas of the donetsk and luhansk oblasts, and substitutes a new definition of non-government controlled ukrainian territory which includes also the additional territory of non-government controlled areas of the kherson and zaporizhzhia oblasts of ukraine. the expanded definition has the effect of extending existing finance, shipping and trade sanctions relating to the autonomous republic of crimea and city of sevastopol (crimea) and non-government controlled areas of the donetsk and luhansk oblasts, and relevant exceptions, to non-government controlled areas of the kherson and zaporizhzhia oblasts. the regulations also introduce a defence to the strict liability offence under section 68(1) of the customs and excise management act 1979 relating to the prohibition on exportation of certain goods to, or for use in, non-government controlled areas of the donetsk, kherson, luhansk and zaporizhzhia oblasts. 177 general licence: humanitarian activity general licence - int/2022/1947936 20 june 2023 implemented under regulation 64 of the 2019 uk-russia regulations 20 june 2023 general licence int/2022/1947936 was amended to update: the definition of non-government controlled ukrainian territory to capture kherson and zaporizhzhia oblasts update annex i of designated financial institutions to capture financial institutions designated since 7 july 2022 178 financial sanctions notice 23 june 2023 amends the 2019 uk-russia regulations 23 june 2023 on 23 june 2023 the following entries have been amended and are still subject to an asset freeze and trust services sanctions: demetris ioannides galina evgenyevna pumpyanskaya dmitry alexandrovich pumpyansky ofsi’s consolidated list of asset freeze targets has been updated to reflect this change. 179 general licence – continuation of business of evraz plc’s north american subsidiaries general licence - int/2022/1710676 5 may 2022 and amended 26 june 2023 implemented under regulation 64 of the 2019 uk-russia regulations 26 june 2023 on 26 june 2023 general licence int/2022/1710676 has been extended further and will expire on 31 march 2024. 180 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 and amended 26 june 2023 implemented under regulation 64 of the 2019 uk-russia regulations 26 june 2023 general licence int/2022/1875276 has been amended to: remove certain entities, which ofsi does not believe are owned or controlled by designated persons (dp) add mosdachtrest and rossiya segodnya as news media services dps adjust the definition of civil telecommunications dps to include certain subsidiaries of zao transtelecom company 181 the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2023 30 june 2023 amendments to the 2019 uk-russia regulations 30 june 2023 this instrument amends the 2019 uk-russia regulations to impose further trade sanctions in relation to russia. following its illegal annexation of crimea in 2014, russia has continued a pattern of aggressive action towards ukraine, which culminated in the invasion of ukraine’s sovereign territory on 24 february 2022. announced by president putin as a “special military operation”, this included recognising the “donetsk people’s republic” and “luhansk people’s republic” as independent states and deploying russian military across ukraine. the uk has called on russia to cease its military activity, withdraw its forces from ukraine and crimea, end its support for the separatists, and fulfil its international commitments including under the 1975 helsinki final act, the 2014 and 2015 minsk protocols, the 1994 budapest memorandum and the un charter. uk policy remains focused on ending russia’s invasion and on assisting ukraine to secure its borders, ensuring a stable, prosperous and democratic future for all its citizens. the uk is unwavering in its support for the country’s independence, territorial integrity and sovereignty. these sanctions are part of a broader set of measures which includes: diplomatic, military, financial and humanitarian support; trade, financial and transport sanctions; and designations. change will therefore be sought through diplomatic pressure and other measures, supported by trade sanctions in respect of actions undermining the territorial integrity, sovereignty and independence of ukraine. the provision of legal services is already partially restricted by the 2019 uk-russia regulations, including by regulations 19 and 55 (the “circumvention regulations”) and several regulations that limit the provision of ancillary services related to sanctioned goods and technologies. the circumvention regulations prevent a person intentionally providing legal advisory services where the object or effect of the legal advisory services directly or indirectly circumvents prohibitions imposed by the 2019 uk-russia regulations, or enables or facilitates the contravention of those prohibitions. however, as a result of the territorial application of the 2019 uk-russia regulations, this generally applies only to legal advisory services provided in relation to prohibited activity undertaken in the uk or by a uk person. this means that without these regulations, it would potentially be lawful for a uk legal services provider to support commercial activity which advances the interests of russia, where that activity does not have sufficient connection to the uk to be prohibited under the uk sanctions regime. this is a particular concern given that the law of england and wales is often chosen as the law governing international commercial activities, and as such, the services of uk lawyers are frequently engaged in relation to those activities, even if the activity is not conducted in the uk or by uk persons. this instrument addresses this issue and supplements other restrictions on providing legal services. it means that no uk person or person in the uk can provide legal advisory services in relation to certain financial or trade activity which would be prohibited under the uk sanctions regime if the activity was done by a uk person or was taking place in the uk. this restriction is limited to legal advisory services and does not cover legal representation services. access to legal representation is an important element of the core democratic principle of the rule of law, and this sort of legal service has therefore been excluded. in keeping with this principle, the instrument introduces an exception that enables services providers to offer expert evidence in connection with legal proceedings, even where the services activity would otherwise be prohibited to a person connected with russia. other exceptions to the restriction are also set out including legal advice related to compliance with the sanctions regime itself. the instrument also introduces a new exception to the prohibition on the provision of professional and business services. the exception, which applies to auditing services, provides companies and auditors with a legal basis under which they can operate where there are statutory or regulatory obligations. this reflects how this measure interacts with the audit requirement in uk company law and the auditor’s obligations to shareholders. this instrument also sets out a referral process relevant to the way that his majesty’s revenue and customs will investigate certain offences under the 2019 uk-russia regulations. 182 financial sanctions notice 6 july 2023 amends the 2019 uk-russia regulations 6 july 2023 the following entry has been removed from the ofis’s russia financial sanctions regime and is no longer subject to an asset freeze: lev aronovich khasis ofsi’s consolidated list of asset freeze targets has been updated to reflect this change. 183 financial sanctions notice 17 july 2023 amends the 2019 uk-russia regulations 17 july 2023 14 entries have been added and 10 entries have been amended under the uk russia financial sanctions regime. these entries are all subject to an asset freeze and trust services sanctions. the ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes and can be accessed here. further details can be found in the annex to the notice here. 184 the russia (sanctions) (overseas territories) (amendment) (no. 2) order 2023 19 july 2023 amendments to the 2019 uk-russia regulations 20 july 2023 and article 4 on 30 september 2023 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (the “principal order”). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the “russia sanctions regulations”) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have recently been amended by the russia (sanctions) (eu exit) (amendment) regulations 2023 (s.i. 2023/440); the russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2023 (s.i. 2023/665) and the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2023 (s.i. 2023/713) (together “the amending regulations”). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations: to modify offences in relation to export of goods to non-government controlled ukrainian territory; to modify relevant offences in relation to import of relevant processed iron or steel products and revenue generating goods from russia; to modify certain provision in relation to prohibitions on the provision of professional and business services. 185 financial sanctions notice 20 july 2023 amends the 2019 uk-russia regulations 20 july 2023 the following entry has been removed from the russia financial sanctions regime: oleg yurievich tinkov furthermore, the following entry has also been corrected under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: sun ship management (d) ltd further details can be found in the annex to the notice. 186 general licence – mongolia energy payments general licence - int/2022/2085212 15 august 2022 and amended 27 july 2023. amends the 2019 uk-russia regulations 27 july 2023 on 27 july 2023 ofsi amended general licence int/2022/2085212. this amendment extends the duration of the general licence, which will now expire on 14 august 2025. 187 financial sanctions notice 28 july 2023 amends the 2019 uk-russia regulations 28 july 2023 the following entries have been amended under the russia regime and remain subject to an asset freeze and trust services sanctions: andrey vladimirovich sharonov eugene tenenbaum further details can be found in the annex to the notice. 188 financial sanctions notice 31 july 2023 amends the 2019 uk-russia regulations 31 july 2023 6 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: vitaly alexsandrovich belitsky ekaterina mikhailovna dorokhina natalia nikolaevna dudar boris georgievich loktionov danila yurievich mikheev anna evgenievna potychko furthermore, the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: ella aleksandrovna pamfilova further details can be found in the annex to the notice. 189 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities general licence - int/2023/3263556 1 august 2023 implemented under regulation 64 of the 2019 uk-russia regulations 1 august 2023 the general licence int/2023/3263556 allows payments and other permitted activities to take place in relation to insolvency proceedings associated with gtlk europe and gtlk capital and their subsidiaries. 190 financial sanctions notice 8 august 2023 amends the 2019 uk-russia regulations 8 august 2023 19 entries have been added, and 1 entry has been corrected under the russia financial sanctions regime. all entries are subject to an asset freeze and trust services sanctions. further details can be found in the annex to the notice, here. 191 financial sanctions notice 8 august 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 8 august 2023 the following entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze: belomo holding joint stock company 2566 radioelectronic armament repair plant jsc peleng open joint stock company gomel radio plant open joint stock company kidma tech open joint stock company orsha aircraft repair plant further details can be found to the notice, here. 192 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 amended 21 october 2022, 26 june 2023, and 23 august 2023. implemented under regulation 64 of the 2019 uk-russia regulations 23 august 2023 general licence int/2022/1875276 has been amended to clarify that pjsc megafon is a designated person operating in the civilian telecommunications and news media service industry. 193 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities general licence - int/2023/3263556 01 august 2023 amended 23 august 2023 implemented under regulation 64 of the 2019 uk-russia regulations 23 august 2023 general licence int/2023/3263556 has been amended to make clear that stlc europe nine leasing limited is covered by the licence. 194 financial sanctions notice 31 august 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 31 august 2023 the following entry has been amended under the belarus financial sanctions regime and remains subject to an asset freeze: dana holdings a.k.a dana astra 195 general licence: payment to water companies for water & sewage general licence - int/2023/3179120 21 september 2023 implemented under regulation 64 of the 2019 uk-russia regulations 21 september 2023 general licence int/2023/3179120 was issued covering payments to water companies for water and sewage. under this licence, subject to the conditions; uk dps may make the permitted payments to water companies from a frozen uk bank account; any person may make a permitted payment to a water company (directly or indirectly), for or on behalf of a dp or for the benefit of a dp; and water companies may receive permitted payments made under paragraphs 1 or 2. under this licence, subject to the conditions the water companies may make return payments to frozen uk bank accounts due as a result of overpayment; and uk dps may receive return payments from water companies into a frozen uk bank account. a relevant uk institution may process payments made in accordance with paragraphs above. reporting requirements on a quarterly basis, the uk dp must report to hm treasury, with details and supporting evidence of: the name of the water company; the amount(s) paid; the payment route used; and the date on which the funds were paid. within 14 days of making a return payment under this licence, the water companies must report to hm treasury, with details of: the name of the uk dp; the amount(s) transferred; the payment route used; official - sensitive official - sensitive official - sensitive official - sensitive iv) the date on which the funds were transferred; and v) the reason for the return payment. record-keeping requirements the water companies and uk dps must keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years. 196 financial sanctions notice 27 september 2023 amends the 2019 uk-russia regulations 27 september 2023 the following entry has been amended under the russia regime and remains subject to an asset freeze and trust services sanctions: alexei kozlov 197 financial sanctions notice 29 september 2023 amends the 2019 uk-russia regulations 29 september 2023 11 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. further details can be found in the notice, here 198 general licence – correspondent banking payments general licence - int/2023/3566356 29 september 2023 implemented under regulation 64 of the 2019 uk-russia regulations 29 september 2023 general licence int/2023/3566356 was issued covering correspondent banking payments - the general licence and its publication notice can be found here on gov.uk anyone who intends to rely on the general licence should consult a copy of the licence for full details of the definitions, permissions, and usage requirements. 199 general licence – prior obligations general licence - int/2023/3024200 10 october 2023 implemented under regulation 64 of the 2019 uk-russia regulations 10 october 2023 general licence int/2023/3024200 has been extended, with additional amendments made to its conditions, definitions and annexes. the general licence and its publication notice can be found here. 200 general licence: payment to energy companies for gas and/or electricity general licence - int/2022/2300292 17 november 2022 and amended 24 february 2023 13 october 2023 all uk autonomous sanctions regulations listed in annex i of this licence 13 october 2023 ofsi amended general licence int/2022/2300292 - payment to energy companies for gas and/or electricity. the amendments include the extension of the term of the general licence - which no longer has an expiry date - and the permission for any person to make permitted payments to energy companies for or on behalf of a designated person. the general licence can be found here. 201 general licence: payments to companies house general licence - int/2023/3626884 19 october 2023 all uk autonomous sanctions regulations listed in annex i of this licence 6 october 2023 ofsi amended general licence int/2023/3626884 - payments to companies house. the amendment provides clarity on terms used within the general licence, specifically permitted payments and uk designated persons. the general licence can be found here. 202 general licence – legal services general licence - int/2023/3744968 25 october 2023 implemented under regulation 64 of the 2019 uk-russia regulations 25 october 2023 new ofsi general licence int/2023/3744968 for legal services to replace current licence int/2023/2954852 from 29 october 2023. the main changes are: the professional legal fees caps have been reset. users will be able to make use of the legal fees caps (£500,000 inc. vat) under parts a and b of the general licence. the expenses caps have been reset and increased from 5% of the legal fees (up to £25,000) to 10% of the legal fees (up to £50,000) under parts a and b. this means if expenses are required for work carried out in satisfaction of a prior obligation (£50,000 limit) and for work undertaken post-designation (£50,000 limit), up to £100,000 (inc. vat) in expenses could be paid. reporting is now due within 14 days of the law firm, legal adviser, counsel, or a provider of expenses receiving payment. the reporting requirement makes clear that the relevant letter of engagement sent to ofsi must be unredacted. the reporting form makes clear that the group id of the dp must be provided to ofsi. general licence int/2023/3744968 takes effect on 29 october 2023 and expires on 28 april 2024 and may be varied, revoked, or suspended by hm treasury at any time. general licence – publication notice can be found here. 203 general licence – continuation of business and basic needs for telecommunications services and news media services general licence - int/2022/1875276 30 may 2022 and amended 21 october 2022 26 june 2023 23 august 2023 27 october 2023 implemented under regulation 64 of the 2019 uk-russia regulations 27 october 2023 on 27 october 2023, general licence int/2022/1875276 was updated to clarify that: pjsc megafon and its subsidiaries are civilian telecommunication dps. digital invest limited liability company (digital invest) is a civilian telecommunication dp. general licence int/2022/1875276 has been extended to 30 may 2026. the general licence and the publication notice can be found here. 204 financial sanctions notice 8 november 2023 amends the 2019 uk-russia regulations 8 november 2023 29 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. further details can be found in the notice, here. 205 financial sanctions notice 9 november 2023 amends the 2019 uk-russia regulations 9 november 2023 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: sergey stognienko further details can be found in the notice, here. 206 general licence – russian travel general licence - int/2022/1839676 23 may 2022 amended 14 february 2023 and 10 november 2023. implemented under regulation 64 of the 2019 uk-russia regulations 10 november 2023 ofsi amended general licence int/2022/1839676 - russian travel. the amendment makes clear that paragraph 4.1 only permits the purchase of tickets from a designated person or any subsidiary for passenger rail or passenger air journeys originating in, or within, russia. 