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These FAQs are produced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, the authority for the implementation of financial sanctions in the UK. They should be considered supplementary to, and not a replacement for, OFSI’s primary guidance.
These FAQs do not represent legal advice
If you are unsure your obligations in a given case, you should consider seeking independent legal advice.
1. How do I stay informed new designations?
Amended on: 24 March 2025
2. Are UK entities’ subsidiaries located outside the UK expected to comply with UK sanctions?
UK financial sanctions apply to all persons within the territory and territorial sea of the UK, and to all UK persons wherever they are in the world. UK persons will include legal persons established under UK law, including their branches.
Additionally, to come within OFSI’s enforcement of financial sanctions, there must be a connection to the UK, which we call a UK nexus. A UK nexus will be considered on a case-by-case basis but might be created by such things as a UK company working overseas, transactions using clearing services in the UK, or in respect of a UK company directing the overseas actions of a local subsidiary (these examples are not exhaustive).
3. What measure (if any) should companies adopt in respect of designated persons with shares in a UK financial institution?
Shares qualify as ‘funds’ and therefore must be frozen if owned, held or controlled by a designated person. Accordingly, unless there is an applicable exception or OFSI licence in place, it is prohibited to “deal with” shares that are frozen, which includes dealing with the shares in a way that would result in any change in their volume, amount, location, ownership, possession, character or destination.
145. If a Relevant Institution creates and temporarily uses a suspense account to effect the requirement to freeze funds owned, held or controlled by Designated Persons, then will OFSI take enforcement action against that institution for breaching the asset freeze?
In general, OFSI does not consider it to be in the public interest to take enforcement action in relation to the creation and use of suspense accounts for the express purpose of putting into effect UK requirements to freeze funds owned, held or controlled by a Designated Person (when the creation/use of the suspense account is at the point the Relevant Institution first becomes aware of such requirements). If Relevant Institutions take this approach, then they can notify OFSI within their frozen asset reporting. Relevant Institutions may wish to make specific reference to this FAQ within any such frozen asset report.
Added on: 27 Mar 2025
205. What happens to specific licences when a designated person is delisted?
When a designated person is delisted, UK financial sanctions cease to apply to that person or entity. Specific licences that concern only the delisted designated person and no other relevant sanctions are no longer needed. Post de-listing, you do not need to apply for a specific licence to be revoked.
Where a specific licence is no longer required following a delisting, you do not need to take any action and do not need to OFSI regarding the status of that licence. If a person or entity is later re-listed, any specific licence(s) issued by OFSI are not re-activated. A new licence application will need to be made.
Any relevant specific licence applications pending at the time of de-listing that cease to be required will be closed.
Added on: 09 October 2026
4. If two or more designated persons are each minority shareholders in a non-designated person, but their aggregate ownership amounts to more than 50% of that non-designated person, should that non-designated person be considered as being owned by a designated person for the purpose of the Russia (Sanctions) (EU Exit) Regulations 2019 (the Regulations)?
When making an assessment of ownership or control, OFSI would not aggregate different designated persons’ shareholdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated persons or one designated person controls the rights of another designated person.
Regulation 7 sets out what is meant by a person being owned or controlled directly or indirectly by a designated person.
If each of the designated persons’ shareholdings is at 50% or falls below the 50% threshold in respect of ownership and there is no evidence of control over the non-designated person, the non-designated person will not be subject to sanctions. However, if there is evidence of control, the non-designated person will be subject to sanctions.
5. Should a UK credit or financial institution process payments that are received directly or indirectly from a bank designated for the purposes of regulation 17A, when both the remitting account holder and beneficiary account holder are not designated?
No. Regulation 17A(2) prohibits UK credit or financial institutions (referred to as banks within this response) from processing payments which have previously been processed by banks designated for the purposes of that regulation. In other words, the prohibition prevents UK banks from clearing and settling the payment. However, the legislation permits the first credit of funds into the UK bank’s account (in their name, excluding any accounts where funds are held on behalf or for the benefit of a customer) given that banks may not receive detailed payment information prior to initial receipt of funds for some transfers. An exception under regulation 59A(2) enables banks to move funds internally (excluding to customer accounts) for the purposes of complying with regulation 17A(2) without breaching this prohibition.
Regulation 17A(2) prohibits UK banks from the onward processing of payments which have previously come from, been routed via, or which are intended to be paid to banks designated under the regulation. This includes cases where the designated bank is involved in the transaction as the remitting bank, a correspondent or intermediary bank in the payment chain or the beneficiary bank. Similarly, it includes cases where the UK bank is involved as a correspondent, intermediary or beneficiary bank in the payment chain.
Regulation 17A(2) prohibitions also apply to banks owned or controlled by banks designated under the regulation.
