The UK Office of Financial Sanctions Implementation recently issued a new general license and amended another under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019. General License INT/2022/1280876, which was originally issued on March 1, 2022, 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. On April 1, 2022, the general license was amended to allow payments in connection with Insolvency Proceedings for a UK subsidiary of VTB, and, on April 22, 2022, the general license was extended to include Sberbank CIB.
On August 22, 2022, General License INT/2022/1280876 was further amended to authorize payments involving VTBC Asset Management International Limited, the Guernsey subsidiary of VTB, and Germany-based VTB Bank (Europe) SE. This general license permits a Person to receive these payments and enables Relevant Institutions to process these payments. Anyone who utilizes this general license must notify HM Treasury in writing within 7 days of the payment and provide current, valid contact information. In addition, any records related to these payments must be kept for a minimum of 6 years. This license expires on April 3, 2023.
On August 22, 2022, OFSI also issued General License INT/2022/2104808 to authorize banks to collect service fees from accounts frozen in accordance with Russia Regulations if the fees are connected with the routine holding or maintenance of these accounts. This license permits the payment of service fee arrears as long as the payment is to a bank that is not designated under the Russia Regime. The license also allows HMRC to receive related payments and Relevant Institutions to process such payments. In addition, if the payments result in any tax liability, persons incurring the liability may make payments to settle those liabilities. Furthermore, anyone that utilizes this general license must keep records of their payments for a minimum of 6 years.