207 general licence – london court of international arbitration (lcia) arbitration costs general licence - int/2022/1552576 17 october 2022 and amended 05 june 2023 13 november 2023 implemented under regulation 64 of the 2019 uk-russia regulations and also under regulation 32 of the republic of belarus (sanctions) (eu exit) regulations 2019 13 november 2023 ofsi amended general licence int/2022/1552576 - london court of international arbitration (“lcia”) arbitration costs. the amendment removes the annex 1 that sets out the schedule of arbitration costs, and updates the definition of arbitration costs by referring to the relevant schedule of costs for lcia arbitration. 208 financial sanctions notice 6 december 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 6 december 2023 the following entry has been added to the belarus financial sanctions regime and is now subject to an asset freeze: jsc display design bureau further details can be found in the notice, here. 209 financial sanctions notice 6 december 2023 amends the 2019 uk-russia regulations 6 december 2023 45 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. more information can be found in the notice, here. 210 financial sanctions notice 8 december 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 8 december 2023 17 entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze. more information can be found in the notice, here. 211 general licence: payments to local authorities general licence - int/2023/3781228 8 december 2023 under all uk autonomous sanctions regulations 8 december 2023 a new general licence was issued covering payments to local authorities - general licence int/2023/3781228 (the general licence). the general licence and its publication notice can be found on gov.uk. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. more information can be found here. 212 financial sanctions notice 11 december 2023 amends the 2019 uk-russia regulations 11 december 2023 the following entry has been amended and is still subject to an asset freeze and trust services sanctions: ooo mvizion more information can be found in the notice, here. 213 financial sanctions notice 11 december 2023 amends the republic of belarus (sanctions) (eu exit) regulations 2019 11 december 2023 the following entries have been amended and are still subject to an asset freeze: mikhail ivanovich dola mikhail kavaliou more information can be found in the notice, here. 214 the russia (sanctions) (eu exit) (amendment) (no. 4) regulations 2023 14 december 2023 amends the 2019 uk-russia regulations regulations 17, 18, 20 and 21 come into force on 26 december 2023. the remainder of these regulations come into force on 15 december 2023. these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations). regulation 3 amends the prohibitions relating to processing payments to provide that these apply to processing a payment in any currency which is received by a uk credit or financial institution but do not apply to the initial crediting of a payment to an account which is in the name of the credit or financial institution but not in the name of a customer of that credit or financial institution. regulation 4 amends existing definitions of certain products, both to add exclusions in relation to certain products where they fall within schedule 2 to the export control order 2008 (“the 2008 order”) (s.i. 2008/3231) or annex 1 of the dual-use regulation(a) and to remove exclusions relating to certain products where they fall within schedule 3 to the 2008 order. regulation 5 extends the prohibitions relating to trade in luxury goods and regulation 9 amends the exceptions to those prohibitions consequentially. regulation 6 makes minor amendments to the prohibitions relating to relevant processed iron and steel products. certain iron and steel products to which the prohibitions in chapter 4c of part 5 to the 2019 regulations are to apply are added by regulation 22(10) and schedule 1. new prohibitions relating to trade in certain metals are created by regulations 7 and 22(11) and schedule 2. regulation 8 amends the exceptions relating to the prohibition on processing payments in regulation 17a(2) of the 2019 regulations. regulation 10 creates new exceptions to the prohibitions on g7 dependency and further goods and expands those for luxury goods where these relate to consumer communication devices and software updates. regulations 11 to 13 create exceptions for iron and steel products, relevant processed iron and steel products and metals where they were exported from russia before the prohibition come into force or where they are already in free circulation in the united kingdom. regulation 14 expands the exceptions from the prohibitions on g7 dependency and further goods in the case of emergencies. regulations 15 and 22(22) allow the treasury to grant licences for certain activities carried out by a uk entity in order to divest itself of assets where those assets are subject to a sanction under the 2019 regulations. regulation 16 creates new reporting obligations to be imposed on relevant firms in relation to funds and economic resources held by them for prohibited persons (as defined by the amendment contained in that regulation). regulation 17 creates new reporting obligations on designated persons themselves, regulation 18 prescribes the criminal penalty for breach of those obligations, regulation 20 provides that those obligations are to be regarded as not being financial sanctions legislation for the purposes of part 8 of the policing and crime act 2017 (c. 3) and regulation 21 allows the treasury to impose civil monetary penalties for breaches of those obligations. regulation 19 prescribes offences created by these regulations, the suspected commission of which may be referred to his majesty’s revenue and customs for investigation. regulation 22— - makes changes to the products covered by the prohibitions on trade in critical-industry goods and critical industry technology (paragraphs (2) to (8)), luxury goods (paragraph (9)), defence and security goods and defence and security technology (paragraphs (12) to (16) and schedule 3) and g7 dependency and further goods (paragraphs (17) to (20)) and schedules 4, 5 and 6). - creates an additional ground on which the treasury may licence the processing of payments which would otherwise be prohibited by regulation 17a(2) of the 2019 regulations (paragraph (23)); - omits certain commodity codes and the associated descriptions (paragraph (24) and schedule 7). minor consequential amendments on that made in regulation 3(2) are made by regulation 23. 215 the russia (sanctions) (eu exit) (amendment) (no. 5) regulations 2023 14 december 2023 amends the 2019 uk-russia regulations 1 january 2024 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) to amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855). in particular, these regulations create prohibitions on the import, acquisition and supply and delivery of diamonds and diamond jewellery (as defined in the schedule inserted by regulation 7(2)) which are located, originate in or are consigned from russia and on the provision of ancillary services relating to those prohibitions (regulation 3). regulations 4 and 5 create certain exceptions to those prohibitions. regulation 6 prescribes which of the offences created by the amendments at regulation 3 of these regulations, may be referred to his majesty’s revenue and customs for investigation. regulation 7(1) makes consequential amendments to the list of schedule 3da revenue generating goods. 216 financial sanctions notice 15 december 2023 amends the 2019 uk-russia regulations 15 december 2023 1 entry has been added and is now subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions: joint-stock commercial bank novikombank and 26 entries have been amended and are all subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions. 217 maritime services ban and oil price cap exception - hmt industry guidance 20 december 2023 the russia (sanctions) (eu exit) (amendment) (no. 16) regulations 2022. 20 december 2023 ofsi published updated guidance for the maritime services ban and oil price cap, to provide additional clarity and detail on the following: attestations: upcoming changes to the existing model will require 1) attestation forms to be provided on a per-voyage basis and 2) itemised ancillary costs to be recorded by tier 1 entities and provided to tier 2 and tier 3a contractual counterparties upon request. the tier system has also been amended. uk nationals: clarification on reporting requirements for uk nationals in third countries reporting timelines: clarification on deadlines and requirements for record keeping and reporting activity under the general licences. more information can be found here. 218 general licence – publication notice 20 december 2023 implemented under regulation 64 of the 2019 uk-russia regulations 20 december 2023 amendments to general licences - int/2022/2469656, int/2022/2470256, int/2022/2470056, int/2022/2470156, int/2023/2660772 and int/2023/3074680 219 financial sanctions notice 21 december 2023 amends the 2019 uk-russia regulations 21 december 2023 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: yuri alekseyevich soloviev 220 general licence: permitted payments to uk insurance companies int/2022/2009156 22 july 2022 and amended 17 august 2022 15 december 2023 06 february 2024 15 february 2024 under all uk autonomous sanctions regulations 15 february 2024 ofsi amended general licence - int/2022/2009156 to remove reference to frozen uk bank accounts from permissions 4.1, 4.3.1, and 6.1 to make clear that payments by dps are not restricted to those made from frozen funds; and the language in permission 5.1 and 6.6 has been clarified. 221 financial sanctions notice 22 february 2024 amends the 2019 uk-russia regulations 22 february 2024 50 entries have been added to and 3 have been amended on the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. more information can be found in the notice. further information can be found in the annex to the notice here. 222 financial sanctions notice 22 february 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 22 february 2024 2 entries has been added to the belarus financial sanctions regime and are now subject to an asset freeze: jsc planar precise electro-mechanics plant further information can be found in the annex to the notice here. 223 financial sanctions notice 23 february 2024 amends the 2019 uk-russia regulations 23 february 2024 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trusts services sanctions: ilya borisovich brodskiy 224 the russia (sanctions) (eu exit) (amendment) regulations 2024 28 february 2024 amends the 2019 uk-russia regulations 1 march 2024 on 1 march 2024, the uk government issued a detailed guidance on the measures concerning russian diamonds processed in third countries and the key components of this guidance are: regulations overview: prohibits import of diamonds meeting specific criteria, including russian origin and processing in third countries. applies to diamonds equal to or larger than 1 carat from 1 march 2024, and 0.5 carats from 1 september 2024. guidance on compliance: traders must provide evidence of supply chain history consistent with regulations. required documentation includes weight, country of origin, processing details, and compliance attestation. licensing provisions: traders can apply for individual licences for prohibited imports, subject to specific criteria. general trade licence allows import of certain diamonds processed outside russia before 1 march 2024, with record-keeping requirements. enforcement and due diligence: traders may need to provide evidence of compliance at the border. hm revenue and customs is responsible for enforcement and investigating offenses. non-compliance may result in criminal penalties. for detailed information, refer to the statutory guidance on russia sanctions here the general trade licence for sanctioned russian diamonds processed in third countries can be found here. the russia (sanctions) (eu exit) (amendment) regulations 2024 can be accessed here and the explanatory memorandum here. 225 general licence – court funds office payments int/2024/4398024 29 february 2024 implemented under regulation 64 of the 2019 uk-russia regulations 29 february 2024 under this licence, subject to the conditions below: a person may make permitted payments, being the payment of monies owed to designated persons into civil court pursuant to a court order, into a bank account held by the court funds office, following confirmation by the court funds office of the relevant bank details. the court funds office may receive permitted payments from a person. a relevant uk institution may carry out any activity necessary to effect the permissions listed in paragraph above. reporting requirements - a person making a payment in the manner described above (see paragraph 4 of this general licence) must, within 14 days of completing such a transaction, provide hm treasury with details of the payments and supporting evidence of the name of the designated person; the amount(s) paid; a copy of the court order; and the date on which the funds were paid. record-keeping requirements - a person must keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years. 226 financial sanctions notice 1 march 2024 amends the 2019 uk-russia regulations 1 march 2024 the following entry has been corrected under the russia financial sanctions regime and remains subject to an asset freeze and trusts services sanctions: vladimir vladimirovich mikheychik 227 financial sanctions notice 5 march 2024 amends the 2019 uk-russia regulations 5 march 2024 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: igor viktorovich makarov 228 the russia (sanctions) (overseas territories) (amendment) order 2024 13 march 2024 amends the russia (sanctions) (overseas territories) order 2020 14 march 2024 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (“the principal order”). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (“the russia sanctions regulations”) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have recently been amended by the russia (sanctions) (eu exit) (amendment) (no. 4) regulations 2023 (s.i. 2023/1364) (“the amending regulations”). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations. 229 general licence – active denizcilik and beks ships transit to port and wind down > int/2024/4576632 28 march 2024 implemented under regulation 64 of the 2019 uk-russia regulations 28 march 2024 this general licence permits insurance and other services to be paid for in respect of vessels currently at sea managed by active denizcilik to facilitate their entry to port, and to permit persons to wind down their relationships involving both active denizcilik and beks gemi for the duration of this licence. 230 general licence under the russia regulations and the belarus regulations legal services general licence int/2024/4671884 26 april 2024 implemented under regulation 64 of the 2019 uk-russia regulations 29 april 2024 legal services general licence expired and replaced - on 28 april 2024, general licence int/2023/3744968 expired. on monday 29 april 2024, a new general licence has come into effect covering legal services - general licence int/2024/4671884 231 financial sanctions notice 3 may 2024 amends the 2019 uk-russia regulations 3 may 2024 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: sarvar ismailov 232 financial sanctions notice 8 may 2024 amends the 2019 uk-russia regulations 8 may 2024 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: said mikhailovich gutseriev 233 financial sanctions general guidance - updated 13 may 2024 section 6 - licensing 13 may 2024 section 6 licensing: ofsi has amended its guidance on our approach to licensing grounds for uk regimes, including updating the definitions for extraordinary expenses and extraordinary situations. 234 financial sanctions notice 17 may 2024 amends the 2019 uk-russia regulations 17 may 2024 the following entry has been added to the russia financial sanctions regime and remains subject to an asset freeze and trusts services sanctions: vostochnaya stevedore limited liability company 235 russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2024 24 may 2024 amends the 2019 uk-russia regulations 28 may 2024 these amendments modify the existing russia (sanctions) (eu exit) regulations 2019 under the sanctions and anti-money laundering act 2018. these updates aim to enhance the effectiveness of existing sanctions against russia and come into force from 28 may 2024 key changes include: expanded designation criteria: new activities that can lead to a person being designated under sanctions have been added. updated ship specification criteria: additional activities that can result in a ship being specified under the sanctions are now included. read the full russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2024, here. 236 general licence – funds of non-designated third parties involving designated credit or financial institutions (personal remittances) int/2024/4761108 28 may 2024 implemented under regulation 64 of the 2019 uk-russia regulations 28 may 2024 funds of non-designated third parties involving designated credit or financial institutions (personal remittances) general licence issued. general licence int/2024/4761108 allows a person to make use of the retail banking services of a designated credit or financial institution provided that the payments made or received are intended for the personal use of a person. the general licence and its publication notice can be found here. 237 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments int/2022/1280876 01 march 2022 amended 01 april 2022, 22 april 2022, 22 august 2022, 06 october 2022, 24 february 2023, 02 january 2024, and 31 may 2024. implemented under regulation 64 of the 2019 uk-russia regulations 31 may 2024 general licence int/2022/1280876 was amended to permit a scheme of arrangement prepared by the joint administrators of vtb capital plc. for full details of the new definitions and permissions that are associated with this amendment ofsi recommends consulting the copy of the licence, in particular paragraphs 5.3(a) – 5.7. 