Financial measures

1) Financial and investment restrictions The Regulations prohibit a person from directly or indirectly dealing with a transferable security or money market instrument •if it has a maturity exceeding 30 days, and was issued after 1 August 2014 by: • Sberbank, VTB bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank (as listed in Schedule 2) • an entity incorporated or constituted in a country other than the UK which is owned by one or more of the five banks listed above • an entity acting on behalf of or at the direction of those five banks named above or an entity incorporated or constituted in a country other than the UK which is owned by one or more of those five banks It is also prohibited for a person to directly or indirectly deal with a transferable security or money market instrument if it has a maturity exceeding 30 days, and was issued after 12 September 2014 by: • OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft or Gazprom Neft (as listed in Schedule 2) • an entity incorporated or constituted in a country other than the UK which is owned by one or more of the six entities listed above • an entity acting on behalf of or at the direction of those six entities named above or an entity incorporated or constituted in a country other than the UK which is owned by one or more of those six entities It is prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued on or after 1 March 2022 by: • an entity incorporated or constituted under the law of the UK and owned by one or more of the entities listed in Schedule 2 • an entity acting on behalf or at the direction of the above It is prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued on or after 1 March 2022 by: • a person connected with Russia (this is defined in regulation 19A(2), and is subject to the exclusions in regulation 16(4D)(a)) • an entity owned by such persons an entity acting on behalf or at the direction of any of the above • It is prohibited for a person to directly or indirectly deal with a transferable security or money market instrument if it was issued: • on or after 15th December 2022 • by a relevant entity (i.e. a person who is not a person connected with Russia) • for the purposes of making an investment in relation to Russia (see below) It is also prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument which was issued on or after 1 March 2022 by the Government of Russia (as defined in regulation 6). 2) Loan and credit arrangements The Regulations prohibit a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit, with a maturity exceeding 30 days to: • the entities listed in Schedule 2 • an entity which is incorporated or constituted under the law of a non-UK country and owned by one or more of the entities listed in Schedule 2, or an entity acting on behalf of or at the direction of either that entity or an entity listed in Schedule 2 • an entity which is incorporated or constituted under the law of the UK and owned by an entity listed in Schedule 2, on or after 1 March 2022 • a person connected with Russia (this is defined in regulation 19A(2), and is subject to the exclusions in regulation 17(5)) The Regulations prohibit granting a new loan or credit arrangement to a relevant entity for the purposes of making an investment in relation to Russia. The Regulations prohibit a person from providing funds to a relevant entity where the purpose of making those funds or economic resources available is to enable a relevant entity to grant a loan that is otherwise prohibited under regulation 17. The Regulations also prohibit a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit to the Government of Russia (as defined in regulation 6), on or after 1 March 2022. 3) Correspondent banking relationships and sterling payments The Regulations prohibit a UK credit or financial institution from establishing or continuing a correspondent banking relationship with a designated person if the UK credit or financial institution knows, or has reasonable cause to suspect, that the correspondent banking relationship is with a designated person. This prohibition applies to correspondent bank accounts held by UK credit or financial institutions in any currency. The Regulations also prohibit a UK credit or financial institution from processing a sterling payment to, from or via, a designated person, or a credit or financial institution (domiciled anywhere including the UK) owned or controlled by the designated person, if the UK credit or financial institution has reasonable cause to suspect that the sterling payment is to, from or via a designated person. This prohibition applies to payment chains or third party payments. 4) Investments in relation to non-government controlled Ukrainian territory The Regulations prohibit: • directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in land located in non-government controlled Ukrainian territory • directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in an entity which has a place of business located in non-government controlled Ukrainian territory (“a relevant entity”) • directly or indirectly granting any loan or credit, entering into any arrangement to grant a loan or credit or otherwise provide funds, including equity capital, to a relevant entity or for the purpose of financing the relevant entity • directly or indirectly establishing any joint venture in non-government controlled Ukrainian territory or with a relevant entity • providing investment services directly related to the activities referred to in the 4 bullet points above 5) Provision of financial services