The UK Office of Financial Sanctions Implementation recently issued The Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 which entered into force on July 19, 2022. The amendment prohibits additional types of new investment in Russia and, more specifically, restricts the acquisition of any ownership interest in land in Russia and in entities connected with Russia or that have a place of business in Russia. The Amendment 12 Regulations also prohibit the establishment of commercial arrangements such as branches, offices or subsidiaries in Russia as well as joint ventures with persons connected with Russia. This amendment also prohibits the provision of investment services directly related to any of the above activities, with certain exceptions.
On July 19, 2022, OFSI also issued General License INT/2022/2002560 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 in order to temporarily permit certain investment activities and related wind down activities that would otherwise be prohibited by the Amendment 12 Regulations. This general license is effective until July 26, 2022. Persons who utilize this general license are required to keep accurate records of the transactions for a minimum of 6 years.
Also on July 19, 2022, OFSI also published new Russia Guidance related to financial and investment restrictions in Russia (Sanctions) (EU Exit) Regulations 2019. The new guidance addresses and incorporates the new investment prohibitions in the Amendment 12 Regulations.