238 financial sanctions notice 31 may 2024 amends the 2019 uk-russia regulations 31 may 2024 the following entry has been amended under the russia financial sanctions regime and is still subject to an asset freeze: dmitry vladimirovich konov. 239 financial sanctions notice 13 june 2024 amends the 2019 uk-russia regulations 13 june 2024 42 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions. further information can be found in the annex to this notice. 240 financial sanctions notice 14 june 2024 amends the 2019 uk-russia regulations 14 june 2024 the following entries have been corrected under the russia financial sanctions regime and are still subject to an asset freeze and trusts services sanctions: central counterparty national clearing centre and llc kompaniya amg. 241 general licence: payments to the fca int/2024/4836676 20 june 2024 uk autonomous sanctions regulations 20 june 2024 this general licence allows for payments to the financial conduct authority (fca) from a designated person (dp), or on behalf of a dp. 242 financial sanctions notice 25 june 2024 amends the 2019 uk-russia regulations 25 june 2024 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions: aleksei nikolaevich filippovskii 243 financial sanctions notice 26 june 2024 amends the 2019 uk-russia regulations 26 june 2024 the following entries have been amended under the russia financial sanctions regime and are still subject to an asset freeze and trust services sanctions: the following entries have been amended and are still subject to an asset freeze: pavel sergeevich barchugov konstantin denisov fractal marine dmcc 244 general licence: payments for statutory audits int/2024/4888228 27 june 2024 uk autonomous sanctions regulations 27 june 2024 this general licence allows for payments to statutory auditors for a statutory audit from a designated person (dp), or on behalf of a dp. 245 general licence – oil price cap: exempt projects and countries int/2022/2470156 04 december 2022 amended 05 january 2023 14 september 2023 28 june 2024 implemented under regulation 64 of the 2019 uk-russia regulations 28 june 2024 on 28 june, the office of financial sanctions implementation (osfi) updated the oil price cap general licence: exempt projects and countries – int/2022/2470156– to extend the sakhalin-2 project expiration date to the 28 june 2025. ofsi has also updated the associated publication notice 246 general licence: payments to revenue authorities int/2024/4881897 1 july 2024 uk autonomous sanctions regulations 1 july 2024 on 1 july 2024, general licence int/2024/4881897 (the general licence) was issued. this general licence allows for payments to be made to the revenue authorities by a uk designated person (dp), or on behalf of a dp. 247 general licence: payments for visa application services int/2024/4907888 3 july 2024 uk autonomous sanctions regulations 3 july 2024 this general licence allows for payments to visa application services providers from a designated person (dp), or on behalf of a dp. 248 general licence – sale, divestment and transfer of financial instruments held by the national settlement depository and payment of safe keeping fees to the national settlement depository int/2024/4919848 3 july 2024 implemented under regulation 64 of the russia (sanctions) (eu exit) (regulations) 2019 3 july 2024 this general licence allows for the sale, divestment or transfer of financial instruments held at the national settlement depository of russia (nsd), and the payment of safe keeping fees to the nsd for the holding of such financial instruments. 249 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments int/2022/1280876 01 march 2022 amended on 01 april 2022, 22 april 2022, 22 august 2022, 06 october 2022, 24 february 2023, 02 january 2024, 31 may 2024, and 23 july 2024. implemented under regulation 64 of the russia (sanctions) (eu exit) (regulations) 2019 23 july 2024 general licence int/2022/1280876 on russian banks. this general licence was amended to change permission 5.2, specifically the insolvency proceedings that apply to owh se (previously known as vtb bank (europe) se), the eu subsidiary. 250 the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2024 30 july 2024 made under the sanctions and anti-money laundering act 2018 (c. 13) (samla), and amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations) 31 july 2024 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13) (samla) and amend the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (the 2019 regulations). they revoke and replace the russia (sanctions) (eu exit) (amendment) (no. 2) regulations 2024 (s.i. 2024/695) (the 2024 regulations) regulation 3 makes amendments to the designation criteria in regulation 6 of the 2019 regulations to specify additional activities for which a person may be designated. regulation 4 makes amendments to the ship specification criteria in regulation 57f of the 2019 regulations to specify additional activities for which a ship may be specified. regulation 5 revokes the 2024 regulations for the reason explained above. 251 general licence – sale, divestment and transfer of financial instruments held by the national settlement depository and payment of safe keeping fees to the national settlement depository int/2024/4919848 2 august 2024 implemented under regulation 64 of the russia (sanctions) (eu exit) (regulations) 2019 2 august 2024 the general licence int/2024/4919848 allows the sale, divestment, and transfer of financial instruments held by the national settlement depository (nsd) and the payment of safekeeping fees to nsd. this licence exempts certain actions from prohibitions under the russia (sanctions) (eu exit) regulations 2019. it defines key terms, outlines permissions for relevant institutions, and mandates record-keeping for six years. the licence is effective from 3 july 2024, to 12 october 2024, and may be altered by hm treasury. 252 financial sanctions notice 9 august 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 9 august 2024 the following 7 entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze: aleksey valerievich lazarenko andrei sergeevich palchyk filip vladimirovich sturchanka denis anatolievich tolstenkov jsc niievm ojsc stankogomel ruchservomotor llc ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 253 financial sanctions notice 26 september 2024 amends the 2019 uk-russia regulations 26 september 2024 the following entries have been added to the russian financial sanctions regime and are now subject to an asset freeze and trust services sanctions: ocean speedstar solutions opc pvt ltd white fox ship management fzco 254 general licence: payment to water companies for water & sewage int/2023/3179120 21 september 2023 updated 1 october 2024 uk autonomous sanctions regulation 21 september 2023 general licence int/2023/3179120 was updated as follows: the definition of uk designated persons(dps) was amended to: those individuals or entities designated (or owned or controlled by an individual or an entity designated) for the purposes of an asset freeze by the uk under the uk autonomous sanctions regulations, excluding those designated for the purpose of compliance with united nations obligations. the definition of return payments was amended to: a payment payable by a water company to a uk dp in connection with water and/or sewerage services to a uk property owned or rented by the dp and arising from: an overpayment by the dp, a credit on the account of the dp, a billing adjustment (whether or not as a result of error) by the water company, termination of the services. the validity of the general licence is now indefinite. 255 financial sanctions notice 3 october 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 3 october 2024 the following entry has been added to the belarus financial sanctions regime and is now subject to an asset freeze: cjsc alfa bank belarus 256 the russia (sanctions) (overseas territories) (amendment) (no. 2) order 2024 2 october 2024 amendment of the russia (sanctions) (overseas territories) order 2020 3 october 2024 this order makes amendments to the russia (sanctions) (overseas territories) order 2020 (s.i. 2020/1571) (“the principal order”). the principal order extends with modifications the russia (sanctions) (eu exit) regulations 2019 (s.i. 2019/855) (“the russia sanctions regulations”) as amended from time to time to all british overseas territories except bermuda and gibraltar (which implement sanctions under their own legislative arrangements). the russia sanctions regulations established a sanctions regime in relation to russia for the purpose of encouraging russia to cease actions destabilising ukraine or undermining or threatening the territorial integrity, sovereignty or independence of ukraine. the russia sanctions regulations have recently been amended by the russia (sanctions) (eu exit) (amendment) (no. 5) regulations 2023 (s.i. 2023/1367), the russia (sanctions) (eu exit) (amendment) regulations 2024 (s.i. 2024/218), the russia (sanctions) (eu exit) (amendment) (no. 3) regulations 2024 (s.i. 2024/900) (together, “the amending regulations”). this order makes the necessary amendments to the principal order to give effect in the relevant british overseas territories to the changes made to the russia sanctions regime by the amending regulations. 257 financial sanctions notice 11 october 2024 amends the 2019 uk-russia regulations 11 october 2024 the following entries have been amended under the russia financial sanctions regime and remain subject to an asset freeze and trust services sanctions: andrey igorevich melnichenko grigory vikotorovitsj berezkin 258 general licence: government debt payments int/2024/5294388 14 october 2024 uk autonomous sanctions regulations 14 october 2024 the general licence allows persons to make and facilitate payments in respect of uk government debt where either the legal holder or the direct or indirect recipient or beneficiary of that payment is a uk dp or uk prohibited person provided the payments are held in frozen accounts or uk prohibited persons accounts. the general licence and its publication notice can be found here. 259 financial sanctions notice 17 october 2024 amends the 2019 uk-russia regulations 17 october 2024 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: semyon mkrtychovich simonyan 260 ofsi general licence under the russia regulations and the belarus regulations int/2024/5334756 25 october 2024 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations 29 october 2024 on 28 october 2024, general licence int/2024/4671884 will expire. on 29 october 2024, a new general licence will come into effect covering legal services - general licence int/2024/5334756 (the general licence). the general licence and its reporting forms can be found on the legal services general licence page on gov.uk. anybody intending to use the general licence should consult the copy for full details of the definitions, permissions and usage requirements. the publication notice lists the main changes to support users of this licence. 261 financial sanctions notice 28 october 2024 amends the 2019 uk-russia regulations 28 october 2024 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: ilya andreevich gambashidze andrey naumovich perla nikolai aleksandrovich tupikin ano dialog social design agency structura national technologies ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 262 general licence: payment to energy companies for gas and/or electricity int/2022/2300292 17 november 2022 amended 24 february 2023, 13 october 2023, 15 december 2023, 29 february 2024, and 29 october 2024. uk autonomous sanctions regulations 29 october 2024 general licence int/2022/2300292 was amended to: make clear that the definition of uk dps includes entities owned or controlled by a designated individual or entity; and excludes those designated for the purpose of compliance with united nations obligations. add heating and/or hot water powered by gas or electricity from an external source such as through a district heating network; and meters related to district heating networks to the “permitted payments” definitions section. update the reference to the energy bills discount support scheme (ebds) in the “return payments” definitions section. update the list of the uk autonomous sanctions regulations schedules contained within annex 1 so that all the relevant regulations are included. 263 financial sanctions notice 7 november 2024 amends the 2019 uk-russia regulations 7 november 2024 47 entries have been added to the consolidated list and are now subject to an asset freeze and trusts services sanctions. further information can be found in the annex to this notice. 264 general licence – payments made in the year 2022 between non-designated third parties involving designated credit or financial institutions (“correspondent banking - 2022 blocked payments”) int/2024/5394840 7 november 2024 under regulation 64 of the russia regulations 7 november 2024 this general licence allows relevant institutions to process payments made in the year 2022 from or via a designated credit or financial institution, provided that the original sender and original intended recipient are not designated persons. 265 the sanctions (eu exit) (miscellaneous amendments) (no. 2) regulations 2024 14 november 2024 these regulations are made under the sanctions and anti-money laundering act 2018 (c. 13). they make miscellaneous amendments to most of the existing sanctions regulations. 5 december 2024 and one measure on 14 may 2025 changes to sanctions legislation introduced through the sanctions (eu exit) (miscellaneous amendments) (no.2) regulations 2024 and faqs updated. on 14 november 2024, the sanctions (eu exit) (miscellaneous amendments) (no.2) regulations 2024 was laid in parliament. this instrument introduces numerous changes to improve ofsi’s intelligence on industry’s compliance, strengthen ofsi’s enforcement powers, enable ofsi to deal with licensing applications more efficiently, and clarify financial sanctions legislation where there is existing uncertainty. all measures except for one will come into force on 5 december 2024. the extension of reporting obligations to high value dealers, art market participants, letting agents and insolvency practitioners will come into force on 14 may 2025. the ofsi’s frequently asked questions page has been updated from 125-131 to clarify the use of regulatory payments exceptions. click here to view. 266 financial sanctions notice 15 november 2024 amends the 2019 uk-russia regulations 15 november 2024 on 15 november 2024 the foreign, commonwealth and development office updated the uk sanctions list on gov.uk. this list provides details of those designated under regulations made under the sanctions act. the following entries have been amended under the russia financial sanctions regime and are still subject to an asset freeze and trust services sanctions: anatoly ilyich bibilov juhang aviation technology (shenzhen) co., limited bringing the entries in line with the uk sanctions list, the following entries have been corrected under the russia financial sanctions regime and remain subject to an asset freeze and trust services sanctions: konstantin yurievich mirzayants virmavia ou the following entry has been removed under the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: didier casimiro 267 financial sanctions notice 19 november 2024 amends the 2019 uk-russia regulations 19 november 2024 10 entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trusts services sanctions. more information can be found in the notice. ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. further information can be found in the annex to this notice. 268 financial sanctions notice 25 november 2024 amends the 2019 uk-russia regulations 25 november 2024 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: alfastrakhovanie plc vsk ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 269 general licence - int/2024/4836676 general licence - int/2023/3626884 general licence – int/2023/3781228 general licence - int/2024/4881897 5 december 2024 sanctions and anti-money laundering act 2018 (the sanctions act) 5 december 2024 general licences - int/2024/4836676, int/2023/3626884, int/2023/3781228 and int/2024/4881897 revoked these general licences have been revoked. the new required payments exception allows for certain payments to be made from, or on behalf of, non-un designated persons to the authorities covered by these general licences, without the need for an ofsi licence. 270 financial sanctions notice 9 december 2024 amends the 2019 uk-russia regulations 9 december 2024 the following entry has been added to the russia financial sanctions regime and is now subject to an asset freeze and trust service sanctions: anto joseph 271 financial sanctions notice 17 december 2024 amends the 2019 uk-russia regulations 17 december 2024 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: 2rivers dmcc 2rivers pte ltd 272 financial sanctions notice 18 december 2024 amends the 2019 uk-russia regulations 18 december 2024 the following entry has been amended under the russia financial sanctions regime and is still subject to an asset freeze and trust services sanctions: autel robotics co., ltd 273 financial sanctions notice 19 december 2024 amends the republic of belarus (sanctions) (eu exit) regulations 2019 19 december 2024 the following entry has been amended under the belarus financial sanctions regime and is still subject to an asset freeze: mikail safarbekovich gutseriev 274 general licence - russian banks – uk subsidiaries – guernsey subsidiary – eu subsidiaries - basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments int/2022/1280876 01 march 2022amended1 april 202222 april 202222 august 20226 october 202224 february 20232 january 202431 may 202423 july 20248 january 2025 under regulation 64 of the russia regulations 8 january 2025 general licence int/2022/1280876 was amended to add permission 5.3a which states that no distributions on vtb bank pjsc’s claim should be made without first deducting from the distributions the value of any vtb capital plc assets which have been or are subject to vtb bank pjsc enforcement action, and the vtb group receivables; and statutory interest should not be paid for any time over which distributions are not paid because of these deductions. 