on 8 july 2025, the european commission adopted measures to further enhance the european union's framework for combating money laundering and terrorist financing. these legislative developments introduce a pivotal review clause into the amendment adopted on 10 june 2025, which updated the high-risk third-country listings specified under delegated regulation (eu) 2016/1675. background and rationale delegated regulation (eu) 2016/1675, established in 2016, serves to identify high risk-third countries posing substantial threats to the eu financial system due to deficiencies in anti-money laundering and countering the financing of terrorism (aml/cft) controls. the recent amendment, adopted on 10 june 2025, aligned the list of high-risk jurisdictions with the recommendations of the financial action task force (fatf). notably, even jurisdictions which are not publicly identified to be subject to increased monitoring and actions, may still present a risk for the eu financial system. recognising this gap, the european commission intends to take specific actions to protect the integrity of the eu financial system and assess whether such countries fall under the category of high-risk third countries. key components the newly inserted article 1a of the new delegated regulation adopting those measures requires the european commission to complete a comprehensive review of such jurisdictions by 31 december 2025. specifically, it targets countries outside the fatf's increased monitoring or call-to-action lists whose suspended membership indicates heightened systemic risks. the findings of this review could lead to further amendments to the annex of delegated regulation (eu) 2016/1675, thereby refining the eu’s approach to identifying and mitigating financial vulnerabilities associated with these jurisdictions. next steps in the process before these new measures come into effect, they will undergo scrutiny by both the european parliament and the council of the european union. if no objections are raised, the delegated regulation adopting those measures will be published in the official journal of the european union and will take effect 20 days thereafter. the adopted delegated regulation can be found here

the cayman islands monetary authority (cima) has introduced a limited-time non-compliant directors' amnesty scheme, running from 16 september to 15 october 2025. this initiative allows eligible registered directors with over two years of unpaid fees (as of 31 august 2025) to settle outstanding annual fees and penalties at a discounted rate. the scheme aims to promote good governance and regulatory compliance while offering directors a chance to return to good standing. however, directors under investigation or enforcement action are not eligible. eligible directors have been contacted via email and can apply through the directors’ gateway portal starting 16 september 2025. for inquiries, email amnesty@cima.ky. act now, this opportunity is only available for 30 days, after which full fees and penalties will apply. cima’s notice can be found here

the cayman islands department for international tax cooperation (ditc) published an industry advisory, to inform that as of 29 august 2025, the cayman islands' country-by-country reporting (cbcr) framework is accessible via the ditc portal. multinational enterprise (mne) groups with cayman islands constituent entities (ces) must re-register on the portal by 30 november 2025, to comply with cbcr regulations. key updates: re-registration required: all mne groups must re-register via the ditc portal. instructions will be sent to primary contacts. updated guidelines: revised cbcr guidelines and resources are available on the ditc website. future updates: cbcr reporting functionality will be added to the portal by november 2025. for more information the industry advisory can be found here

on 18 june 2025, cyprus published the “prevention and suppression of money laundering from illegal activities (amendment) (no. 2) law of 2025” (the amending law) in the official gazette of the republic. the amending law focuses on aml compliance matters for crypto-asset service providers (casps), in particular what is known as the “travel rule”. key updates include: alignment with eu directives: the amending law harmonises local aml legislation with eu directive 2015/849 (the eu aml directive) as amended by eu regulation 2023/1113 (the transfer of funds regulation) and relevant recommendations issued by the financial action task force (fatf). definitions update: casps are now included in the definition of a “financial institution”. territorial scope provisions: limited guidance is provided on when obligations under local aml laws arise for non-eu casps servicing clients based in cyprus. risk mitigation measures: introduces stricter due diligence requirements for crypto-asset transactions, including identifying parties involved in transfers to/from self-hosted wallets and applying enhanced due diligence measures. duty to perform cdd on correspondents: cypriot casps must consider whether correspondent casps are licensed for their services and apply enhanced due diligence to their end-users. supervisory authority powers: expands the authority of supervisory bodies to impose sanctions for non-compliance with the transfer of funds regulation. central contact points: mandates the appointment of central contact points for casps which are established in cyprus but do not maintain a branch. these amendments strengthen the legal framework, ensuring effective implementation and compliance with international anti-money laundering and counter-terrorism financing standards. the amending law (only in greek) can be found here