Some of OFSI’s general licences permit payments that would otherwise be prevented by Regulation 17A. If you are an account holder in such a transaction, please consult OFSI’s general licences and your bank to clearly explain how the transaction meets the criteria for the relevant general licence.
If there is a relevant licensing ground which applies to the transaction, OFSI may be able to issue a specific licence to enable a UK bank to process the payment. Licensing grounds applicable to these transactions, these are set out at Parts 1B and 1C of Schedule 5 of the Russia Regulations.
6. Do the Regulations prohibit the payment of dividends to designated persons?
Regulations 12 and 13 prohibit making funds available to, or for the benefit of, designated persons. Regulation 58(4) provides an exception from these which allows a relevant institution (as defined in Regulation 58) to credit a frozen account held by a designated person under specific circumstances.
8. Would a licence be required for a UK company to pay a non-designated Russian resident’s pension either to a UK bank or to a non-sanctioned Russian bank?
A payment from a UK company to a non-designated person would not need to be licensed if none of the persons in the payment chain are either designated or owned or controlled by a designated person.
9. Regulation 16 prohibits “dealing with” transferable securities and money-market instruments. What activities does this include?
Dealing with transferable securities and money-market instruments includes purchasing or selling the security or instrument, providing investment services relating to the security or instrument or assisting in the issuance of the security or the instrument. In this context, investment services means the reception and transmission of orders in relation to one or more financial instruments, the execution of orders on behalf of clients, dealing on own account, portfolio management, the provision of investment advice, the underwriting of financial instruments or placing of financial instruments on a firm commitment basis, the placing of financial instruments without a firm commitment basis and any service in relation to the admission to trading on a regulated market or trading on a multilateral trading facility.
10. Do the restrictions cover transferable securities issued by persons connected with Russia traded on the secondary market? Under what conditions?
It is prohibited by Regulation 16 to deal with a transferable security on secondary markets that was issued by a person connected with Russia after 1st March 2022.
Under the terms of Regulation 18B, it is prohibited to buy securities issued before this date if by doing so you acquire an ownership interest in persons connected with Russia for the purpose of making funds or economic resources available to or for the benefit of persons connected with Russia. However, purchasing a relevant transferable security (the definition of which includes a requirement that it was to a regulated market or multilateral trading facility prior the SI coming into force) is permitted.
11. How would OFSI determine the purpose of a transaction for the prohibitions in Regulation 16, 17 and 18B?
OFSI may consider a person as having knowledge or reasonable cause to suspect that a transaction was for the purpose of making funds or economic resources available to a person connected with Russia where this is explicitly stated to be the purpose of the transaction. For example, if the intention to make funds available to a person connected with Russia was stated as the purpose of a issue in the prospectus for that issue. If funds are raised for a purpose other than making funds or economic resources available to a person connected with Russia but despite that those funds are subsequently made available to a person connected with Russia, then the prohibition would not be breached.
12. Are UK firms still allowed to deal with transferable securities and money-market instruments which are not the subject of restrictions in the Regulations on Russian exchanges?
UK firms are still allowed to deal with transferable securities and money-market instruments on Russian exchanges as long as such dealing with does not contravene any of the prohibitions in the Regulations. Dealing with transferable securities and money-market instruments issued before the relevant dates indicated in Regulation 16 is possible, provided that such dealing with does not contravene any of the other prohibitions in the Regulations, including 18B.
13. Are UK persons still allowed to purchase shares in persons who are not connected with Russia from Russian persons who hold those shares?
UK persons may purchase shares in persons who are not connected with Russia from Russian shareholders so long as the purpose for which those shares were issued is not for an activity that is prohibited under Regulation 18B (see Regulation 60ZZA); and the purchase does not otherwise breach the financial prohibitions imposed by the Russia Regulations.
14. Does Regulation 16 cover existing securities or does it apply only to new securities (issued on or after 1 March 2022)?
Regulation 16 of the Regulations sets out what transferable securities and money-market instruments are covered by the prohibition. This includes some transferable securities and money-market instruments issued before 1 March 2022.
15. Do the Regulations prevent UK persons operating in Russia from paying usual statutory taxes in Russia directly to the Russian Central Bank?
Regulation 18A of the Regulations does not prevent a person from paying taxes lawfully due in Russia to the Russian Central Bank.
16. I own shares in a designated person. Can I sell those shares?
Provided that the shares do not fall within the scope of Regulation 16, you can sell your shares on the secondary market without an OFSI licence as long as (a) you are not a designated person and (b) the sale will not result in funds or economic resources being made available to a designated person.
17. Might payment terms for goods and services whose trade is not prohibited under the Regulations be considered as a relevant loan for the purpose of Regulation 17?
