On April 6, 2022, the UK’s Foreign Secretary Liz Truss announced a new wave of sanctions in response to reports of “abhorrent attacks on civilians” during Russia’s ongoing invasion of Ukraine. The new sanctions include full asset freezes on Sberbank, Russia’s largest state-owned bank – an action taken in coordination with the US – and the Credit Bank of Moscow, Russia’s largest non state public bank. The UK also called for an end to its dependence on Russian coal and oil by the end of 2022 and an end to gas imports soon thereafter, and banned the export of key oil refining equipment and catalysts – an action in line with EU’s ban on imports of Russian coal. In addition, the UK imposed a ban on all new outward investment to Russia, which amounted to £11 billion in the UK in 2020 alone, and targeted key Russian industries and state-owned enterprises by banning the import of iron and steel products and imposing new restrictions on Russia’s ability to acquire UK’s quantum and advanced material technologies. Finally, the UK designated 8 additional oligarchs who operate in the newly-targeted industries.
The Foreign Secretary also announced plans to urge G7 Foreign Ministers, during their April 7, 2022 meeting, to take further collective action such as additional coordinated waves of sanctions against Russia and suggest that all G7 countries adopt an accelerated timetable to end their dependence on Russian energy.
On the same day, the Office of Financial Sanctions Implementation issued a new general license under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 and updated another, in order to address the designations of Sberbank and the Credit Bank of Moscow. OFSI updated General License INT/2022/1277877 to temporarily allow wind down transactions until June 24, 2022, related to the processing of GBP payments to, from or through designated person (DP) Sberbank (including UK and non-UK credit or financial institutions owned or controlled by Sberbank) for the purpose of making Relevant Energy Products available in the UK.
OFSI also issued General License INT/2022/1544176 to authorize wind down activities for 30 days with DP Credit Bank of Moscow or a Subsidiary. This general license enables a Person to engage in any wind down transaction to which it is a party and involves the DP or a Subsidiary, including the closing out of any positions. In addition, a Person, Relevant Institution or the DP or a Subsidiary is permitted to carry out any activity reasonably necessary to effect this. This general license expires on May 6, 2022.