the bvi financial services commission published the presentations from the 2025 meet the regulator forum. the forum focused on beneficial ownership (bo) transparency, stakeholder consultations and policy updates. key takeaways include: international developments: fatf recommendation 24 and eu aml directive 6 emphasise legitimate interest for bo access. stakeholder feedback: concerns over media/ngo access, short objection periods and privacy safeguards. support for exemptions for minors, high-risk individuals and enhanced data protection. policy on bo access: access limited to entities with legitimate interest (e.g., aml/cft purposes). information disclosed: name, birth month/year, nationality and ownership (25%+). strict confidentiality, penalties for misuse and a 12-day access timeline. exemptions: grounds include risks like fraud, national security or public interest. applications processed via the virrgin system. implementation timeline: transitional period: july 2025–march 2026. full regime operational by april 2026. for more detailed information, the 2025 meet the regulator forum presentation can be found here

france, germany and the uk (the e3) have triggered the "snapback" mechanism under un security council resolution 2231, escalating diplomatic pressure on iran regarding its nuclear programme. this decision, announced on 28 august 2025, follows years of escalating iranian non-compliance with the joint comprehensive plan of action (jcpoa). jcpoa: from consensus to breakdown the jcpoa, endorsed in 2015, set strict limits on iran’s nuclear activities in exchange for sanctions relief. key commitments included sharply reducing enriched uranium stockpiles, capping enrichment levels and enabling robust iaea inspections. the agreement began to unravel after the united states’ withdrawal in may 2018, leading iran to systematically breach its obligations from 2019 onwards. iran’s non-compliance the e3 have determined that iran now holds uranium stockpiles beyond permitted levels, deploys advanced centrifuges and blocks iaea inspectors from key sites. further, the abandonment of the additional protocol by iran has eroded transparency, raising proliferation concerns regarding iran’s nuclear intentions. e3’s diplomatic efforts and legal framework the e3 have spent over five years on diplomatic efforts including formal dispute resolution, sustained negotiations and multiple proposals—all ultimately rejected by iran. with the snapback mechanism, any jcpoa participant can notify the security council of significant non-performance, triggering a 30-day countdown. if no new resolution is adopted, previously lifted un sanctions and restrictions automatically reapply. implications of snapback this process places immediate pressure on iran to return to compliance or face renewed comprehensive sanctions, arms embargoes, and other restrictive measures. the path ahead the e3 signal remains open to diplomatic solutions, but the 30-day window could represent the final chance for constructive engagement. iran’s response will determine whether international engagement continues under the jcpoa framework or transitions to comprehensive sanctions enforcement. under the jcpoa, iran remains subject to a lighter touch sanctions regime under the uk and eu sanctions programmes as relevant to its nuclear programme. a comprehensive and distinct regime is in place related to human rights abuses. following snapback, significant and wide-ranging sanctions will be reinstated on iran related to its nuclear programme in both the uk (and uk associated jurisdictions) and the eu. these will be directly relevant to all jurisdictions at harneys. entities with exposure to iran should immediately seek appropriate legal advice as regards next steps regarding sanctions compliance post-snapback. uk’s press release can be found here, france’s news release here and germany’s here

to ensure compliance and transparency, the cayman islands monetary authority (cima) recently published several updates to its regulatory measures. these updates are critical for licensees, private funds and mutual funds operating within the jurisdiction. the categorised updates include: marketing policies: these policies outline the standards and requirements for marketing activities, ensuring compliance with cima's regulatory framework. regulatory policies for licensees: these updates emphasise compliance with advertising and promotional standards for licensees. the list of updates are: corporate services regulatory measures marketingpolicy4_1599579834 marketingpolicyforlicensees_1754331283.pdf trusts regulatory measures marketingpolicy1_1599570685.pdf marketingpolicyforlicensees_1754331375.pdf money services business regulatory measures marketingpolicy2_1599572524.pdf marketingpolicyforlicensees_1754331350.pdf insurance regulatory measures marketingpolicy1_1599569987.pdf marketingpolicyforlicensees_1754331420.pdf securities regulatory measures marketingpolicy5_1599581210.pdf marketingpolicyforlicensees_1754331252.pdf investment funds regulatory measures marketingpolicy6_1599582424.pdf marketingpolicyforlicensees_1754331176.pdf exemption from valuation requirements: cima has updated its regulatory policy regarding exemptions from valuation requirements for registered private funds. exemption policy 1 exemption policy 2 auditor approval policy: a revised policy has been introduced to streamline the approval process for auditors of regulated entities. revised auditor approval policy guidance on licensing mutual funds: cima has issued a statement of guidance to clarify the licensing requirements for mutual funds. statement of guidance

further to our blog post on uk russia sanctions, please find below an updated table of sanctions. item 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 o 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 hese 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 amended 26 june 2023 amended 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 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 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 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. 2024/834) and the russia (sanctions) (eu exit) (amendment) (no. 4) 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 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, 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 under 2710 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 2023 24 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 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 updated 27 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 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 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 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 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 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 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; 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.