No, payment terms or delayed payment for goods or services are not in general considered as a relevant loan for the purpose of Regulation 17. However, the provision of payment terms/delayed payment may not be used to circumvent the restrictions to provide a relevant loan under this Regulation. Payment terms which are not in line with normal business practice or which have been substantially extended may constitute circumvention (as defined in Regulation 19).
18. What are the sanctions reporting obligations for firms falling outside of the definition of a ‘relevant firm’?
Firms that fall outside of the definition of “relevant firms” (found at Regulation 71) do not have a legal requirement under Regulation 70 to report to OFSI if they know or suspect someone is a designated person or has committed a financial sanctions breach.
Please note, however, that every year HM Treasury carries out a review to update our records to reflect any changes to frozen assets during the reporting period. As part of this review, HM Treasury requests all persons (not only “relevant firms”) that hold or control funds or economic resources owned, held, or controlled by a designated person, to provide a report to us with the details of these assets. If you possess this information you are required to complete such a report and submit it to OFSI. This review generally takes place in the autumn.
19. Are insurers allowed to insure Russian ships and cargo carrying food and fertiliser from Russia and Ukraine to a third country?
Insurers may apply for a licence from OFSI under the food security purpose within the Regulations. This allows anything to be done in connection with the production or distribution of food for the benefit of the civilian population of a country. Furthermore, applying under the food security purpose does not preclude applicants from also applying under other purposes in the Regulations (e.g prior obligations) if applicable. Applicants must demonstrate how their activity satisfies that particular purpose, for example how their activity is in connection to the production/distribution of food.
20. If a UK person has provided a good or service to a person subject to the prohibitions in Regulation 17, would payment terms/delayed payment for such a good or service exceeding 30 days constitute a new loan or credit?
For the purposes of Regulation 17, payment terms/delayed payment for goods or services are not considered loans or credit. The provision of payment terms/delayed payment may not be used, however, to circumvent the prohibition to provide new loans or credit.
21. How should the rollover of debt obligations by persons subject to the prohibitions in Regulation 17 be treated?
The prohibitions in Regulation 17 extend to the rollover (including cashless) of existing debt. Any rollovers must comply with the 30-day maturity limit imposed for new transactions made after IP completion day, or after 1 March 2022 depending on what entity is involved. However, multiple rollover agreements with a maturity of 30 days or less could amount to circumvention.
22. Can a UK person provide funds to a non-designated person, which are channelled through a person who is subject to the prohibitions in Regulation 17, provided that the funds do not stay with the latter person for more than 30 days?
Such an arrangement would not constitute providing a new loan or credit with a maturity exceeding 30 days to a person subject to the prohibitions in Regulation 17. It would therefore not fall within the prohibitions set out in therein.
23. Are derivatives covered by the prohibitions in Regulation 16?
Derivative products which give the right to acquire or sell a transferable security or money market instrument covered by Regulation 16, such as options, futures, forwards or warrants, irrespective of how they are traded (on-exchange or over-the-counter (OTC)) are covered by the prohibitions set out in Regulation 16. Certain other derivatives which do not give the right to acquire or sell a transferable security or money market instrument covered by Regulation 16, such as interest rate swaps and cross currency swaps, are not covered by the prohibitions in that Regulation, nor credit default swaps (except where these give the right to acquire or sell a transferable security). Derivatives used for hedging purposes in the energy market are also not covered by Regulation 16.
24. Can a modification be made to a transferable security entered into prior to 1 August 2014,12 September 2014 or 1 March 2022 respectively?
It is prohibited under Regulation 16 to adjust a transferable security which falls within the scope of that Regulation, entered into prior to 1 August 2014, 12 September 2014, or 1 March 2022 respectively where the change would result or potentially result in additional capital being made available to a targeted entity. While certain other changes may be permitted, a case by case assessment would be made of the effect and substance of any changes in order to determine whether or not such changes reasonably requires this to be considered a new instrument.
25. Do promissory notes fall within the scope of prohibitions relating to transferable securities or money-market instruments in Regulation 16?
As a freely transferable debt instrument, promissory notes may be dealt in on the money markets and thus, to the extent that they are issued by a person subject to the restrictions in Regulation 16, they would fall into the scope of the prohibitions in that Regulation.
If a person subject to the prohibitions in Regulation 16 were to issue a non-negotiable promissory note as a means of payment for non-prohibited goods with UK persons, that would not be prohibited by Regulation 16 (albeit this could not be used as a means to circumvent the prohibition). This allows legitimate trade to continue while remaining consistent with the objectives of the Regulations.
26. Do bills of lading fall within the scope of prohibitions relating to transferable securities or money-market instruments in Regulation 16?
In so far as bills of lading document the carriage and receipt of goods and serve as proof of entitlement to such goods, they do not fall under the prohibitions in Regulation 16.
