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UK-Russia Sanctions Update 17 March 2022


10 MARCH 2022

The UK Government announced the following asset-freeze designations:

  • Roman Arkadyevich Abramovich
  • Igor Ivanovich Sechin
  • Oleg Vladimirovich Deripaska
  • Dmitri Alekseevich Lebedev
  • Alexei Borisovich Miller
  • Andrei Leonidovich Kostin
  • Nikolai Petrovich Tokarev

They are identified as prominent Russian businesspeople connected with companies associated with the Russian Government, and/or involved in obtaining a benefit from or supporting the Government of Russia.

15 MARCH 2022

Economic Crime (Transparency and Enforcement) Act – this new Act enables the UK Government to move more quickly to impose sanctions against Russian persons already designated by other sanctioning authorities.

In accordance with the new powers, on 15 March 2022 the UK designated 12 individuals and 2 entities to the Consolidated List. The entities are Rosneft Aero and JSC Zelenodolsk Shipyard. In the case of all 14 designations, they mirror previous designations made by the EU.

Also on 15 March 2022, the UK added 350 entries to the consolidated list under the Russia regime, and 9 entries have been added under the Cyber regime. Amongst the 350 are all members of the Federation Council of the Russian, and senior officials/associates of the Russian Government again mirroring previous designations made by the EU and others. The 9 entries under the Cyber regime include 8 individuals and 1 entity.

A new Register of Overseas Entities is to be created under the Act. This will require those behind foreign companies which own UK property to reveal their identities. Entities who refuse to reveal their ‘beneficial owner’ will face restrictions on selling the property and expose them to fines of up to £2,500 per day or up to 5 years in prison.

Reforms to Unexplained Wealth Orders (UWOs) are also to be implemented to remove barriers to their use, increase the time available to enforcement agencies to review material provided in response to a UWO and shield them from exposure to legal costs if they act reasonably in a case that is ultimately unsuccessful.