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UK introduces new sanctions against Russia

legal updates
26 / 02 / 2024

Extension of the list of designated persons

On 22 February 2024, the UK announced new blocking sanctions that affected 50 Russian and non-Russian individuals and businesses linked to the Russian defence industry, metals industry, the manufacture and supply of electronics, diamonds, energy trade, etc.

The blocking sanctions were imposed on 21 individuals most of whom are the top managers of Russian companies (including Alrosa, Mechel, Novatek, OMK and UGMK), including:

  • Mr P.A. Marinychev, the CEO and Chairman of the Board of Alrosa, and other top managers of the company: Mr E.Y. Agureev, Mr S.V. Barsukov, Mr A.N. Filippovskii and Mr I.V. Sobolev;
  • Mr A.E. Natalenko, Chairman of the Board of Directors of Novatek, and other members of the Board of Directors: Mr. L.V. Feodosyev, Ms I.V. Gaida, Mr V.A. Kryukov, Mr V.G. Nesterenko and Mr O.V. Orel; and
  • Mr I.V. Zyuzin, Chairman of the Board of Directors for Mechel.
The UK blocking sanctions also clamped down on 29 legal entities, of which:

  • 19 entities are Russian companies, including Arctic LNG 2, AZIA Shipping Company, Kamensk-Uralskiy Metallurgicheskiy Zavod and Samara Metallurgical Plant; and
  • 10 entities are foreign companies from China, the Marshall Islands, the UAE, Türkiye and Switzerland. More specifically, sanctions against the Turkish companies Active Denizcilik Ve Gemi İşletmeciliği Anonim Şirketi and Beks Gemi İşletmeciliği Ve Ticaret Anonim Şirketi, the Swiss company Paramount Energy & Commodities SA and the UAE-based company Fractal Marine Dmcc were introduced for operations in the Russian energy sector, and those against the Chinese company Beijing Micropilot Flight Control Systems Co., for shipping UAV components to Russia.
Some companies (for example, Active Denizcilik Ve Gemi İşletmeciliği Anonim Şirketi) have already made statements assuring they had not breached UK sanctions and intend to challenge their designation.

Effects of the UK blocking sanctions

The mentioned sanctions took effect on the date they were imposed — 22 February 2024. As at the date of this alert, the UK has not issued new general licences in connection with these sanctions restrictions.

As a reminder, the blocking sanctions impose the following responsibilities on UK Persons
  • Any individuals within the UK territory, irrespective of their citizenship;
  • UK citizens irrespective of where they are located;
  • legal entities and their branches registered in the UK;
  • Any persons on board an aircraft or vessel under the jurisdiction of the UK (“UK Persons”). The UK sanctions restrictions on Russia apply to the British Overseas Territories (except for the Bermuda Islands and Gibraltar).

  • to freeze (block) the assets of designated persons: funds, securities, movable and immovable property, etc; and
  • to refrain from making funds or economic resources available directly or indirectly to or for the benefit of designated persons (in the absence of a prior approval in the form of a licence).
These restrictive measures also apply to legal entities that are directly or indirectly (by more than 50%) owned or controlled by designated persons.

Other potential measures

Along with the sanctions restrictions outlined above, in the official statement the UK’s foreign secretary also mentioned measures that are yet to come. We are referring, among others, to tougher measures aimed at:

  • ensuring compliance with the oil price cap for oil and petroleum products of Russian origin; and
  • tackling the so-called “shadow fleet” used by Russia to export oil and petroleum products.


The new UK sanctions show the exhaustion of the restrictive measures’ potential. The restrictive measures now consist of the extension of already existing sanctions and the designated persons list.

At the same time, they put at risk smaller Russian companies and their top management, as well as foreign companies that are engaged in shipping sanctioned goods and technology to Russia (dual-use and military goods and technology in the first place) or operate in the sanctioned sectors of the Russian economy (in the energy sector in the first place).