for the purpose of foreign exchange reserve and asset management The Regulations prohibit a UK individual or entity from providing financial services for the purpose of foreign exchange reserve and asset management to: • the Central Bank of the Russian Federation • the National Wealth Fund of the Russian Federation • the Ministry of Finance of the Russian Federation • a person owned or controlled directly or indirectly by any of the persons above; or • a person acting on behalf of or at the direction of any of the persons above “Foreign exchange reserve and asset management” means activities relating to the reserves or assets of the persons listed above. Such reserves or assets include money market instruments (including cheques, bills and certificates of deposit); foreign exchange; derivative products (including futures and options); exchange rate and interest rate instruments (including products such as swaps and forward rate agreements); transferable securities; other negotiable instruments and financial assets (including bullion, such as gold); and special drawing rights. For example, it is prohibited to provide financial services to carry out transactions with the Central Bank of the Russian Federation involving its gold. 6) Investments in relation to Russia The Regulations prohibit: • direct acquisition of any ownership interest in Russian land and persons connected with Russia • indirect acquisition of any ownership interest in Russian land and persons connected with Russia for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia • direct or indirect acquisition of any ownership interest in entities (which are not persons connected with Russia) for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia • establishing joint ventures with a person connected with Russia • opening representative offices and establishing branches and subsidiaries in Russia; or • the provision of investment services directly related to all activities above 7) Trust Services The Regulations prohibit: the provision of trust services to or for the benefit of persons designated for the purposes of this measure, and the provision of trust services to or for the benefit of persons connected with Russia unless those services were provided immediately prior to the day the regulations come into force pursuant to an arrangement that has effect at that time “Trust services” means: • the creation of a trust or similar arrangement; • the provision of a registered office, business address, correspondence address or administrative address for a trust or similar arrangement; • the operation or management of a trust or similar arrangement; acting or arranging for another person to act as trustee of a trust or similar arrangement. Trust services are provided “for the benefit of” where the person (“P”): • is a beneficiary of a trust or similar arrangement, • is a potential beneficiary in a document from the settlor relating to a trust or similar arrangement (such as a letter of wishes), or having regard to all the circumstances, P might reasonably be expected to obtain, or be able to obtain, a significant financial benefit from the trust or similar arrangement. • “beneficiary”, “potential beneficiary” and “settlor”, in relation to an arrangement similar to a trust, means those individuals who hold equivalent or similar positions to those described in the sub-paragraphs above in respect of a trust. 8) Suspension of Banking Act 2009 requirement to recognise third-country resolution actions The Regulations disapply the Bank of England’s statutory duty under section 89H(2) of the Banking Act 2009 to make a decision in respect of recognition notifications from third-country resolution authorities where: • the resolved bank or financial institution is a designated person subject to an asset freeze; or • the resolved bank or financial institution is owned or controlled directly or indirectly by such a designated person. This means that the Bank of England will not make a decision under section 89(H)(2), that is to recognise, partially recognise or refuse to recognise a third-country resolution action, for as long as the resolved institution in question is designated as subject to an asset freeze or is owned or controlled directly or indirectly by a person who is designated as subject to an asset freeze under the Russia Regulations. 9) banknotes denominated in sterling and any official currency of the European Union

UK

The Russia (Sanctions) (EU Exit) Regulations 2019

UK country specific

Russia

The Russia (Sanctions) (EU Exit) Regulations 2019 came fully into force on 31 December 2020. They are intended to ensure that certain sanctions relating to Russia continue to operate effectively. You should also review the following regulations to find out any changes made to the Regulations: the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2020 the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 4) Regulations 2020 the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 11) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 13) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 16) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 the Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2023 the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 This sanctions regime is aimed at encouraging Russia to cease actions destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine. Those persons who are designated under this regime are included on the UK sanctions list.

Licensing and exception provisions are contained in Part 7 of the Regulations.