March 2, 2022

UK issues several general licenses aimed at Russia sanctions

The UK’s Office of Financial Sanctions Implementation recently issued 6 general licenses under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019.  On February 25, 2022, OFSI issued General License INT/20022/1272278 that allows for a 30-day wind down period for transactions involving VTB Bank, Russia’s second largest bank, that expires on March 27, 2022.  

OFSI issued five additional general licenses on March 1, 2022, including General License INT/2022/1280876 that authorizes any subsidiary of VTB incorporated in the UK to make or receive certain payments related to basic needs (i.e., insurance premiums and mortgage/utility payments), reasonable fees or service charges related to frozen funds, and reasonable professional fees related to the provision of legal services.  The use of this general license requires that HM Treasury be notified within 7 days of payment and any records related to these payments be kept for a minimum of 6 years.  OFSI also issued General License INT/2022/1280976 to enable any “Relevant Authority” to carry out statutory functions that involve VTB Capital and any of its subsidiaries.   

Additional general licenses issued by OFSI under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 include General License INT/2022/1277777 that allows for a 7-day wind down period for sovereign debt, loans and money market instruments measures that expires on March 8, 2022 ; General License INT/2022/1277778 that allows for a 30-day wind down period for clearing and correspondent banking prohibitions that expires on March 31, 2022; and General License INT/2022/1277877 that authorizes clearing and correspondent banking prohibitions until June 24, 2022 for transactions aimed at making “Relevant Energy Products” available for use in the United Kingdom. 

General License INT/2022/1272278 | General License INT/2022/1277777 | General License INT/2022/1277778 |General License INT/2022/1277877 | General License INT/2022/1280876 | General License INT/2022/1280976