TRACE ROAD LIMITED LIABILITY COMPANY

Berezhkovskaya Embankment, 38, Bldg. 1, Inter Dorogomilovo Municipal District, Moscow, Russia

OGRN 1247700271829 TIN 9710131220 (TIN region – Moscow) Checkpoint 773001001

The Secretary of State considers that there are reasonable grounds to suspect that TRACE ROAD LLC is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 because it is associated with A7 LLC, a Government of Russia-affiliated entity carrying on business in a sector of strategic significance to the Government of Russia (namely the Russian financial services sector), by reason of: (i) its operational integration into the A7 network through shared infrastructure and personnel; (ii) the documented role of its principals within the network; and (iii) the financial benefit it obtains in that capacity. The Secretary of State further considers that there are reasonable grounds to suspect that TRACE ROAD LLC makes available economic resources to A7 LLC and to other persons within the A7 network which are themselves carrying on business as Government of Russia-affiliated entities and in the Russian financial services sector.

UK

Asset freeze, Trust Services Sanctions, Director Disqualification Sanction

2026-05-26

UK

The Russia (Sanctions) (EU Exit) Regulations 2019

UK country specific

Russia

Asset freeze and making available provisions, Trade sanctions, Travel bans, Transport sanctions

• The Regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly. • The effect of the Regulations is to impose a travel ban on persons designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. • Trade sanctions. • Transport sanctions.

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.