The UK Government recently published a guidance note to help the public understand how it collects and handles the data related to sanctions issued in response to the Russia’s invasion of Ukraine and what this information represents. According to the guidance note, which was issued on June 10, 2022, the UK Sanctions List provides the details of all sanctions imposed by the UK, and the primary legislation that enables these designations is the Sanctions and Anti-Money Laundering Act 2018. Almost all of the UK sanctions imposed in response to Russia’s invasion of Ukraine have been issued under the UK’s Russia regime, Cyber regime or Belarus regime.
Even though the invasion officially began on February 24, 2022, UK’s first wave of sanctions related to Ukraine’s invasion were imposed upon Russia on February 22, 2022, and these sanctions are included in the UK’s post- invasion data. The UK Sanctions List includes sanctioned individuals, including oligarchs, which are defined for UK sanctions purposes as a Russian national who has an ultra-high-net-worth is connected to the Putin regime. The UK reports that an oligarch’s estimated net worth comes from either the 2021 or 2022 Forbes Billionaires Lists and is calculated using the IMF daily average 2021 exchange rate. The UK Sanctions List also includes family members of Russian oligarchs, including spouses, partners, former partners children and children’s partners. While most designated individuals are subject to asset freezes and travel bans, some are not; therefore, the UK Sanctions List describes the restrictive measures imposed upon each individual.
When listing sanctioned entities, the UK Sanctions List includes the sanction regime under which the entity was designated. Under UK legislation, subsidiaries, or entities that are owned or controlled by a designated person or entity, are subject to the same financial sanctions as the designated individual or entity. Section 7 of Russia Sanction Regulations and the Office of Financial Sanctions Implementation both provide detailed guidance on how the ownership and control of an entity is determined, and the guidance note also describes how the estimated number of sanctioned subsidiaries in the UK is calculated. When sanctioning banks, the UK determines the estimated value of the bank’s global assets using the 2021 Finmarket – Interfax Rankings and the 2021 average IMF exchange rate, which can cause asset values to fluctuate. It is important to note that the UK can only freeze assets held in the UK financial system, a much smaller amount than the entity’s estimated global asset value.
If more information is needed regarding the UK Government’s sanctions data, the public is encouraged to email any questions to the Foreign, Commonwealth & Development Office (FCDO) Communications team at newsdesk@fcdo.gov.uk.