275 financial sanctions notice 9 january 2025 amends the 2019 uk-russia regulations 9 january 2025 the following entry has been amended to the russia financial sanctions regime and is still subject to an asset freeze and trust services sanctions: zapchasttrade llp 276 financial sanctions notice 10 january 2025 amends the 2019 uk-russia regulations 10 january 2025 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: pjsc surgutneftegas gazprom neft 277 general licence: russian oil exempt projects int/2025/5635700 10 january 2025 under regulation 64 of the russia regulations 10 january 2025 this general licence allows for the continuation of business operations with the relevant subsidiary to the extent they are in relation to the exempt projects (as defined in the licence). 278 general licence: russian oil majors wind down int/2025/5635701 10 january 2025 under regulation 64 of the russia regulations 10 january 2025 this general licence allows for a wind down period of positions involving the gazprom neft and pjsc surgutneftegas or any entity owned or controlled by gazprom neft and pjsc surgutneftegas. 279 general licence interim basic necessities for designated persons int/2025/5632740 14 january 2025 uk autonomous sanctions regulations 14 january 2025 this general licence allows persons to make funds available to or for the benefit of a uk designated person(dp) up to the permitted maximum in each of the two months following the date of the uk dp’s designation for the purpose of the uk dp making permitted payments. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. 280 financial sanctions notice 15 january 2025 amends the 2019 uk-russia regulations 15 january 2025 the following entry has been amended under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: gazprom neft (group id: 16736) 281 financial sanctions notice 15 january 2025 amends the 2019 uk-russia regulations 15 january 2025 the following entry has also been amended on ofsi's list of investment ban targets and remains subject to an investment ban: gazprom neft (group id: 13119) 282 financial sanctions notice 27 january 2025 implemented under 2019 belarus (sanctions) (eu exit) regulations 27 january 2025 the following entries have been added to the belarus financial sanctions regime and are now subject to an asset freeze: alevkurp ojsc andrei valerievich ananeko mikhail petrovitch bedunkevich viktor alexandrovich dubrovka igor vasilyevich karpenko pavel ivanovich kazakov andrey mikhailovich tsedrik kb unmanned helicopters (uavheli) ledmash plant jsc ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 283 general licence–oil price cap nt/2024/4423849 19 february 2024 amended 08 march 2024, 24 may 2024, and 29 january 2025. under regulation 64 of the russia regulations 29 january 2025 the oil price cap (opc) general licence (gl) – int/2024/4423849– was amended to update the combined nomenclature (cn) / harmonized system (hs) commodity code for “premium to crude”, 2710 19 43, which now falls under2710 19 42. this change does not alter uk providers use of the opc gl in relation to the supply or delivery of this oil product, prior to or following the update. providers should also continue to report to ofsi as per the gl’s reporting conditions, just updating the product code if relevant. the full list of products at the uk integrated online tariff is here for further information. 284 financial sanctions notice 30 january 2025 amends the 2019 uk-russia regulations 30 january 2025 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: nikolay ivanovich bortsov 285 financial sanctions notice 10 february 2025 amends the 2019 uk-russia regulations 10 february 2025 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: irina vladimirovna chubarova 286 financial sanctions notice 14 february 2025 amends the 2019 uk-russia regulations 14 february 2025 the following entries have been added to the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions: artem yuryevich chaika pavel mikhailovich fradkov joint stock company kirov energomash plant limited liability company rosatom additive technologies vladimir viktorovich selin the following entry has been amended on the russia financial sanctions regime and is still subject to an asset freeze and trust service sanctions: yuri yakovlevich chaika 287 general licence: membership fees for international organisations int/2025/5855272 21 february 2025 amends the 2019 uk-russia regulations 21 february 2025 this general licence allows international organisations to receive permitted payments transferred from an account held with gazprombank. anybody intending to use the general licence should consult the copy of the licence for full details of the definitions, permissions, and usage requirements. 288 financial sanctions notice 24 february 2025 amends the 2019 uk-russia regulations 24 february 2025 66 entries have been added to the consolidated list under the russia financial sanctions regime and are now subject to an asset freeze and trust services sanctions. further information can be found in the notice. the following entry has been added to the consolidated list under the russia financial sanctions regime and is now subject to an asset freeze, trust services sanctions and a prohibition on correspondent banking and clearing: ojsc keremet bank also the following entry has been amended on the consolidated list under the russia financial sanctions regime and remains subject to an asset freeze and trust services sanctions: tsargrad ooo ofsi’s consolidated list of asset freeze targets has been updated to reflect these changes. 289 financial sanctions notice 26 february 2025 amends the 2019 uk-russia regulations 26 february 2025 the following entry has been removed from the russia financial sanctions regime and is no longer subject to an asset freeze or trust services sanctions: francois edouard mauron 290 financial sanctions notice 27 february 2025 amends the 2019 uk-russia regulations 27 february 2025 the following entries have been corrected under the russia financial sanctions regime and are still subject to an asset freeze and trust services sanctions: vasily vitalyevich abramov natalya aleksandrovna tyurina jsc siberia airlines monolink group fzco the following entry has been corrected and is still subject to an asset freeze, trust services sanctions and a prohibition on correspondent banking and clearing: ojsc keremet bank 291 financial sanctions notice 7 march 2025 amends the 2019 uk-russia regulations 7 march 2025 the following entries have been removed from the russia financial sanctions regime and are no longer subject to an asset freeze or trust services sanctions: rosbank pjsc active denizcilik ve gemi isletmeciligi anonim sirketi the following entry has been amended on the russia financial sanctions regime and is still subject to an asset freeze, trust services sanction and a prohibition on correspondent banking and clearing: tbank 292 general licence – petrol station payments for united kingdom nationals in kyrgyzstan and tajikistan int/2025/5886860 14 march 2025 under regulation 64 of the russia regulations 14 march 2025 general licence - int/2025/5886860, allows a uk national to purchase petrol from the designated persons(dp) at any petrol station in kyrgyzstan and tajikistan that is either owned by the dp or sells the dp’s petrol, provided that the petrol is for that uk national’s personal vehicle 293 financial sanctions notice 19 march 2025 amends the 2019 uk-russia regulations 19 march 2025 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze or trust services sanctions: farkhad akhmedov the following entries have been corrected and are still subject to an asset freeze and trust services sanctions: mcr global elektronik sanayi ve ticaret ltd sirketi poly technologies, inc 294 financial sanctions notice 19 march 2025 implemented under 2019 belarus (sanctions) (eu exit) regulations 19 march 2025 the following entry has been amended and is still subject to an asset freeze: alexander vasilevich shakutin 295 financial sanctions notice 20 march 2025 amends the 2019 uk-russia regulations 20 march 2025 the following entry has been amended and is still subject to an asset freeze and trust services sanctions: red box energy services pte ltd 296 general licence: humanitarian activity int/2022/1947936 7 july 2022 amended:20 june 202324 march 2025 under regulation 64 of the russia regulations 24 march 2025 general licence int/2022/1947936 was amended to remove rosbank pjsc and tinkoff bank from annex i; and add tbank to annex i 297 general licence – mongolia energy payments int/2022/2085212 15 august 2022 amended 27 july 2023 and 24 march 2025. under regulation 64 of the russia regulations 24 march 2025 general licence int/2022/2085212, was amended such that rosbank pjsc has been removed from the definition of sanctioned banks; and tbank has been added to the definition of sanctioned banks 298 financial sanctions notice 24 march 2025 amends the 2019 uk-russia regulations 24 march 2025 the following entry has been amended and is still subject to an asset freeze and trusts services sanctions: tigran oganesovich khudaverdyan 299 financial sanctions notice 27 march 2025 amends the 2019 uk-russia regulations 27 march 2025 the following entries have been amended and are still subject to an asset freeze and trust service sanctions: 2rivers dmcc 2rivers pte ltd 300 general licence – lithuania rail int/2023/2883496 14 april 2023 updated27 march 2025 under regulation 64 of the russia regulations 27 march 2025 general licence int/2023/2883496, lithuania rail was extended until 23:59 on 13 april 2027 301 general licence – russia: regulatory authorities – prudential supervision, financial stability, protection of consumers or integrity of the uk financial system int/2022/1280976 01 march 2022 amended 24 february 2023, 14 april 2023, and 27 march 2025 uk autonomous sanctions regulations 27 march 2025 general licence int/2022/1280976, regulatory authorities – prudential supervision, financial stability, protection of consumers or integrity of the uk financial system was amended so that it: applies to all persons designated under the uk’s autonomous sanctions regimes listed in annex 1 of the general licence; and is extended indefinitely 302 general licence – bond amendments and restructurings for non-designated persons int/2023/2824812 28 march 2023, 28 march 2025 under regulation 64 of the russia regulations 28 march 2025 general licence int/2023/2824812, bond amendments and restructurings for non-designated persons was extended until 27 march 2026. 303 general licence – london court of international arbitration (lcia) arbitration costs int/2022/1552576 17 october 2022 amended 05 june 2023, 13 november 2023, and 15 december 2023 revoked 28 march 2025. implemented under 2019 belarus (sanctions) (eu exit) regulations 28 march 2025 general licence int/2022/1552576, london court of international arbitration (lcia) arbitration costs was revoked following the issuance of the arbitration costs general licence gl int/2025/5787748. 304 ofsi general licence under the russia regulations and the belarus regulations int/2024/5334756 25 october 2024 amended 28 march 2025 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations 28 march 2025 general licence int/2024/5334756, legal services was amended to clarify: that legal advice and/or representation in dispute resolution is included in the definition of “legal services”; and the reference to ‘owned and controlled’ applies only to companies and not individuals under the definition of “dp”. 305 general licence: arbitration costs int/2025/5787748 28 march 2025 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations 28 march 2025 general licence int/2025/5787748, arbitration costs was issued. this licence allows persons to make payments to arbitration associations and arbitrators to cover fees and expenses for their arbitration services. the general licence also permits arbitrators and arbitration associations to direct payment of, receive and use such payments to cover arbitration costs. 306 financial sanctions notice 14 april 2025 amends the 2019 uk-russia regulations 14 april 2025 the following entries have been amended and are still subject to an asset freeze: niels oscar troost and paramount energy & commodities dmcc 307 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities int/2023/3263556 01 august 2023 amended 23 august 2023 24 april 2025 under regulation 64 of the russia regulations 24 april 2025 the general licence int/2023/3263556 is extended to allow payments and other permitted activities to take place in relation to insolvency proceedings associated with gtlk and subsidiaries. 308 the russia (sanctions) (eu exit) (amendment) regulations 2025 new guidance documents: complying with technology transfer sanctions complying with sectoral software sanctions 24 april 2025 amends the 2019 uk-russia regulations 24 april 2025 effective april 24, 2025, the uk introduced updated trade sanctions on russia under the russia (sanctions) (eu exit) (amendment) regulations 2025. these measures expand export, import, and technology transfer restrictions to curtail russia's military-industrial operations and economic resilience. newly sanctioned items include chemicals, electronics, machinery, and metals, with additional prohibitions on sectoral technology and software transfers, such as industrial design tools and oil and gas-related software. new import bans target helium and synthetic diamonds processed in third countries to close potential revenue streams for russia. these measures closely align with sanctions imposed by allies like the us and eu for maximum impact against russia's war economy. to assist businesses with compliance, the office of financial sanctions implementation (ofsi) has issued two new guidance documents. the first, complying with technology transfer sanctions, outlines rules for managing restricted technologies. the second, complying with sectoral software sanctions, focuses on software transfer restrictions, including intangible formats like downloads and cloud services. these sanctions underline the uk's commitment to supporting ukraine while disrupting russia's ability to sustain its aggression. businesses are urged to review the updated regulations and guidance to ensure full compliance. 309 general licence: membership fees for international organisations int/2025/5855272 21 february 2025 amended 28 april 2025 under regulation 64 of the russia regulations 28 april 2025 general licence int/2025/5855272, membership fees for international organisations was amended to include the international maritime organisation. 310 ofsi general licence under the russia regulations and the belarus regulations int/2025/6160920 28 april 2025 under regulation 64 of the russia regulations and regulation 32 of the belarus regulations. 28 april 2025 general licence int/2025/6160920, legal services was issued. streamlined guidance for legal services under sanctions. the ofsi general licence permits specified payments for legal services to assist designated entities (dp) under the russia & belarus regulations, ensuring compliance with strict conditions. activities must adhere to financial caps, reporting requirements, and restrictions on funds benefiting dps directly. comprehensive record-keeping and adherence to hourly rate limits are non-negotiable. misuse or breaches render the licence invalid, risking penalties. any persons intending to use general licence int/2025/6160920 should consult the copy of the licence for full details of the definitions, permissions, and usage requirements as these do not mirror those of general licences int/2022/2252300, int/2023/2954852, int/2023/3744968, int/2024/4671884 or int/2024/5334756. 311 general licence – integration of credit suisse group ag and ubs group ag int/2025/6135848 28 april 2025 under regulation 64 of the russia regulations 28 april 2025 general licence int/2025/6135848, integration of credit suisse group ag and ubs group ag was issued. the general licence allows the transfer of assets and liabilities as part of the integration of credit suisse group ag into ubs group ag. 312 financial sanctions notice 1 may 2025 amends the 2019 uk-russia regulations 1 may 2025 the following entry has been amended and is still subject to an asset freeze and trust service sanctions: albert kashafovich shigabutdinov 313 financial sanctions notice 9 may 2025 amends the 2019 uk-russia regulations 9 may 2025 uk government has sanctioned 101 ships, 5 individuals, and 4 entities under the russia sanctions regime. further details the uk full list of russia sanctions targets on 9 may 2025 can be accessed here 314 general licence – amsterdam trade bank n.v – winding down, basic needs and insolvency related payments int/2022/1678476 12 may 2022 amended 28 march 2023 and 12 may 2025 under regulation 64 of the russia regulations 12 may 2025 the updated general licence, allows amsterdam trade bank n.v. (atb) to conduct specific activities under the russia (sanctions) (eu exit) regulations 2019. it permits atb to make payments for basic needs, such as employee remuneration, taxes, and supplier payments. additionally, it authorises actions related to insolvency proceedings, including payments and the exercise of rights by insolvency practitioners, provided no funds benefit designated persons under the russia regulations. the licence also facilitates the winding down of transactions involving atb or its subsidiaries, including loan restructuring and closing out positions, with relevant institutions allowed to process these payments. the licence requires atb, its subsidiaries, or involved parties to notify hm treasury within seven days of conducting permitted activities and maintain accurate records for six years. 