In any negotiable form where bills can be traded for financing purposes, or any similar activity which could amount to circumvention, these instances would be prohibited by Regulation 16 (or Regulation 19 in the case of circumvention).
27. Can UK persons use repurchase agreements or securities lending agreements with a person not subject to the prohibitions in Regulation 16 using any transferable securities or money market instruments issued by a person subject to the prohibitions in Regulation 16 as collateral?
UK persons are prohibited from entering into repurchase agreements or securities lending agreements where transferable securities or money market-instruments which fall within the scope of Regulation 16 are used as collateral.
28. Can UK persons enter into repurchase agreements or securities lending agreements with a person subject to the prohibitions in Regulation 16, if non-prohibited instruments are used as collateral?
Repurchase agreements or securities lending agreements are money market instruments as defined in Regulation 16 of the Regulations, as they are instruments normally dealt in on the money market. UK persons are therefore prohibited from entering into repurchase agreements or securities lending agreements with persons subject to the prohibitions in Regulation 16 where those agreements meet the conditions set out in that Regulation.
29. Is the provision of financial research in relation to prohibited transferable securities allowed?
Regulation 16 sets out the prohibition on dealing with certain transferable securities or money-market instruments as set out therein. Regulation 16(9) states that “dealing with” includes providing investment services, including the provision of investment advice, relating to the security or instrument, or assisting in the issuance of the security or instrument. While the provision of research may not equate to the provision of advice, to the extent that it does constitute direct or indirect advice, it would fall under the definition of “investment service” and would thus be prohibited.
30. Can a UK credit institution owned by a person subject to the prohibitions in Regulation 17 provide collateral (e.g. in the form of guarantees, deposits, pledges, risk participations or funded participations) for intra-group risk mitigation purposes to its non-UK subsidiary?
Yes, provided the collateral provided does not constitute a relevant loan under Regulation 17 and the collateral used is not a transferable security or money market-instrument covered by Regulation 16.
31. Where the underlying of cash-settled derivatives consists of securities falling under Regulation 16, are transactions with such derivatives permitted under that Regulation so long as this does not involve the actual purchasing, selling, or holding of the underlying securities?
The prohibitions in Regulation 16 extend to direct or indirect dealings in all “transferable securities” with a maturity exceeding 30 days, issued by the persons listed in Regulation 16 after a certain date. Under Regulation 16(10), “transferable securities” includes any securities “giving the right to purchase or sell any” transferable security”. In such cases, the prohibition on dealing with transferable securities in Regulation 16 applies regardless of whether or not that right is actually exercised.
32. If a person subject to the prohibitions in Regulation 16 issues new transferable securities after the relevant dates set out in Regulation 16 that are fungible with pre-existing transferable securities, can UK persons still deal with the old securities in the event that it is impossible to identify which of the securities were issued before or after the relevant cut-off dates?
UK persons may deal with transferable securities issued by the persons subject to Regulation 16 before the relevant cut-off dates set out in that Regulation. Market participants bear the onus of ensuring that any trades they enter into do not involve the prohibited securities.
33. Who is considered a “prohibited person” under regulation 18A(1)?
A prohibited person means 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 these entities, or a person acting on behalf of or at the direction of these entities.
34. What assets must be reported under regulation 70A?
Designated persons must report any funds or economic resource if the value of those funds or economic resources exceeds the value of £10,000. If multiple funds or economic resources of the same type (for example, jewellery, art, bank accounts), taken together exceed £10,000, this must also be reported.
98. Do the asset freeze and restrictions on making funds and economic resources available apply to persons, who are not individuals, owned or controlled by designated persons listed on the UK Sanctions List? Where can I find reference to those persons owned or controlled by designated persons?
If a person is designated, their name will be recorded on the UK Sanctions List. The asset freeze and restrictions on making funds and economic resources available apply to designated persons and to persons, who are not individuals, that are owned or controlled directly or indirectly by a designated person. Persons who are owned or controlled directly or indirectly by a designated person may not be designated in their own right, in which case their names will not appear on the UK Sanctions List.
Please note that “persons who are not individuals” refers to legal persons including a body of persons corporate or unincorporate, any organisation and any association or combination of persons.
There is no list of those persons owned or controlled by designated persons, who are not designated in their own right. It is up to each party to exercise their own due diligence and consider whether a designated person owns or controls the person. More information on ownership and control can be found in Chapter 4 of OFSI’s general guidance.
99. What measure (if any) should companies adopt in respect of designated persons with shares in a UK financial institution?
Shares qualify as ‘funds’ and therefore must be frozen if owned, held or controlled by a designated person (see Regulation 11). Accordingly, unless there is an applicable exception or OFSI licence in place, it is prohibited to “deal with” shares that are frozen, which includes dealing with the shares in a way that would result in any change in their volume, amount, location, ownership, possession, character or destination.
