On July 16, 2024, the UK Office of Financial Sanctions Implementation updated its running list of Financial Sanctions FAQs, adding FAQ 35 and FAQ 36 under the Russia (Sanctions) (EU Exit) Regulations 2019.
FAQ 35 explains that all sanctions on professional and business services continue to apply with respect to persons connected with Russia pursuant to Regulation 54C, even when trust services are involved, unless permitted by license or specific exception. Separate licenses are required for professional business services and trust services when engaging in trust-related activities covered by the sanctions.
FAQ 36 clarifies how asset freezes interact with the trust services sanctions: whilst the assets of designated persons remain frozen under Regulation 11, an exception applies that permits the provision of trust services necessary for compliance with the asset freeze – for example when some action is needed to maintain the frozen assets, and a license is obtained by the trustee or designated person to undertake the stated action.