315 financial sanctions notice 20 may 2025 amends the 2019 uk-russia regulations 20 may 2025 the uk government has sanctioned 20 individuals, 62 entities, and 18 ships under the russia (sanctions) (eu exit) regulations 2019. this package targets russian revenue generating sectors, including energy, communications and financial services, the russian military industrial complex (rmic) and its third country suppliers, and malign actors involved in democratic interference and russia’s information war on ukraine. further details the uk full list of russia sanctions targets on 20 may 2025 can be accessed here. 316 general licence – wind down of positions involving st petersburg currency exchange and non-bank credit organisation joint-stock company petersburg settlement centre 20 may 2025 under regulation 64 of the russia regulations 20 may 2025 general licence int/2025/6275812, wind down of positions involving st petersburg currency exchange and non-bank credit organization joint-stock company petersburg settlement center was issued. the general licence allows for persons to wind down from any transactions involving the designated persons to which that person is a party. any persons intending to use general licence int/2025/6275812 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 317 general licence – deposit insurance agency permitted payments 20 may 2025 under regulation 64 of the russia regulations 20 may 2025 the general licence int/2025/6279615, deposit insurance agency permitted payments was issued. the general licence allows for persons to make insurance premiums payments to the deposit insurance agency. any persons intending to use general licence int/2025/6279615 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 318 general licence – russia designated persons – charities and interim managers and trustees 30 may 2022 amended 28 march 2023 and 21 may 2025 under regulation 64 of the russia regulations 21 may 2025 the general licence int/2022/1834876 was extended until 23:59 on 30th may 2028. any persons intending to use general licence int/2022/1834876 should consult the copy of the licence for full details of the permissions and usage requirements. 319 general licence - gtlk companies and their subsidiaries – insolvency related payments and activities int/2023/3263556 01 august 2023 amended 23 august 2023, 24 april 2025, 12 june 2025, and 13 june 2025 under regulation 64 of the russia regulations 13 june 2025 ofsi general licence int/2023/3263556, gtlk companies and their subsidiaries – insolvency related payments and activities amended on 13 june 2025, the general licence int/2023/3263556 was amended to: add regulation 18a to the regulations that are exempt under the general licence; add definitions for notes, noteholders, trustee, relevant non-uk institution, uk prohibited persons and uk prohibited persons account; make it clear in permission 4.2 that any funds made available to dps must be held in a frozen account and any economic resources made available must be treated as frozen; add permission 4.3 which states that financial services for foreign exchange reserve and asset management must not be provided to a uk prohibited person unless any resulting payments are credited to a uk prohibited person’s account; make corresponding clarificatory changes to permission 5, the notification requirement and the record-keeping requirement; and add a new reporting requirement. 320 financial sanctions notice 13 june 2025 amends the 2019 uk-russia regulations 13 june 2025 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze: aleksey leonidovich fisun. 321 financial sanctions notice 17 june 2025 amends the 2019 uk-russia regulations 17 june 2025 uk government has sanctioned 4 individuals, 6 entities, and 20 ships under the russia (sanctions) (eu exit) regulations 2019. 322 financial sanctions notice 26 june 2025 amends the 2019 uk-russia regulations 26 june 2025 16 entries have been amended on the consolidated list and remain subject to an asset freeze and trust services sanctions. further information can be found in the annex to this notice, here. 323 general licence: russian oil exempt projects int/2025/5635700 10 january 2025 amended 27 june 2025 under regulation 64 of the russia regulations 27 june 2025 on the 27 june 2025, the date of expiration of the sakhalin-2 project was extended to 28 june 2026. any persons intending to use general licence int/2025/5635700 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. ofsi has also updated the associated publication notice. 324 general licence – oil price cap: exempt projects and countries int/2022/2470156 4 december 2022 amended on 05 january 2023, 14 september 2023, 28 june 2024, and 27 june 2025 under regulation 64 of the russia regulations 27 june 2025 on 27 june 2025, the office of financial sanctions implementation updated the oil price cap general licence: exempt projects and countries – int/2022/2470156– to extend the sakhalin-2 project expiration date to the 28 june 2026. ofsi has also updated the associated publication notice. 325 financial sanctions notice 01 july 2025 amends the 2019 uk-russia regulations 01 july 2025 the following entries have been amended and are still subject to an asset freeze and trust services sanctions: yegor yurievich karasev anatoliy moiseevich cherner the main directorate of deep-sea research of the ministry of defence of the russian federation. 326 general licence: non-designated third-party brokerage accounts held at designated brokerage firms (brokerage accounts) int/2025/6641960 18 july 2025 under regulation 64 of the russia regulations and regulation 32 of the republic of belarus regulations 18 july 2025 the general licence int/2025/6641960 was issued under the russia and the belarus regulations which allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker. this general licence only applies where the only designated party involved is the designated broker. any persons intending to use general licence int/2025/6641960 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 327 financial sanctions notice 18 july 2025 amends the 2019 uk-russia regulations 18 july 2025 the following entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions: african initiative anna sergeevna zamaraeva victor aleksandrovich lukovenko artyom sergeevich kureyev 328 general licence – oil price cap int/2024/4423849 19 february 2024 amended 8 march 2024, 24 may 2024, 29 january 2025, 13 february 2025, and 18 july 2025. under regulation 64 of the russia regulations 18 july 2025 the uk, alongside the eu, is lowering the oil price cap on seaborne russian crude oil from $60 to $47.60, reducing russia’s income and ability to fund its war machine. the lowered oil price cap of $47.60 per barrel comes into effect at 23:01 (bst), tuesday, 2 september 2025. this action forms part of the uk’s ongoing commitment to supporting ukraine in its struggle against russia’s illegal war of aggression. this will apply to all services captured by the oil price cap, including maritime transportation and the provision, directly, or indirectly, of brokering services or financial services or funds, related to the maritime transport of russian crude from a place in russia to third countries or from one third country to another. for any trades with an effective date of contract before 23:01 (bst), tuesday, 2 september 2025 and which are compliant with the existing price cap of $60 per barrel, there will be a wind-down period of 45 days. after the wind-down period of 45 days, ending at 23:01 (bst), friday, 17 october 2025, the lower price cap of $47.60 per barrel takes effect. this measure is necessary to give uk businesses the required time to adjust and ensure the consistent implementation of the price cap by all operators. ofsi has published faqs 154 to 161 today to support industry to adapt to the lower price cap and explain the 45-day wind-down period. market participants must comply with the usual reporting and attestation requirements imposed by the oil price cap general licence. 329 general licence – wind down of positions involving litasco middle east dmcc 21 july 2025 under regulation 64 of the russia regulations 21 july 2025 on 21 july 2025, general licence int/2025/6488808, wind down of positions involving litasco middle east dmcc was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. any persons intending to use general licence int/2025/6488808 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 330 general licence – intershipping services llc wind-down general licence 21 july 2025 under regulation 64 of the russia regulations 21 july 2025 the general licence int/2025/6397444, intershipping services llc wind-down was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. any persons intending to use general licence int/2025/6397444 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. 331 financial sanctions notice 21 july 2025 amends the 2019 uk-russia regulations 21 july 2025 the following entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions: intershipping services llc litasco middle east dmcc the following entries have been amended and are still subject to an asset freeze and trust services sanctions: yegor yurievich karasev ojsc keremet bank 332 general licence: intershipping services llc general licence 21 july 2025 under regulation 64 of the russia regulations 21 july 2025 the general licence int/2025/6403704 was issued. the general licence allows for the continuation of business operations of vessels owned or operated by, or on behalf of, the government of the gabonese republic. 333 financial sanctions notice 20 august 2025 amends the 2019 uk-russia regulations 20 august 2025 uk government has designated the following 5 entities and 3 individuals under the russia sanctions regime: kantemir kaparbekovich chalbayev zhanyshbek uulu nazarbek leonid shumakov altair holding sa cjsc tengricoin grinex llc grinex llc capital bank of central asia old vector llc 334 general licence – continuation of business of evraz plc’s north american subsidiaries 5 may 2022 revoked 3 september 2025 under regulation 64 of the russia regulations n/a ofsi general licence int/2022/1710676 revoked - on 3 september 2025, following the sale of evraz's n. american business, general licence (int/2022/1710676) on the continuation of business of evraz plc’s north american subsidiaries has been revoked. 335 financial sanctions notice 11 september 2025 amends the 2019 uk-russia regulations 11 september 2024 the following entry has been removed from the consolidated list and is no longer subject to an asset freeze and trust service sanctions: ilya borisovich brodskiy 336 financial sanctions notice 12 september 2025 amends the 2019 uk-russia regulations 12 september 2025 the uk government has designated the 27 entities, 3 individuals and specified 70 ships under the russia sanctions regime. for more detailed information, the uk sanctions list from fcdo lists which people, entities and ships are designated or specified under the sanctions and anti-money laundering act 2018, and why, can be accessed here the ofsi consolidated list from hmt provides information relating to asset freeze and investment ban targets across all financial sanctions regimes implemented in the uk, can be found here 337 general licence for int/2025/5886860 - here to see the general licence for int/2025/5635700 - here 10 january 2025 amended 27 june 2025 and 15 october 2025. under regulation 64 of the russia regulations 15 october 2025 on 15 october 2025, the definitions of a dp and a subsidiary in general licences int/2025/5886860 and int/2025/5635700 were amended to include pjsc lukoil oil company and pjsc rosneft oil company following their designation by the uk. 338 general licence – energy entities wind-down general licence int/2025/7538856 15 october 2025 under regulation 64 of the russia regulations 15 october 2025 on 15 october 2025 the general licence int/2025/7538856, energy entities wind-down was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. 339 general licence – russian oil majors wind down int/2025/7539056 15 october 2025 under regulation 64 of the russia regulations 15 october 2025 general licence int/2025/7539056, russian oil majors wind down was issued. the general licence allows for persons to wind down from any transactions involving the designated person to which that person is a party. 340 financial sanctions notice 15 october 2025 amends the 2019 uk-russia regulations 15 october 2025 the uk government has designated the following 34 entities, 5 individuals, and specified the following 51 ships under the russia (sanctions) (eu exit) regulations 2019. 341 general licence – continuation of business of pjsc rosneft oil company’s german named subsidiaries int/2025/7598960 22 october 2025 under regulation 64 of the russia regulations 22 october 2025 on 22 october 2025, the general licence int/2025/7598960 was issued. the general licence allows a person to continue business operations involving the named subsidiaries. any persons intending to use general licence int/2025/7598960 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. ofsi has released faq 169 to accompany this licence regarding if business operations with rosneft deutschland gmbh and rn refining and marketing gmbh continue as normal with regard to uk financial sanctions. 342 general licence – legal services int/2025/7323088 22 october 2025 under uk autonomous sanctions regulations 22 october 2025 the general licence int/2025/7323088 was issued. the general licence allows a uk legal firm or uk counsel who has provided legal advice to a person designated under the uk autonomous sanctions regimes which will take effect following the expiry of legal services general licence int/2024/6160920 on 28 october 2025. any persons intending to use general licence int/2025/7323088 should consult the copy of the licence for full details of the definitions, permissions, and usage requirements as these do not mirror those of general licences int/2022/2252300, int/2023/2954852, int/2023/3744968, int/2024/4671884, int/2024/5334756 or int/2025/6160920. 2 faqs added regarding general licence int/2025/7323088 and 2 faqs withdrawn on 24 october 2025, faqs 170 and 171 were added to the faqs page to address questions around the changes of the upcoming licence int/2025/7323088 and if payments can be made from abroad into the uk. faqs 54 and 76 have been withdrawn. to see the faqs page - here 343 financial sanctions notice 23 october 2025 amends the 2019 uk-russia regulations 23 october 2025 the following entries have been amended and are still subject to an asset freeze and trust service sanctions: aleksandr aleksandrovich shulgin mihajlo perencevic alisher burkhanovich usm holdings limited narmina dadashova 344 general licence – payments made in the year 2022 between non-designated third parties involving designated credit or financial institutions (“correspondent banking - 2022 blocked payments”) int/2024/5394840 5 november 2025 under regulation 64 of the russia regulations 5 november 2025 general licence int/2024/5394840 has been extended to 7 november 2027. the definition of designated credit or financial institution has been amended. the reporting conditions have been amended. within 14 days of the end of each calendar month, a relevant institution must report to hm treasury any relevant payments processed under general licence int/2024/5394840 during that calendar month with details and supporting evidence of the amount(s) processed; the name of the original sender and the original intended recipient; the name on the account at the final institution in the chain of payments to which the funds were processed; the payment route used; and the date on which the funds were processed. 345 financial sanctions notice 19 november 2025 amends the 2019 uk-russia regulations 19 november 2025 the following entry has been added to the uk consolidated list and is now subject to an asset freeze and trust service sanctions: aeza group llc 346 general licence – continuation of business of lukoil bulgaria entities int/2025/7895596 14 november 2025 amended 20 november 2025) under regulation 64 of the russia regulations 20 november 2025 general licence int/2025/7895596 was amended to extend the subsidiaries covered to: lukoil aviation bulgaria eood; and lukoil bunker bulgaria eood. faq 173 was amended to reflect the recent update of general licence int/2025/7895596. the faq can be accessed here 347 general licence – continuation of business of lukoil international entities int/2025/8031092 27 november 2025 under regulation 64 of the russia regulations 27 november 2025 on 27 november 2025, ofsi issued general licence int/2025/8031092 under regulation 64 of the russia (sanctions) (eu exit) regulations 2019 (“the russia regulations”) which allows for the continuation of business operations with the lukoil international entities. new content based on faq 174 has been added to the general licence, to confirm that business operations with lukoil international gmbh can continue as normal with regard to uk financial sanctions. this general licence is valid for 3 months, until 26 february 2026 (and may be extended). 348 financial sanctions notice 28 november 2025 amends the 2019 uk-russia regulations 28 november 2025 the following entry has been amended and is still subject to an asset freeze and trust service sanctions: sergey vladimirovich mikhailov 349 general licence – transactions related to agricultural commodities including the provision of insurance and other services int/2022/2349952 4 november 2022 amended 6 june 2023, 15 december 2023, and 28 november 2025) under regulation 64 of the russia regulations 28 november 2025 transactions related to agricultural commodities including the provision of insurance and other services amended. the general licence int/2022/2349952 was amended to reflect changes to schedule 3e part 2a of the russia regulations (expanding the definition of fertiliser to include those permitted under commodity code 2814 and its subheadings). the revisions relate to the grain and feed trade association receiving funds and economic resources in connection with the provision of services by or on behalf of gafta, including membership, arbitration fees, and training/certification courses, and also provide that insurance providers will not be in contravention of the russia regulations when providing professional indemnity insurance services to gafta.

