The UK’s Office of Financial Sanctions Implementation recently issued three general licenses under Regulation 64 of The Russia (Sanctions) (EU Exit) Regulation 2019. On March 4, 2022, OFSI issued General License INT/2022/1295476 which allows for a 30-day wind down period for transactions involving five Russian banks, including Bank Otkritie, Promsvyazbank, Bank Rossiya, Sovcombank, and Vnesheconombank (Veb). The same day, OFSI issued General License INT/2022/1298776 to authorize a 30-day wind down period for transactions involving Sberbank. Both general licenses expire on April 3, 2022.
On March 10, 2022, OFSI also issued General License INT/2022/1327076 to enable the continuing operation of the Chelsea Football Club and its subsidiaries, an entity owned or controlled by designated person Roman Arkadyevich Abramovich. The general license permits payments that are essential to the continuation of the Club’s operation, including the payment of wages to employees and players; the payment fees or dividends to Club directors that are not designated persons; the payment of regular maintenance fees including taxes, insurance and energy costs; travel and security costs for players and staff not to exceed £20,000 per game per Club team; the payment for goods and services necessary for the hosting of fixtures on Club grounds not to exceed £500,000 per fixture per Club team; and inter-club payment obligations under player loan and sale agreements that existed prior to the designation. The general license also specifies that persons who purchased tickets prior to March 10, 2022 can continue to attend fixtures and purchase refreshments, and broadcasters may broadcast fixtures involving the Club and continue to receive payments associated with broadcasting.
The general license also provides that, due to Abramovich’s designation, any funds which the Club receives must be frozen. OFSI also requires that any person who uses this license for a permitted activity with a value exceeding £5,000 is required to keep accurate and complete records for a minimum of 6 years and must make the records available to OFSI upon request. This general license expires on May 31, 2022.