Summary of latest UK sanctions general licenses

On 4 March, the United Kingdom issued new general licenses for:

• wind down of positions with Sberbank, which is now subject to UK correspondent banking and payable-through-account restrictions, permitting the “provision of financial services to” Sberbank or its subsidiaries for the purpose of wind down, and
• wind down of transactions “involving” Bank Otkritie, PSB, Bank Rossiya, Novikombank, Sovcombank and VEB (now subject to UK asset freeze sanctions).

Both licenses took effect from 4 March 2022 and expire on 3 April 2022.

On 7 March, the United Kingdom amended the general license related to the wind down of positions involving VTB (initially issued 28 February). It expanded the definition of subsidiary to any entity owned or controlled by VTB and updated references to relevant legislation. Any act which would otherwise breach the prohibitions in Regulations 11 to 17A of the Russia Regulations is permitted to the extent required to give effect to the permissions in the license. The United Kingdom amended the license again on 9 March to "clarify whether funds owed to VTB ought to be placed into a blocked account."

According to General Licence INT/2022/1272278 (re VTB), there is no requirement that funds becoming payable to VTB as a necessary part of winding down any transactions with VTB must be paid into a frozen account. With regard to funds becoming payable to any subsidiary of VTB, OFSI suggests parties "consider how the ownership and control provisions in the Russia Regulations could apply to such payment."

The General License allowing for a seven day wind down period in respect of sovereign debt, loans and money market instruments expired on 8 March 2022.

On 9 March, the United Kingdom announced new aviation and trade-related restrictions related to Russia. Further details can be found here.

The United Kingdom also issued a General License to permit flight data providers to make payment(s) directly or via a relevant institution to Belaeronavigatsia for aeronautical information publication data.

   On 10 March, the United Kingdom updated its general license related to correspondent banking relationships and processing Sterling payments with Sberbank (originally issued on 1 March 2022)

The Licence was amended to add paragraph 4.1: A UK credit or financial institution may continue a correspondent banking relationship with: 1. Sberbank; or 2. A non-UK credit or financial institution which is owned or controlled directly or indirectly (within the meaning of regulation 7 of the Russia Regulations) by Sberbank; or 3. A UK credit or financial institution, which is owned or controlled directly or indirectly (within the meaning of regulation 7 of the Russia Regulations) by Sberbank.