Overview
On February 22, 2022, UK Prime Minister Boris Johnson announced the designation of five Russian banks and three high net worth individuals under the recently expanded Russia (Sanctions) (EU Exit) Regulations 2019 (see our previous blog post on the UK’s expanded sanctions powers here). The announcement follows the Russian government’s recognition of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) and placement of Russian military forces in those territories for purported peacekeeping operations.
The sanctions target Russian banks and high net worth individuals involved in the destabilization of Ukraine or in obtaining a benefit from, or supporting, the Government of Russia. All three individuals and four of the five banks (with the exception of PJSC Promsvyazbank) already were sanctioned by the United States.
The UK measures, which took effect immediately upon their announcement, impose asset freezes and prohibitions on making funds or economic resources available to – or for the benefit of – designated persons. The designated individuals also are subject to UK travel bans.
The five Russian banks targeted are:
- Bank Rossiya;
- Black Sea Bank for Development and Reconstruction;
- JSC Genbank;
- IS Bank; and
- PJSC Promsvyazbank.
- Gennadiy Timchenko;
- Boris Rotenberg; and
- Igor Rotenberg.
- individuals and legal entities who are within, or undertake activities within, the UK’s territory must comply with the newly imposed measures; and
- UK nationals and legal entities established under UK law, including their branches, must also comply with the measures irrespective of where their activities take place.
- sanction those members of the Russian Duma and Federation Council who voted to recognize the independence of the so-called DNR and LNR;
- extend the territorial sanctions imposed on Crimea to non-government controlled territory in the so-called DNR and LNR over the coming weeks, preventing UK individuals and businesses from dealing with these territories until they are returned to Ukrainian control; and
- implement a wide ranging set of sanctions measures targeting the Russian financial sector and trade in the event of further aggressive acts by Russia against Ukraine. As part of this package of measures the UK will shortly introduce legislation to prevent Russia from issuing sovereign debt on UK markets should Russia not de-escalate.