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CIMA highlights compliance challenges for VASPs in the Cayman Islands

the cayman islands monetary authority (cima) released a desk-based review of the virtual asset service providers (vasps) to assess compliance with the virtual assets (service providers) act (vasp act) and related regulations in november 2025. the review, covering 11 entities, focussed on corporate governance, internal controls, cybersecurity, financial stability, and virtual asset custody arrangements. key findings: corporate governance: gaps in board composition and succession planning were identified. boards lacked diversity and independent directors, contrary to regulatory requirements. internal controls: deficiencies in business continuity planning, internal audits, and complaints handling were noted. many entities lacked comprehensive policies and regular reviews. cybersecurity: weaknesses included inadequate governance, risk management, and data protection measures. many entities failed to conduct regular audits or implement robust cybersecurity frameworks. virtual asset custody: policies for managing virtual asset custody and private keys were insufficient. over 80 per cent of entities had not conducted independent audits of custody platforms. recommendations: strengthen governance by ensuring board diversity and formal succession plans. enhance internal controls, including business continuity plans and regular audits. improve cybersecurity frameworks, conduct regular risk assessments, and secure insurance against cyber risks. develop robust policies for virtual asset custody, including independent audits and client disclosures. regulatory reminders: vasps must promptly notify cima of changes in key personnel, cybersecurity incidents, or operational changes. compliance with the vasp act, aml regulations, and other legal obligations is critical. for more information cima’s desk-based review can be found here