100. Can Russian nationals resident in the UK open or maintain UK bank accounts?
If a person is not designated under a sanctions regime, and is not owned or controlled by a person designated under a sanctions regime, they will not be subject to the financial sanctions. As such, they will not be prohibited under financial sanctions from opening or maintaining a UK bank account.
Added on: 15 Aug 2024
101. Are UK entities’ subsidiaries located outside the UK expected to comply with UK sanctions?
UK financial sanctions apply to all persons within the territory and territorial sea of the UK, and to all UK persons wherever they are in the world. UK persons will include legal persons established under UK law, including their branches.
Please further note that to come within OFSI’s enforcement of financial sanctions, there has to be a connection to the UK, which we call a UK nexus. A UK nexus will be considered on a case-by-case basis, but might be created by such things as a UK company working overseas, transactions using clearing services in the UK, or in respect of a UK company directing the overseas actions of a local subsidiary (these examples are not exhaustive).
Added on: 15 Aug 2024
102. If a General Licence expires, can you still make payments to a frozen account of a Designated Person?
Once a General Licence has expired, it cannot be relied upon to lawfully make a payment that would otherwise be prohibited under sanctions regulations.
If there is no General Licence in place, unless there is an applicable exception or OFSI licence permitting the payment, payment to the account of a designated person will be prohibited.
Added on: 15 Aug 2024
103. Can money-market instruments and transferable securities of persons not subject to the restrictions envisaged by Regulation 16 still be dealt with?
If the person is not designated under the Regulations and it is not owned or controlled by a designated person (i.e. the person is not subject to the asset freeze and the prohibitions on making funds and economic resources available), its money-market instruments and transferable securities can be dealt with.
Added on: 15 Aug 2024
104. Are American Depositary Receipts (ADRs) covered by the restrictions in Regulation 16?
The term “transferable security” in Regulation 16 means a security, negotiable on the capital market, of any of the following kinds, but excluding instruments of payment:
(i) shares in companies and other securities equivalent to shares in companies, partnerships or other entities, and depositary receipts in respect of shares
(ii) bonds or other forms of securitised debt, including depositary receipts in respect of such securities
(iii) any other securities giving the right to purchase or sell any security of a kind mentioned in paragraph (i) or (ii).
Regulation 16 sets out the circumstances in which it is prohibited to deal with such transferable securities.
Added on: 15 Aug 2024
105. Do the restrictions in Regulation 16 also apply to transferable securities denominated in a virtual currency?
Yes. The term “transferable security” in the context of Regulation 16 is defined in Regulation 16(10), which makes no reference to the currency in which a transferable security is denominated.
Added on: 15 Aug 2024
106. Do the restrictions in Regulation 16 apply to the sale of units in collective investment undertakings whose portfolio includes, on or after 1 March 2022, newly issued transferable securities regardless of the percentage they represent of the fund’s assets?
Regulation 16 prohibits dealing, directly or indirectly, with any transferable security which meets the conditions set out therein. That Regulation makes no reference to any minimum percentages (for example, of a fund’s assets) in order for the Regulation to apply.
Added on: 15 Aug 2024
107. What obligations do operators of payment systems have under the Regulations with regard to payment cards issued by sanctioned Russian financial institutions?
UK persons, including UK operators of payment systems and UK acquirers, are prohibited from processing transactions involving sanctioned financial institutions unless there is a licence from OFSI that allows them to do so, or they can rely on an exception in the Regulations.
OFSI encourages UK persons, including UK operators of payment systems and UK acquirers, to exercise caution and due diligence in dealing with non-UK operators of payment systems that are known to host payment cards issued by sanctioned financial institutions and whose payment cards are accepted in the UK.
Added on: 15 Aug 2024
108. Are financial institutions allowed to provide financial services, such as payment channels, for food and fertiliser exports from Russia and Ukraine to a third country?
Yes, as long as the required licence is in place. Financial institutions may apply for a licence under the food security purpose to provide these services. However, there may already be an OFSI licence in place permitting the food/fertiliser exports, which will usually contain a permission to allow banks and other financial institutions to effect the activities of the licence. Therefore separate licences for financial institutions are usually unnecessary.
Added on: 15 Aug 2024
109. Is the production and distribution of fertiliser covered by the licensing purpose for food security?
Yes, OFSI considers that the production and distribution of fertiliser is within the scope of the food security licensing purpose.
Added on: 15 Aug 2024
110. If before IP completion day (11:00pm, 31 December 2020) or 1 March 2022 respectively, a UK person extended a loan or credit to a person subject to the restrictions in Regulation 17, can that UK person then sell a part of or the whole claim with a maturity exceeding 30 days to another person subject to the restrictions in Regulation 17?
In so far as the arrangement would not involve new loans or credit to either person subject to the restrictions in Regulation 17, or any other restricted activity, such a resale would be allowed.
