Last week the UK’s foreign secretary announced 65 new Russian and Belarus sanctions to cut off vital industries fueling Russia’s war on Ukraine. The UK has now sanctioned over 1,000 individuals and businesses under the Russian sanction’s regime since the invasion on Ukraine.
Liz Truss announced that six more banks have been targeted, including Alfa-Bank the largest of the private banks in Russia and based in Moscow, and individual sanctions including the founder of Tinkoff bank Oleg Tinkov, and Herman Gref, the CEO of Russia’s largest bank Sberbank.
Foreign Secretary Liz Truss said:
“All those sanctioned today will have their assets in the UK frozen which means no UK citizen or company can do business with them, and individuals subject to travel bans are also prohibited from travelling to or from the UK.”
“Today’s sanctions will bring the total global asset value of the banks the UK has sanctioned since the invasion to £500 billion and the net worth of the oligarchs and family members in excess of £150 billion.”
“The UK has led the international sanctions effort, cutting off whole sectors of the Russian economy by targeting its defence companies, its trade and transport sector, and working with allies to exclude Russia from the SWIFT financial system.”
The UK financial regulatory authorities reiterate that all UK financial services firms, including the cryptoasset sector, are expected to play their part in ensuring that sanctions are complied with. Since February firms have been inundated with the requirement to understand and conform to these sanctions, with a high expectation that firms:
- Have established systems and controls to counter the risk that they might be used to further financial crime and this includes compliance with financial sanctions obligations.
- Are screening against the UK sanctions list to meet these new sanctions measures – https://www.gov.uk/government/publications/the-uk-sanctions-list.
- Are screening against the Office of Financial Sanctions Implementation (OFSI) list of asset freeze targets for financial sanctions obligations – https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets/consolidated-list-of-targets
- Are legally obliged to report to the OFSI if they know or suspect that a breach of financial sanctions has occurred, and the FCA should also be notified.
- If they identify transactions that give rise to concerns about sanctions evasion or money laundering that they are reported to the UK Financial Intelligence Unit (UKFIU) at the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.
- Check the FCA register to identify whether any cryptoasset firms they do business with are registered, or to check the equivalent register of the jurisdiction in which the cryptoasset firm is based. Both the FCA and the Prudential Regulation Authority (PRA) will act if they see authorised financial institutions supporting cryptoasset firms operating in the UK illegally.
- Review the extended UK sanctions alongside any sanctions issued by any other country or bloc, such as US and EU.
The situation regarding sanctions is evolving rapidly, and requires continuous monitoring, implementation, and reporting. It is therefore no surprise that we are seeing a high demand for sanction experts to support interim projects and increased workloads.
If you are a sanctions expert looking for an interim role or a firm that is looking to hire in some extra support, please contact Bradley Handelaar who would be happy to discuss the current market.
In addition, if you are a UK based Compliance, Financial Crime, Risk or Legal expert that has been displaced from financial instructions that have been affected by these sanctions, please contact Bradley Handelaar who will be happy to discuss current interim opportunities.
Bradley Handelaar | Senior Associate | Danos Consulting
T: +44 (0) 207 010 1154 | E: firstname.lastname@example.org
For the latest UK Government Russia sanctions guidelines visit: https://www.gov.uk/government/publications/russia-sanctions-guidance/russia-sanctions-guidance