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Important update for BVI Registered Agents: Economic Substance filing transition

on 20 november 2025, the british virgin islands international tax authority (ita) announced that economic substance (es) reporting obligations will transition from the beneficial ownership secure search system (bosss) to the virtual integrated registry regulatory general information network (virrgin) portal. the ita has confirmed that the new virrgin es filing portal is in its final stages of preparation and will be deployed for filings due in 2026. key points to note: final bosss filings: filings due in december 2025, which relate to financial periods ending in july 2025, are expected to be the last conducted via the boss portal. new virrgin filings: filings for financial periods ending after july 2025 will be made in the new virrgin es portal, which is anticipated to be available for use in 2026. action required: registered agents with es information ready before the end of december are strongly encouraged to file as early as possible to mitigate any potential disruption during the transition period. final dates for the boss portal closure and the virrgin portal launch will be confirmed by the ita shortly. we advise all affected parties to be aware of this transition. need support? for further guidance, the harneys team remains available to assist with navigating the transition and related es compliance considerations.

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EBA Report 2025: Strengthening crypto oversight to combat financial crime

on 9 october 2025, the european banking authority (eba) released a report addressing money laundering (ml) and terrorist financing (tf) risks in the crypto-asset sector. here is a concise summary of the key points: evolving risks in crypto the crypto sector’s dynamism is rapidly transforming the financial landscape; however, this also makes it a prime target to ml/tf risks. key channels of exposure include: exploitation of regulatory gaps by crypto firms, often engaged in "forum shopping" or misuse of exemptions like reverse solicitation. weak governance, opaque beneficial ownership structures and inadequate aml/cft measures. high-risk exposure through decentralised finance (defi) platforms, which were often identified as entry and exit points for illicit funds. enhanced framework insufficient without effective implementation the report welcomes the introduction of further safeguards through the eu's markets in crypto-assets regulation (mica) and amendments to the eu anti-money laundering directives (amld), including: unified authorisation and passporting regime accompanied by transparency requirements, and stronger governance standards. the empowerment of competent authorities to enforce compliance, monitor unauthorised activities and ensure effective implementation of these frameworks. public registers for authorised crypto-asset service providers (casps) and consumer outreach campaigns aim to improve transparency and protect users from unauthorised operators. however, the report stresses the need for effective implementation of the regimes by the national competent authorities of eu member states and issues a number of supervisory recommendations, including: upholding cross-border cooperation and information-sharing among authorities to close regulatory gaps. monitoring linked entities and ensure transparency in ownership structures to prevent misuse of complex arrangements. addressing legacy compliance issues before granting authorisations under mica. leveraging advanced tools like blockchain forensics, supervisory technology (suptech) solutions and public-private dialogue to stay ahead of emerging risks. ensuring effective implementation of the central contact point (ccp) mechanism to enhance oversight of cross-border entities. adopt innovative tools and techniques such as surveys on market exposure to specific casps raising ml/tf concerns. the report concludes that supervisors must remain agile and informed about evolving risks, including those linked to new technologies, products and geopolitical developments. continuous training, risk assessments and collaboration with private sector stakeholders are critical to addressing these challenges. eba’s press release can be found here and the report here.

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Bermuda's Beneficial Ownership Act 2025: A legal summary

bermuda enacted the beneficial ownership act 2025 (the act), a significant legislative reform designed to consolidate and enhance the jurisdiction's framework for corporate transparency. pursuant to the beneficial ownership act 2025 commencement day notice 2025, the act is in force as of 3 november 2025. this legislation aligns bermuda with revised international standards set by the financial action task force (fatf) and introduces fundamental changes to compliance obligations for legal persons operating in the jurisdiction. for businesses and legal professionals, understanding these changes is paramount. this summary guides you through the act's most critical updates, including the transfer of the central register, new verification duties, expanded definitions and the implications for legal entities in bermuda. key objectives and legal framework the beneficial ownership act 2025 was introduced with several strategic goals. it aims to: consolidate the legal framework: the act unifies multiple pieces of legislation governing beneficial ownership into a single, streamlined statute. it repeals and replaces the previous fragmented regime found across the companies act 1981, limited liability company act 2016, and various partnership acts. align with fatf standards: it addresses key recommendations from the caribbean financial action task force (cfatf) and ensures bermuda's framework meets the latest international standards on transparency and anti-money laundering (aml). enhance regulatory oversight: the act transfers responsibility for the central register from the bermuda monetary authority (bma) to the registrar of companies (roc), creating a single, authoritative body for managing beneficial ownership information. to support this new framework, the beneficial ownership (consequential amendments) order 2025 makes necessary changes to related laws, including the companies act 1981, the economic substance act 2018, and the exchange control act 1972, ensuring a cohesive regulatory environment. changes introduced by the act the legislation brings about several pivotal changes that all legal persons in bermuda must understand. expanded scope and reduced exemptions perhaps the most significant change is the expansion of the act's scope. the new regime applies to all "legal persons," which includes companies, limited liability companies and all forms of partnerships (exempted, limited and overseas). critically, many previous exemptions have been removed. under the old framework, entities like certain financial institutions and permit companies were exempt. now, the only exemption applies to legal persons whose shares are listed on the bermuda stock exchange or another appointed stock exchange, along with their direct subsidiaries. this means a large number of entities previously out of scope must now comply with the new beneficial ownership requirements. all such "in-scope entities" must establish and maintain a beneficial ownership register. transfer of the central register to the roc to streamline oversight, responsibility for bermuda's central register has been transferred from the bma to the roc. the roc will now manage the collection, maintenance and security of all beneficial ownership data through a new, dedicated electronic portal. approval for new beneficial owners will now be handled by the roc, a key change for non-regulated entities. however, existing beneficial owners approved under prior laws will not need to seek new approval. new verification and information requirements the act places a stronger emphasis on the accuracy and verification of data. section 2 of the act defines key terms for data quality: adequate: information sufficient to identify registrable persons and the means by which control is exercised. accurate: information that has been verified against reliable, independent sources. current: information that is up-to-date and reflects the latest changes. in-scope entities now have a legal duty to take "reasonable measures" to verify the identity of their beneficial owners using independent source documents and must maintain records of these verification measures. the minimum required information has also expanded to include details from a valid government-issued id, such as the number, country of issue and expiry date. revised definition of "beneficial owner" the definition of a "beneficial owner" has been updated to align more closely with fatf terminology, focussing on "ultimate effective control." an individual is considered a beneficial owner if they meet one of the following conditions: own or control 25 per cent or more of the shares, voting rights or partnership interests. exercise ultimate effective authority over the governance of the legal person. exercise control through other means. if no individual meets these conditions, the entity must identify the senior manager (eg, ceo, managing director) as the beneficial owner. enforcement, penalties and dispute resolution the act introduces robust mechanisms for enforcement and clarifies the roles of the roc and the courts. the role of the court sections 13 and 14 of the act empower the supreme court of bermuda to handle disputes and rectify registers. where a bona fide legal dispute over beneficial ownership is being adjudicated, no changes can be made to the register without a court order. any person aggrieved by their inclusion or omission from a register may apply to the court for rectification. penalties for non-compliance compliance is enforced through the registrar of companies (compliance measures) act 2017. failure to adhere to the act's provisions can result in significant penalties. for instance, knowingly or recklessly disclosing information from the central register without the roc's consent can lead to fines of up to $100,000 and two years’ imprisonment on summary conviction, or up to $250,000 and five years’ imprisonment on indictment. access to the central register another key feature of the act is the provision for expanded access to the central register. while the register is not public, access may be granted to specific parties for legitimate purposes, including: competent authorities: the bma and other statutory bodies can access data to perform their functions. obliged entities: financial institutions and designated non-financial businesses can access the register to conduct customer due diligence (cdd). notably, section 18(3) of the act grants the registrar the authority to restrict or prohibit the disclosure of information as deemed appropriate, providing a safeguard in circumstances where a beneficial owner may be at risk of harm. bermuda’s beneficial ownership act 2025 can be found here the beneficial ownership act 2025 commencement day notice here beneficial ownership (consequential amendments) order 2025 can be accessed here

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Upcoming changes to financial services fees in the Cayman Islands

on 7 november 2025, the cayman islands government announced fee adjustments across the financial services sector to ensure proportionality, align with international standards and improve administrative efficiency by simplifying compliance and reducing the administrative burden. these changes will take effect progressively from 1 january 2026. key updates: class “a” banking licence renewal fees: transition to a tiered fee structure based on total assets. phased implementation from 2026 to 2028: less than usd 1 billion: no change ($1m annually). usd 1–3 billion: increases to $1.75m by 2028. usd 3 billion or more: increases to $2.25m by 2028. consolidated annual fees for mutual and private funds: combines existing annual fees into a single payment. annual return fee increases: from $300 to $450 for funds. from $150 to $225 for sub-funds. new annual fee for registered offices of exempted limited partnerships (elps): introduction of a $100 annual fee for elp-registered offices. payable by licensed service providers. class b(i), (ii), and (iii) insurer fees: 10 per cent increase in annual fees across all categories. implementation timeline: 2026–2028: tiered banking licence fees. 2026: all other changes. industry stakeholders are advised to assess these changes and make necessary preparations for their implementation. the industry advisory can be found here

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BVI entities: 30 November 2025 frozen assets reporting deadline approaching

the british virgin islands (bvi) introduced its first annual frozen assets reporting (far) process for 2025, aligning with the virgin islands’ sanctions framework and uk sanctions legislation. bvi entities, that are in scope for this reporting, are reminded of their mandatory statutory obligation to report frozen assets linked to uk-designated persons. key reporting details for bvi: who must report: any bvi person or entity holding, controlling or managing funds or economic resources of uk-designated persons. this includes assets located both inside and outside the bvi. note: assets frozen solely under other sanctions regimes (eg, ofac) are excluded. reference date: close of business on 30 september 2025. submission deadline: reports must be submitted by 30 november 2025. how to file: persons to whom this reporting is relevant are required to report the details of the frozen assets by competing and submitting to the sanctions unit within the attorney general’s chambers the relevant parts of the compliance reporting form using parts a and c (frozen assets) and annex ii, here or by using the dedicated frozen assets reporting template, here circulated by the sanctions unit with the notice of this reporting obligation. a link to the sanctions unit notice dated 20 november 2025 can be found here. submit completed forms to the sanctions unit, attorney general’s chambers via email: sanctions@gov.vg. refer to the virgin islands sanctions guidelines for detailed instructions on freezing obligations, reporting standards, and required supporting information:sanctions guidelines (revised december 2024)compliance reporting form key considerations: reporting frozen assets is a statutory requirement under bvi sanctions legislation. failure to report or submitting inaccurate reports may constitute an offence. entities should maintain robust screening processes and promptly freeze any funds or economic resources of designated persons. stakeholders must: review their client base and accounts for any exposure to uk-designated persons. confirm that asset-freezing controls are operating effectively. prepare the report: start gathering the data as of 30 september 2025 and submit the required report by 30 november 2025. seek guidance if you are unsure about your reporting scope or obligations. if you need assistance to determine if your bvi entity is in scope of this reporting requirement, please do feel free to get in touch with us. stay compliant and ensure your reports are submitted on time to avoid penalties. post updated: 28 november 2025