A change of lenders, even if they are a person subject to the restrictions in Regulation 17, would not generally be prohibited by the Regulations, to the extent this does not constitute advancing new funds contrary to Regulation 17.
Added on: 15 Aug 2024
111. If a UK person extended a loan or credit with a maturity exceeding 30 days before or on IP completion day or 1 March 2022 respectively, could the UK person enter into an M&A transaction whereby a person subject to Regulation 17 assumes the role of the borrower of the debt arising from such loan after IP completion day or 1 March 2022?
It would be prohibited for a UK person to enter into any M&A transaction, whereby a person subject to the prohibitions in Regulation 17 would assume the role of borrower of an existing loan or credit with a maturity exceeding 30 days. The example above would effectively constitute making a new loan or credit available to a targeted entity after IP completion day or 1 March 2022 respectively and would therefore be prohibited.
Added on: 15 Aug 2024
112. A loan or credit with a maturity exceeding 30 days before or on IP completion day or 1 March 2022 respectively had been extended by a UK person to a person subject to Regulation 17. Can the UK person cancel or forgive debt arising from such a loan after IP completion day or 1 March 2022 respectively?
The Regulations prohibit persons subject to the prohibitions in Regulation 17 from being extended credit or a new loan, as their purpose is to restrict access to capital, even in circumstances where the sums extended need to be reimbursed. Cancellation of the debt would provide access to capital in the same way as a loan but without a duty to reimburse or pay interest. It would therefore be prohibited.
Added on: 15 Aug 2024
114. With regards to relevant loans as defined in Regulation 17, can UK persons provide payment or settlement services including in the context of correspondent banking?
For the purposes of Regulation 17, payment and settlement services, including through correspondent banking, would be construed as directly or indirectly ‘making’ or ‘being part of an arrangement to make’ a relevant loan or credit to a person subject to the prohibitions in Regulation 17.
Any loans or credit made after IP completion day which are the subject of such payment or settlement services must comply with the 30-day maturity limit, or related exceptions, in order to avoid being caught by the restrictive measures.
Added on: 15 Aug 2024
115. Do the Regulations limit the ability of UK subsidiaries of targeted entities to monitor risks, including the evaluation of credit risk, for operations across the group?
While receiving information and undertaking risk management and monitoring is unaffected by the Regulations, such risk management would not be permitted if it amounted to circumvention of any of the financial sanctions.
Added on: 15 Aug 2024
116. What constitutes a letter of credit?
A letter of credit is an undertaking by a bank to pay the beneficiary of the credit (or to accept and pay drafts drawn by the beneficiary) in accordance with, and upon satisfaction of the terms and conditions, of the letter of credit. It is no more than an undertaking from the bank (at the request of its customer) to extend a credit, or make a payment, provided that the conditions set out within the letter of credit itself are satisfied and the bank is provided with proof of this (usually by the provision of documents).
Added on: 15 Aug 2024
117. Can UK persons confirm or advise a letter of credit that was issued after 31 December 2020 by a person subject to the prohibitions in Regulation 17 for the export or import of goods or services between non-UK countries? Is discounting or post financing of such letters of credit allowed?
UK persons can confirm or advise letters of credit, and provide discounting or post financing for them, unless the maturity exceeds 30 days and applicant of the letter of credit is a person subject to the prohibitions in Regulation 17. This would be prohibited as it constitutes extending a relevant loan.
Added on: 15 Aug 2024
118. What is the process for reviews and appeals for civil monetary penalties imposed for a breach of regulation 70A?
The procedure for the right to review, right to appeal and the process for paying a monetary penalty is set out in Regulation 88D of The Russia (Sanctions) (EU Exit) Regulations 2019. Further information on the right of appeal can be found in Chapter 7 of OFSI’s enforcement and monetary penalty guidance Further information on paying a monetary penalty can be found in Chapter 8 of OFSI’s enforcement guidance Further information on the process of review can be found in sections 6.2 to 6.14 of OFSI’s enforcement and monetary penalty guidance.
Both representations and requests for review must be made in writing (unless oral representations have been agreed) to:
Email: [email protected]
Office of Financial Sanctions Implementation HM Treasury 1 Horse Guards Road London SW1A 2HQ
Added on: 15 Aug 2024
119. When are persons required to report to OFSI under regulation 70A (5)?
Regulation 70A(5) requires you to report changes in your financial circumstances to OFSI as soon as practicable. You must report to OFSI when the value of your funds or economic resources, when taken together, has changed by an amount exceeding £10,000 compared with the report you filed with OFSI. You must also report to OFSI if there has been a change to the nature or location of funds or economic resources where those funds or economic resources exceeds the value of £10,000 – this also applies where multiple funds or economic resources of the same type taken together exceed £10,000.
