The Office of Financial Sanctions Implementation has published updated guidance on the Russia (Sanctions) (EU Exit) Regulations 2019 that specifically addresses financial and investment restrictions. The Russia Guidance, published on June 16, 2021, should be considered supplementary to, and not a replacement for, OFSI’s General Guidance on Financial Sanctions.
The Russia sanctions regulations, imposed by OFSI to encourage Russia to terminate its efforts to destabilize Ukraine, use a combination of asset freezes and unique measures intended to prevent Russian state-owned financial institutions from accessing capital markets, including prohibitions on the purchase and sale of certain transferable securities and money market instruments and bans on loan and credit arrangements with specific financial institutions. The guidance also addresses restrictions on investments made in relation to the Republic of Crimea and the city Sevastopol and any exceptions that might apply to each restriction, including instances when an OFSI license may be appropriate. The guidance also addresses frequently asked questions to provide additional clarity regarding financial arrangements that may still be authorized and financial obligations that exist under the regulations.