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EBA Report reveals progress in AML/CFT oversight across the EU

on 8 october 2025, the european banking authority (eba) released a comprehensive report summarising six years of reviews of the approach of national competent authorities on anti-money laundering (aml) and countering the financing of terrorism (cft) supervision across eu/eea member states. the report highlights significant progress in the following areas: aml/cft supervision notably, 81 per cent of national competent authorities (ncas) have revised their supervisory manuals in line with eba standards. key measures include providing guidance on how to assess the adequacy and effectiveness of obliged entities’ aml/cft systems and controls, as well as enhancing customer sampling policies. an impressive 90 per cent of ncas have enhanced their strategic use of supervisory tools, increasing both the intrusiveness and impact of their oversight. key measures include the use of external parties to carry out specific supervisory tasks and introducing new supervisory tools. cooperation domestic cooperation has strengthened, with significant advances in formalising arrangements with financial intelligence units (fius) and tax authorities, though some authorities are still working to improve practical information-sharing. on the international front, 55 per cent of ncas have fully or largely addressed any findings on the effectiveness of the bilateral cooperation with their counterparts in other jurisdictions. aml/cft colleges now play a central role in facilitating cross-border collaboration and even though challenges persist when cooperating with third-country authorities, improvements have been recorded. despite ongoing resource constraints and a complex geopolitical landscape, overall effectiveness has improved. the new anti-money laundering authority (amla) is poised to build on this progress, addressing lingering challenges and driving standardisation of aml/cft supervision across the eu. eba’s press release can be found here and the final report here

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BVI entities: 2025 frozen assets reporting deadline approaching (end of November)

the british virgin islands (bvi) introduced its first annual frozen assets reporting (far) process for 2025, aligning with the virgin islands’ sanctions framework and uk sanctions legislation. while no standalone notice has been issued, entities in the bvi are reminded of their statutory obligation to report frozen assets linked to uk-designated persons. key reporting details for bvi: who must report: any person or entity in the bvi holding, controlling or managing funds or economic resources of uk-designated persons. this includes assets located both inside and outside the bvi.note: assets frozen solely under other sanctions regimes (eg, ofac) are excluded. reference date: close of business on 30 september 2025. submission deadline: reports must be submitted by 30 november 2025. how to file: use the bvi compliance reporting form, which includes a dedicated section for frozen assets. submit completed forms to the sanctions unit, attorney general’s chambers via email: sanctions@gov.vg. refer to the virgin islands sanctions guidelines for detailed instructions on freezing obligations, reporting standards, and required supporting information: sanctions guidelines (revised december 2024) compliance reporting form uk template reporting form key considerations: reporting frozen assets is a statutory requirement under bvi sanctions legislation. failure to report or submitting inaccurate reports may constitute an offence. entities should maintain robust screening processes and promptly freeze any funds or economic resources of designated persons. stakeholders must: review their client base and accounts for any exposure to uk-designated persons. confirm that asset-freezing controls are operating effectively. prepare the report: start gathering the data as of 30 september 2025 and submit the required report by 30 november 2025. seek guidance if you are unsure about your reporting scope or obligations. stay compliant and ensure your reports are submitted on time to avoid penalties.

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UK trade sanctions breach detection: How due diligence makes a difference

on 13 october 2025, the uk office of trade sanctions implementation (otsi) shared a compelling case study that underscores the importance of due diligence in preventing breaches of uk trade sanctions. the case involves a multinational bank's uk branch, which successfully identified and stopped payments linked to sanctioned goods originating from russia. this proactive action not only ensured compliance with the russia (sanctions) (eu exit) regulations 2019 but also safeguarded the bank's reputation and business interests. case overview between april and june 2025, the uk branch of the bank flagged several transactions involving the trade of a sanctioned product from russia to a third country. under uk sanctions law, it is illegal for uk persons or entities to facilitate the movement of such goods, including providing financial services like payment processing. the bank's internal account screening system detected the payments, prompting enhanced due diligence checks. as a result, the payments were declined, and the activity was reported to otsi using their online reporting tool. otsi's investigation confirmed that the uk branch had not breached sanctions, as the payments were never processed. this case highlights the effectiveness of internal compliance systems in identifying and mitigating risks before they escalate. key lessons for businesses understand sanctions regulations: businesses, especially in the financial sector, must be well-versed in how uk sanctions impact their operations. this includes understanding the specific obligations for uk branches of multinational corporations. adopt a risk-based approach: conduct enhanced due diligence on high-risk clients and transactions, particularly those involving jurisdictions with a history of sanctions evasion. regularly update these checks to reflect changes in transactional patterns. strengthen internal screening: develop robust internal systems to flag and review transactions that may breach sanctions regulations. this includes implementing safeguards to stop payments before they are processed. mandatory and voluntary reporting: regulated sectors must comply with mandatory reporting requirements, while other businesses can benefit from making voluntary disclosures to otsi. prompt reporting can mitigate potential penalties and demonstrate a commitment to compliance. learn from the financial sector: businesses outside the financial industry can adopt similar compliance practices to enhance their sanctions awareness and counter evasion tactics. leverage otsi resources: utilise tools like otsi's online reporting system to report suspected breaches or near misses. this not only aids compliance but also contributes to global efforts to prevent sanctions evasion. this case study serves as a reminder of the global nature of trade sanctions and the need for international cooperation. otsi's ability to share information with counterparts in other jurisdictions ensures a coordinated approach to investigating and preventing sanctions breaches. for businesses, it reinforces the importance of maintaining strong compliance frameworks to navigate the complexities of international trade regulations. by taking proactive measures, businesses can protect themselves from legal and reputational risks while contributing to the broader goal of upholding international sanctions regimes. the official article can be accessed here

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The Virgin Islands prepares for CRS 2.0 and CARF implementation

on 23 october 2025, the bvi international tax authority (ita) published a notice to advise that the organisation for economic co-operation and development (oecd) introduced significant updates to the common reporting standards (crs), now referred to as crs 2.0, alongside the development of the crypto-asset reporting framework (carf). these initiatives aim to improve global tax transparency and address emerging challenges in financial markets. the bvi will implement crs 2.0 starting 1 january 2026, with reporting deadlines set for may 2027. virgin islands financial institutions will need to collect the new information during 2026 to be reported to the ita by may 2027. carf implementation is scheduled for 2028. key updates in crs 2.0: inclusion of digital products: financial accounts now encompass electronic money products and central bank digital currencies (cbdcs). expanded definition of financial assets: relevant crypto-assets, derivatives and indirect crypto-asset investments are now included. due diligence: strengthened procedures mandate validation of self-certifications for account holders and controlling persons. clarified reporting entities: e-money providers and accounts holding cbdcs are now explicitly covered. improved reporting quality: updates include expanded reporting requirements, reliance on aml/kyc procedures and exceptional due diligence for cases lacking valid self-certifications. oecd’s guide highlights: the crs, introduced in 2014, was designed to promote tax transparency for financial accounts held abroad. over 100 jurisdictions have implemented the crs, but evolving financial markets, including the rise of crypto-assets, necessitated a comprehensive review. this review, conducted by the oecd in collaboration with g20 countries, resulted in two major outcomes: crypto-asset reporting framework (carf): a global tax transparency framework for the automatic exchange of tax information on crypto-asset transactions. carf addresses the unique challenges posed by crypto-assets, which often operate outside traditional financial systems, reducing tax administrations' visibility on tax relevant activities. carf includes: rules for domestic implementation, covering the scope of crypto-assets, reporting entities, transactions and due diligence procedures. a multilateral competent authority agreement for information exchange. an xml schema for standardised reporting and exchange of information between tax administrations. amendments to the crs: updates to include new financial assets, products and intermediaries, while avoiding duplicative reporting with carf. enhancements include: detailed reporting requirements. strengthened due diligence procedures. new categories for non-reporting financial institutions (e.g., genuine non-profit organisations) and excluded accounts (e.g., capital contribution accounts). additional guidance to improve consistency in crs application. next steps for financial institutions: financial institutions in the bvi must familiarise themselves with these changes to ensure compliance with the revised reporting standards. for further details, the bvi ita’s notice can be found here

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UK’s latest Russia sanctions: Impacts and compliance takeaways

on 15 october 2025, the uk intensified its sanctions against russia, targeting key sectors of its economy in response to the ongoing conflict in ukraine. these measures aim to undermine russia's ability to fund its military operations while signalling the uk's commitment to global security and peace. a breakdown of the latest developments is as follows: key highlights of the new sanctions targeting russian oil giants: the uk has sanctioned rosneft and lukoil, russia's two largest oil companies, which collectively export 3.1 million barrels of oil daily. this follows earlier sanctions on gazprom neft and surgutneftegas. these measures aim to cut off significant revenue streams for russia, which heavily relies on oil exports for funding. crackdown on the "shadow fleet": 44 tankers involved in transporting russian oil, along with four oil terminals in china and an indian refinery (nayara energy ltd), have been sanctioned. seven specialised lng tankers and the chinese beihai lng terminal, linked to arctic lng2, a disrupted russian project, are also targeted. broader economic measures: this package is aimed at tightening enforcement of existing restrictions and at neutralising circumvention channels in global oil flows — which is why the uk has targeted the “shadow fleet”, relevant terminals and lng infrastructure. sanctions on businesses supplying critical electronics for russian drones and missiles, spanning countries including thailand, singapore, turkey, and china. financial impact: since february 2022, uk sanctions have frozen £28.7 billion of russian assets (as of may 2025) under the uk’s russia sanctions regime, showcasing the uk's role in enforcing financial restrictions. legal services general licence (gl) expansion: ofsi in the uk clarified the scope of the new gl, effective 29 october 2025 which requires reporting payments to ofsi within 14 days and runs (as published) until 28 april 2026. the gl now applies to most uk autonomous sanctions regimes, expanding beyond its previous focus on russia and belarus. the gl can be found here and ofsi’s publication notice here. law firms, legal advisors, counsel, and providers of expenses can receive payments from designated persons under these regimes, provided all conditions of the licence are met. payments are permitted from abroad into uk bank accounts or certain non-uk accounts, but the gl does not allow payments to or for the benefit of individuals designated under united nations sanctions. jurisdictional extent: uk sanctions measures apply in the uk overseas territories (ukots) (through orders in council) and implemented in the crown dependencies (cds) through their own domestic legislation, which aligns with uk sanctions policy. the changes referred to above automatically apply in the ukots and in practice in the cds with the exception of the gl which applies only in the uk. the uk's latest sanctions against russia represent a significant escalation in the economic and political pressure on the kremlin. while these measures are expected to have an impact on russia's economy, they also reinforce the uk's commitment to supporting ukraine and upholding international law. please see futher: uk press release dated 15 october 2025 available: here policy paper on “list of russia sanctions targets” dated 15 october 2025” - here general licence int/2025/7323088 (legal services) – here

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Cayman Islands frozen assets reporting 2025: Key information

on 6 november 2025, the cayman islands financial reporting authority (fra) published a notice requiring all entities holding frozen assets linked to designated persons (dps) under uk sanctions law to submit an annual report. this measure is part of global efforts to combat financial crime, terrorism financing and human rights abuses. here is what you need to know: what you need to do who must report: entities holding funds or economic resources owned, held or controlled by dps listed under uk sanctions law. exemptions: no need to submit a report if no such assets are held. deadline: submit reports by 30 november 2025, detailing assets as of 30 september 2025. going forward, there is now an ongoing obligation to make such reports. reporting requirements: report all funds or economic resources, whether held in the cayman islands and overseas that are frozen under uk sanctions. include asset types, values (in usd if applicable) and account details. use the official frozen assets reporting template available on the fra website. ongoing compliance regularly check for accounts linked to dps. freeze and report newly identified assets immediately. avoid dealing with or making assets available to dps unless licensed. submission details email completed forms to financialsanctions@gov.ky. why this is happening global compliance: the cayman islands implements uk sanctions under the sanctions and anti-money laundering act 2018. these sanctions target individuals, entities and regimes involved in activities like terrorism, corruption and human rights violations. transparency and accountability: reporting ensures that funds and economic resources linked to dps are identified, frozen and not used to support illicit activities. failure to comply is an offence and may result in penalties. for more information, the official notice can be accessed here and the frozen assets reporting template here.

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