UK provisions extensive new sanctions against Russia

Extensive new sanctions that can hit any company or individual that is either benefiting from or giving support to the Russian government have been provisioned by the UK.

On 10th February 2022, The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022 came into force. The regulations amend the designation criteria of The Russia (Sanctions) (EU Exit) Regulations 2019.

The sanctions will come into effect only if Russia invades Ukraine, but the new sanctions dramatically broaden the range of people/entities who might be concerned. The prior sanctions were restricted to those Russians deemed by the UK to be destabilizing Ukraine, or threatening its sovereignty.

Designation criteria now includes those who have been involved in obtaining a benefit from or supporting the Government of Russia, but also the Government of Russia’s affiliated entities and businesses of economic and strategic significance to the Russian government, as well as their owners, directors and trustees

Foreign Secretary Liz Truss said:

The UK is resolute in its support for Ukraine’s sovereignty and right to self-determination.

We urge Russia to de-escalate and choose the path of diplomacy. If Russia persists with its aggression towards Ukraine the UK and its partners will not hesitate to act.

This new sanctions regime is the strongest the UK has ever implemented against Russia. It means the UK can now impose sanctions on Russian businesses and individuals in a wide range of economic and strategically significant sectors, such as the chemical, construction, defense, extractives, transport, electronics, energy, ICT and financial services industries.

The regulations imply the UK could also potentially designate a range of Russian oligarchs residing in the UK, or possessing assets in British Overseas Territories, thereby targeting “dirty money”.

The “government of Russia” is defined as:

-the Presidency of the Russian Federation;
-public bodies and agencies subordinate to the President of the Russian Federation, including the Administration of the President of the Russian Federation;
-the Chairman of the Government of the Russian Federation and the deputies of the Chairman of the Government;
-any Ministry of the Russian Federation;
-any other public body or agency of the Government of the Russian Federation, including the armed forces and law-enforcement organs of the Russian Federation;
-the Central Bank of the Russian Federation


The UK, US and numerous other countries have indicated that they may impose coordinated sanctions and export controls should Russian troops invade Ukraine.

To be closely followed in upcoming days.


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