SanctionsThe UK has responded to the conflict in Ukraine with the following sanctions measures (listed by date, beginning with most recent). With relevant developments, we will update this post on a weekly basis.

Additional jurisdictions we are tracking include: EU, Japan, Republic of Korea and US.

April 22, 2022: The UK Government announced further trade restrictions on a range of Russian Generals and defense firms.

April 14, 2022: The UK Government passed a law banning the import of steel and iron products as well as the export of quantum technologies, advanced materials and luxury goods.

April 13, 2022: UK Foreign Secretary Liz Truss announced 178 new sanctions listings, coordinated with the EU, targeting alleged separatists.

April 8, 2022: The UK Government imposed sanctions targeting the daughters of Russian President Vladimir Putin and Foreign Minister Sergei Lavrov who have been subject to travel bans and asset freezes.

April 6, 2022: The UK Government announced full asset freeze on Sberbank and Credit Bank of Moscow, a halt to all new UK outward investment into Russia as well as an end on all imports of Russian coal and oil by end of 2022. Eight Oligarchs were added to the sanctioned list as well as key strategic industries, such as a ban on imports of iron and steel products.

March 31, 2022: The UK Government announced 14 new sanctions against Russia propagandists and state media.

March 24, 2022: UK Government announced 65 new sanctions targeting strategic industries, banks and business elites.

March 15, 2022: The UK enacted the Economic Crime (Transparency and Enforcement) Act 2022. The UK had been perceived to be slower than the EU and US to sanction individuals in particular.  Part of the reason for this was that the UK post-Brexit sanctions legislation contained safeguards which gave openings for potentially targeted individuals to challenge their designation.  The Economic Crime (Transparency and Enforcement) Act 2022, which went through all stages of primary legislation in a matter of days, is intended to address this, and to bring more transparency to property holdings in the UK.  The main effects of the Act are:

  1. Much greater transparency about the ultimate beneficial ownership of property in the UK
  2. Stronger Unexplained Wealth Order processes
  3. Provision for urgent designation of sanctioned individuals and entities, including the power to include anyone sanctioned by US, EU, Canada, Australia, or any other country as notified by the Government

The UK government added 350 new listings under the Russia sanctions regime and 9 new listings under the Cyber sanctions regime.

The UK government also added 14 new listings under the Russia sanctions regime.

March 11, 2022: Foreign Secretary Liz Truss announced sanctions against 386 members of the Russian Duma for their support for the breakaway Ukrainian regions of Luhansk and Donetsk. The individuals listed are banned from travelling to the UK as well as accessing assets in the UK and doing business in the UK.

Group of Seven (G7) Leaders issued a statement reaffirming their commitment to sanctions on Russia as well as confirming efforts to reduce energy dependency on Russia through means, “[i]n addition to announced plans.” Further, the statement indicated the G7 will work through their national processes to deny Russia Most-Favored-Nation status on certain products. Additionally, the statement noted efforts to prevent Russia from obtaining financing from multilateral financial institutions, including the International Monetary Fund, the World Bank, and the European Bank for Reconstruction and Development.

March 10, 2022: UK government added 7 Russian oligarchs in the sanctions list with a full asset freeze and travel ban.

March 8, 2022: UK government announced the phasing out of Russian oil imports by the end of 2022.

March 4, 2022: The UK parliament announced the Economic Crime (Transparency and Enforcement) Bill in an effort to streamline its sanctions process, allowing ministers to tighten restriction on Russian businesses and wealthy individuals.

March 1, 2022: The UK government enacted new legislation targeting Russia.  The main effects of this legislation are to extend the arms embargo, carried over from the EU 2014 embargo which already prohibited the supply to Russia of (1) arms and military-related services and (2) the sale, supply, transfer or export of dual-use items for military use or to military end-users (exceptions include technology for aeronautics and for the space industry). The expansion of the legislative terms means it now prohibits the export, supply and delivery, making available and transfer of dual-use items to, or for use in, Russia, irrespective of end-user.

Additionally, the legislation serves to prohibit the export, supply and delivery, making available and transfer of critical industry items to, or for use in, Russia and to provide for exceptions from these measures, licensing and enforcement, and the creation of criminal offences.

The government also announced the removal of Russia as a permitted destination for nine Open General Export Licenses (OGELs), and that all existing export licenses and approvals of new licenses were suspended from February 28.

The UK government also imposed a ban on ban Russian ships from UK ports. The ban includes “any vessels owned or operated by anyone connected to Russia” (though the regulation contains a relatively narrow definition of “connected to Russia”). Under the measure, UK authorities also gain new powers to detain Russian vessels.

Additionally, the government implemented additional economic measures, including the prohibition of UK individuals and entities from providing financial services to the Russian Central Bank as well as the Russian Ministry of Finance and the sovereign wealth fund Russian Direct Investment Fund (RDIF). The UK government’s sanctions on RDIF its chief executive, Kirill Dmitriev, means their assets are now frozen and a travel ban is in place for Dmitriev.

February 26, 2022: The European Commission, France, Germany, Italy, the UK, Canada, and the US issued a Joint Announcement on the imposition of further targeted sanctions against Russia, namely through removing Russian banks from the SWIFT banking system and imposing restrictive measures on the Russian Central Bank. Further coordination through a transatlantic task force has been agreed.

February 25, 2022: The UK government announced the assets freeze of President Vladimir Putin and Foreign Minister Sergey Lavrov.

February 24, 2022: UK Foreign Secretary Liz Truss announced sanctions including freezing of Russian bank assets in the UK and sanctions on more than 100 companies and individuals, export control on Russia’s hi-tech and strategic industries and a ban on Russia’s national airline from UK airspace.

The G7 issued a statement affirming their response on severe and coordinated economic and financial sanctions.

Our related publications: 

Additional US, UK and EU Sanctions on Russia (March 2022)

The US, UK, and EU Impose a Series of New Targeted and Territorial Russia-Related Sanctions(February 2022)

Russia Sanctions Update: What Risk Management Steps Can Be Taken Now? (February 2022)

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