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As The UK Gets Tougher on Russia, Are you Up to Date?

As The UK Gets Tougher on Russia, Are you Up to Date?

Tensions between Russia and the West have been mounting in recent years, with the EU imposing various economic and financial sanctions on Russia in response to its illegal annexation of Crimea in 2014. The threat of further EU sanctions being imposed on Russia seems even more of a possibility following the recent nerve agent attack in Salisbury, with Russia announcing yesterday that it would send UK diplomats home in retaliation to the UK’s expulsion of 23 Russian diplomats just a day earlier.

The UK also intends to freeze Russian state assets where there is evidence that they could be used to threaten the life or property of UK nationals or residents, and it is pushing to impose asset freezes and travel bans on Russians involved in corruption and human rights violations. This, along with the announcement from the US that it will impose sanctions on individuals involved in vote tampering and cyber attacks during the 2016 US Presidential election, could create a real risk of further economic and financial sanctions on Russia.

Current EU sanctions on Russia include:

  • An arms embargo;
  • A ban on supply of dual-use items which are or may be intended for military end-use or for a military end-user in Russia;
  • Restrictions on export of oil industry related equipment and technology to Russia or for use in Russia;
  • Assets freezes and travel bans on 150 individuals and 38 entities;
  • Investment bans on 11 state financial institutions.

Some might say that the UK will struggle to secure support from other EU countries for tougher sanctions on Russia. However, the recent tensions with Russia could result in financial sanctions being applied to people who were not previously subject to restriction. As such, it is crucial to review your exposure to risk and where new risks arise, re-run searches of the UK Consolidated List and if required the US SDN list. Breach of financial sanctions is a serious criminal offence which can result in prison sentences or fines. Separately, OFSI can impose a civil penalty of up to 50% of the value of the total breach or £1 million, whichever is greater.

For further information or advice please contact Lynne Moss or Fran Hutchison.

By Lynne Moss
Senior Associate

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