the uk overseas territories and crown dependencies have updated their sanctions lists to align with the latest uk measures against russia. financial institutions are required to: evaluate their exposure to newly listed entities, freeze any relevant assets report actions to the reporting authority. failure to comply could result in significant penalties, highlighting the need for prompt action. institutions should review updates frequently to ensure compliance. stay informed by reviewing the updated lists: bvi financial services commission – the latest notice being sanctions circular no. 67 of 2025 of 20 august 2025, here. cayman islands monetary authority – the latest notice dated 28 august 2025, here. bermuda monetary authority – the latest notice dated 21 august 2025, here. jersey financial services commission – the latest notice dated 21 august 2025, here.

on 12 august 2025, the luxembourg tax authorities published a circular (circular l.i.r n°168quater/2) offering guidance on the collective investment vehicle (civ) exemption under the reverse hybrid rules introduced by atad2. these rules, implemented in luxembourg since 2022, aim to address tax mismatches involving reverse hybrid entities (rhes). the civ exemption is designed to exclude certain investment funds from being taxed as rhes, provided they meet specific criteria. key highlights of the circular: eligible funds: investment funds such as undertakings for collective investments (ucis), specialised investment funds (sifs), and reserved alternative investment funds (raifs) automatically qualify for the exemption. other funds may also qualify if they meet the following three criteria: being widely held, maintaining a diversified portfolio of securities and adhering to investor protection regulations. broad investor participation: funds must be marketed to multiple unrelated investors. the circular provides flexibility, allowing exceptions during the launch phase (up to 36 months) or the liquidation phase. in master-feeder structures, the “widely held” criterion is assessed at the feeder fund level. a fund is presumed to meet this criterion if no single investor holds more than 25% of the capital or voting rights. diversified portfolio of securities: the term “securities” is interpreted broadly to include shares, bonds, fund units, deposits and derivatives. a fund is considered diversified if it spreads investments across multiple issuers, with no more than 30% of assets allocated to a single issuer unless justified. the diversification requirements align with those applicable to sifs under luxembourg law. investor protection compliance: funds under the supervision of the luxembourg commission de surveillance du secteur financier (cssf) or managed by authorised alternative investment fund managers (aifms) are presumed to meet this requirement. this circular provides clarity and practical guidance for the application of the civ exemption. by defining eligibility criteria and offering flexibility in certain circumstances, it restores confidence in the exemption’s applicability and ensures greater consistency in the interpretation of luxembourg tax law. this is a significant development for the fund industry, particularly for those managing or investing in luxembourg-based funds. luxembourg’s circular can be found (in french) here

on 25 july 2025, cyprus published a new sanctions law, the criminalisation of violation of restrictive measures law of 2025 (the cvrm law), replaces the current criminal penalties for sanctions violations with a robust framework to determine the criminal offences and penalties for breaches of eu sanctions and restrictive measures, ensuring stricter compliance and accountability. the cvrm law constitutes the final product of cyprus’ implementation of directive (eu) 2024/1226 of 24 april 2024, which seeks to harmonise criminal enforcement of sanctions across the eu. our prior blog on this directive can be found here. key highlights of the cvrm include: scope: the cvrm law applies to violations committed within or outside cyprus, including acts by citizens of cyprus or entities registered in cyprus, as well as offences benefiting businesses operating in cyprus. it also extends to offences committed on ships or aircrafts which are registered in cyprus or having the cypriot flag. offences: criminal offences include: providing funds or resources to sanctioned individuals or entities. failing to freeze funds or economic resources as mandated by eu measures. facilitation of the entry into, or transit through, the territory of a member state by designated natural persons. providing misleading to conceal the fact that a designated person or entity is the ultimate owner of funds or economic resources that should be frozen. circumventing restrictive measures through fraudulent means. conducting prohibited transactions, such as trade or financial services, with sanctioned parties. noncompliance with conditions of licences granted by competent authorities for the conduct of activities which, in the absence of such a licence, would be prohibited. penalties: for individuals: fines up to €100,000 and/or imprisonment up to 5 years, depending on the offence's severity and value. for legal entities: fines up to €40 million or 5% of global turnover, alongside potential revocation of licences, exclusion from public funding or bans on business activities. aggravating factors include offences committed within criminal organisations or by public officials. exemptions: humanitarian assistance and activities supporting basic human needs are explicitly excluded from criminalisation, ensuring that the law does not hinder essential aid efforts. cooperation with relevant persons: the cvrm law mandates close cooperation of the cyprus police with the competent authorities of other member states, with eu bodies such as eurojust, europol and the european public prosecutor's office to combat cross-border sanctions violations effectively. repeal of previous law: the prior cypriot sanctions law of 2016 (law 58 (i) of 2016) has been repealed, with its provisions incorporated into this updated framework. the cvrm law is in force as of the date of gazetting, which is 25 july 2025. the cvrm law strengthens cyprus' commitment to enforcing eu restrictive measures and ensuring humanitarian principles are upheld. the cvrm law, published in the official gazette, can be found here (only in greek)

