On October 6, 2022, the Office of Financial Sanctions Implementation issued an additional amendment of General License INT/2022/1280876, which was originally issued on March 1, 2022 under Regulation 64 of the Russia (Sanctions)(EU Exit) Regulation 2019. This general license initially authorized 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, it was amended to allow payments in connection with Insolvency Proceedings for a UK subsidiary of VTB and was extended, on April 22, 2022, to include Sberbank CIB and its UK subsidiaries. On August 22, 2022, the general license was further amended to authorize payments involving VTBC Asset Management International Limited, the Guernsey subsidiary of VTB, and Germany-based VTB Bank (Europe) SE.
In the October 6, 2022 amendment, OFSI extends these authorizations to payments related to the Insolvency Proceedings under the German Banking Act. General License INT/2022/1280876 permits a Person to receive these payments and allows 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.