This obligation applies regardless of whether you have existing reporting obligations under an OFSI licence.
Added on: 15 Aug 2024
146. My OFSI licence(s) still mention(s) Rosbank PJSC following its merger. What should I do?
Rosbank PJSC, which was designated, ceased to exist as a separate entity when it merged with TBank as of 1 January 2025. The Consolidated List entry was amended to TBank (Group ID: 15917) to reflect this change. Should you hold a live licence referencing Rosbank PJSC, and you wish to continue relying on this licence, then you should immediately request an amendment to your licence from OFSI as OFSI would consider it a breach of sanctions if entities/individuals continued using their licence without the correct licence permission in place.
OFSI does not generally provide updates on restructures of designated persons, but in this specific case judged it appropriate to clarify the legal position.
Added on: 22 Apr 2025
147. My OFSI licence(s) still mention(s) Bank Otkritie following its merger. What should I do?
Bank Otkritie, which was Designated under the Russia (Sanctions) (EU Exit) Regulations 2019, ceased to exist as a separate entity when it merged with BM-Bank as of 1 January 2025. BM-Bank remains designated as a result of its ownership and control by the designated entity VTB Bank. OFSI has amended the Humanitarian Activity General Licence INT/2022/1947936 to reflect the merger with BM-Bank and you may continue to rely on this General Licence, provided you otherwise comply with its terms and conditions. Should you hold a live specific licence referencing Bank Otkritie, and you wish to continue relying on this licence, then you should immediately request an amendment to your licence from OFSI as OFSI would consider it a breach of sanctions if entities/individuals continued using their licence without the correct licence permission in place.
Amended on: 05 Feb 2026
148. Will OFSI amend General Licences affected by the mergers of Rosbank PJSC and Bank Otkritie with BM-Bank?
OFSI has amended the affected live General Licences, including those impacted by the merger of Rosbank PJSC and the merger of Bank Otkritie with BM-Bank. Therefore, entities/individuals relying on these General Licences can continue to do so. OFSI will not proactively identify specific licences referring to these entities.
Amended on: 05 Feb 2026
152. When should securities held at designated local Russian registrars be reported to OFSI?
Relevant institutions should update their annual Frozen Asset Report (FAR) to reflect any changes in the custody of these assets, rather than submitting initial reports ‘without delay’. This is provided there has been no material change in the value of the frozen assets.
186. Does the designation of Huobi Global S.A. apply to the HTX cryptocurrency exchange?
Yes. On 26 May 2026, the UK designated HUOBI GLOBAL S.A. (“Huobi”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”). Huobi is consequently subject to financial sanctions, as are entities owned or controlled by Huobi.
OFSI considers that the HTX cryptocurrency exchange is subject to the UK’s financial sanctions due to its ownership by Huobi, meeting the condition in regulation 7(2)(a) of the Russia Regulations.
Added on: 29 May 2026
These regulations prohibit dealing with transferrable securities and money market instruments issued by certain persons on or after certain specified dates. Dealing with transferrable securities and money market instruments that were issued before the specified dates is not prohibited, provided the activity does not otherwise breach the Russia Regulations or the Belarus Regulations (e.g. by making funds available to a designated person).
In some cases, a new transferable security or money market instrument is created in respect of an instrument or security issued prior to the specified dates referred to above (including in the context of an MCA) which could then potentially be caught by the relevant regulations. Determining whether this is the case is fact-dependent and will be considered by OFSI on a case-by-case basis (but determinations will only be made if relevant to specific OFSI casework). In that consideration, OFSI will place significant weight on whether an issuance (including as part of an MCA) results in finance being raised for the issuer.
For example, regulation 16 or regulation 15A may not apply if:
Shares subject to regulation 16 (or regulation 15A) originally issued prior to the relevant date in regulation 16 (or regulation 15A) become subject to a mandatory stock split after that date;
Shares subject to regulation 16 (or regulation 15A) originally issued prior to the relevant date in regulation 16 (or regulation 15A) become subject to a mandatory stock split after that date;
that stock split does not raise new finance for the company undertaking it; and;
that stock split does not raise new finance for the company undertaking it; and;
there is no material change to the rights and/or value of the shares.
there is no material change to the rights and/or value of the shares.
Funds allocated by International Central Securities Depository(ICSD)
172. Would an OFSI licence be required for a UK financial institution to deal with or receive (or use once received) funds allocated to it by an International Central Securities Depository (ICSD) where corresponding ICSD funds held by the National Settlement Depository (NSD) have been seized and dealt with by the NSD?