on 30 july 2025, the bermuda monetary authority (bma) published a discussion paper on the responsible use of artificial intelligence (ai) in bermuda's financial services sector. the paper outlines the transformative potential of ai while emphasising the need for strong governance to mitigate risks. key proposals include: governance & accountability: boards of financial institutions will hold ultimate responsibility for ai oversight, ensuring systems align with regulatory and ethical standards. risk management: a framework is proposed to assess ai risks across dimensions like impact, autonomy and data sensitivity, with proportional oversight based on risk levels. transparency & fairness: institutions must ensure ai systems are explainable, fair and free from bias, with tailored disclosures for stakeholders. global alignment: the bma draws on international regulatory principles to balance innovation with safeguards, ensuring bermuda remains a trusted financial hub. industry input is sought to refine the framework, with a consultation deadline of 30 september 2025. bma’s consultation paper can be found here

effective 27 june 2025, the cayman islands monetary authority (cima) updated its regulatory handbook and enforcement manual. regulatory handbook (vol. 1):enhances policies on external membership and stakeholder engagement, guiding cima’s regulatory and co-operative functions. enforcement manual (vol. 2):consolidates enforcement procedures, including administrative fines, enforcement actions, publication and lost contact (at the relevant regulated entity), to address non-compliance under regulatory acts. access the updated documents here and cima’s notice here

on 24 july 2024, the jersey financial services commission (jfsc) published significant enhancements to the jersey private fund (jpf) regime, set to take effect on 6 august 2025. these updates are designed to strengthen the framework and ensure it remains aligned with the evolving needs of international professional investors. key changes include removal of the 50-offer/investor cap, offering greater flexibility. expansion of the professional investor definition to broaden eligibility. permission for listing jpf interests with jfsc consent. introduction of a streamlined 24-hour authorisation process for applications via registered designated service providers. these enhancements, supported by a new statutory instrument, reaffirm jersey’s commitment to innovation and its position as a leading jurisdiction for bespoke, efficient private fund solutions. the revised jpf guide ensures the regime remains robust, adaptable, and trusted by global investors. resources available: jpf guide track changed jpf guide q&a for jersey private fund (jpf) regime enhancements 2025 the official news release can be found here.

on 9 july 2025, the cyprus securities and exchange commission (cysec) issued circular c721 to clarify the application of section 62(2) of the prevention and suppression of money laundering activities law (the aml law). section 62(2) of the aml law governs the verification of customer and beneficial owner identities. key points: general rule: identity verification must be completed before establishing a business relationship or conducting a transaction. exception: verification may occur during the relationship if: business continuity requires it. money laundering/terrorist financing risks are low. verification is completed as soon as possible after the initial contact. conditions for low-risk assessment: deposits must not exceed €2,000. funds must originate from a bank account in the customer’s name. verification must be finalised within 15 days or the relationship is terminated and funds refunded. refunds: deposits, including profits, must be returned to the originating account if verification is incomplete. losses are deducted. administrative service providers (asps): asps must justify any delay in verification and ensure compliance with section 62. aml manual: obliged entities must document internal procedures to ensure compliance with section 62(2). cysec emphasises the importance of completing identity verification before entering business relationships and urges entities to adopt robust measures to mitigate risks. cysec’s circular c721 can be found here