The NSD is a designated person (Group ID: 16534) under the UK’s Russia sanctions regime. OFSI understands that UK financial institutions may have had funds allocated to them by an ICSD following unilateral seizure by the NSD of ICSD funds held at the NSD. No, an OFSI licence would not be required by a UK financial institution to deal with or receive (or use once received) those funds, provided that:
the NSD (which is a designated person) has no ownership or control over the funds in question;
the NSD (which is a designated person) has no ownership or control over the funds in question;
funds are not being made available to, or for the benefit of, designated persons by the financial institution;
funds are not being made available to, or for the benefit of, designated persons by the financial institution;
no other financial sanctions are engaged.
no other financial sanctions are engaged.
OFSI cannot on whether licences from other jurisdictions may be required in this scenario.
Added on: 31 Oct 2025
Trust Services Sanctions
92. What are the trust services sanctions and what activity is prohibited?
Since 16 December 2022 under Regulation 18C of the Russia Regulations , it has been prohibited for a person to newly provide trust services to or for the benefit of a person connected with Russia (unless they are continuing trust services that were provided before the regulations came into force). It is also prohibited to provide trust services to or for the benefit of persons designated for the purposes of this measure.
‘To or for the benefit’ as defined in Regulation 18C(5) of the Russia Regulations includes being a potential beneficiary, for example, someone who may benefit from the trust service provision in the future, such as based on a letter of wishes.
Added on: 19 Jul 2024
93. Is there a trust services General Licence
Yes. To support trust service providers wind down their services in relation to designated persons, OFSI issued General Licence INT/2023/2589788 which allows 90 calendar days to wind down those services. It is effective from the date of designation for the purposes of Regulation 18C of the person to whom the trust services are being provided. Anyone using the General Licence must report to OFSI within 30 calendar days of undertaking any activity under the General Licence. Reporting must include the details of the trust services provided (amongst other things) and evidence should be provided where applicable, and can be completed using this form .
This General Licence is in addition to the existing exceptions and licencing grounds, including the exception to allow trust services to continue to be provided for the purposes of complying with an asset freeze. More information on exceptions and licensing grounds can be found in OFSI’s updated Russia guidance.
Added on: 19 Jul 2024
94. Do the trust services sanctions apply in the UK Crown Dependencies and Overseas Territories?
Like all UK sanctions measures, the trust services prohibitions also apply across the UK’s Crown Dependencies and Overseas Territories (OTs), with HM Treasury and the Foreign, Commonwealth and Development Office (FCDO) supporting on their effective implementation. OTs can issue General Licences with the consent of the Foreign Secretary and a number of OTs may already mirror OFSI’s General Licence.
Added on: 19 Jul 2024
95. Can a person provide professional and business services when operating or managing a trust?
The provision of professional and business services to persons connected with Russia is prohibited under Regulation 54C, unless permitted by a professional and business services licence (issued by the Export Control Joint Unit (ECJU) in the Department for Business and Trade (DBT)) or there is an applicable exception. All sanctions on professional and business services continue to apply even when trust services are permitted, unless the professional or business service is permitted by a licence in respect of that professional or business service or there is an applicable exception from the professional or business services sanction. If both professional business services and trust services sanctions apply to activities in relation to a trust, then separate licences for each activity will be required from DBT (for professional and business services sanctions) and OFSI (for trust services sanctions).
Added on: 19 Jul 2024
96. What happens when an asset freeze is in place - how do the trust services sanctions interact?
The assets of designated persons caught under Regulation 11 must remain frozen. The trust services sanctions includes an exception to permit the provision of trust services for the purpose of complying with the asset freeze (exception 60ZZB(1)(b)). This could include where an activity needs to be undertaken regarding frozen assets, and a designated person or the trustee obtains a licence or utilises an exception applicable to the asset freeze. Assets should remain frozen unless there is an applicable exception or OFSI has issued a relevant licence.
97. Whether the trust services sanctions cover the drafting of wills that contain trusts which may benefit a person connected with Russia, or whether the sanctions become relevant once the will trust comes into effect after the testator’s death?
Since 16 December 2022 under Regulation 18C of the Russia Regulations , it has been prohibited for a person to newly provide trust services to or for the benefit of a person connected with Russia (unless they are continuing trust services that were provided before the regulations came into force). It is also prohibited to provide trust services to or for the benefit of persons designated for the purposes of this measure.
‘To or for the benefit’ as defined in Regulation 18C(5) of the Russia Regulations includes being a potential beneficiary, for example, someone who may benefit from the trust service provision in the future, such as based on a letter of wishes
Added on: 19 Jul 2024
In addition, some interpret “located in Russia” to mean “based in” rather than literally in the physical location of Russia at a particular moment in time. “Based in” requires a more substantive connection, closer to that of “ordinarily resident”. Therefore someone who is hardly ever in Russia but is visiting for e.g. a week would not be “located in Russia”?
The trust services sanctions of the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations) target the provision of trust services, by UK persons in relation to the conduct of all U...
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