Expansion of the list of designated persons
UK blocking sanctions targeted 34 individuals and 33 legal entities, including:- major Russian companies and businessmen involved in the sectors of strategic significance to the Russian economy, including Siberia Airlines JSC (S7) and its shareholder V.F. Filev, Avilon AG JSC and its former president A.O. Pavlovich, majority shareholder of Expobank JSC I.V. Kim, majority shareholder of Irkutsk Oil Company LLC N.M. Buinov, founder and general director of Akron Holdings P.A. Morozov and others;
- state-owned entities involved in the Russian defence sector, including Federal State Unitary Enterprise “Main Center of Special Communication” and its head I.A. Gaychenya, Federalnoe Kazennoe Predpriiatie Gosudarstvennyi Nauchno-Issledovatelskii Institut Khimicheskikh Produktov, Scientific and Production Enterprise Salyut JSC and Russian Academy of Sciences Siberian Branch Khristianovich Institute of Theoretical and Applied Mechanics;
- Russia-based importers of dual-use goods and suppliers to the Russian defence sector, including Intervesp LLC, TM Tech LLC and its shareholder T.V. Khomenko, Grant-Trade LLC, its participant and director M.D. Mustafaev, as well as his sister D.D. Mustafaeva and others;
- 16 international suppliers to the Russian defence sector (from China, Thailand, Germany, India, Turkey, Kyrgyzstan and the UAE), as well as their owners and managers;
- Russian government officials — senator A.B. Kanokov and Deputy Minister of the Ministry of Civil Defence, Emergencies and Disaster Relief D.G. Popov; and
- DPRK Defence Minister and other high-ranking DPRK officials.
Furthermore, UK blocking sanctions also targeted 40 “shadow fleet” ships carrying Russian oil.
It should be separately noted that for the first time UK sanctions have been imposed on a foreign financial institution, KeremetBank OJSC (Kyrgyzstan). The UK regulator cited the bank’s activities in the Russian financial services sector as the basis for the restrictive measures adopted.
We remind you that on 15 January 2025, the US also imposed blocking sanctions on KeremetBank OJSC. According to the US Department of the Treasury’s Office of Foreign Assets Control, this bank coordinated with Russian officials and US-designated Promsvyazbank PJSC to implement a sanctions evasion scheme.
Effects of UK blocking sanctions
The abovementioned sanctions measures became effective on the date they were imposed — 24 February 2025. As at the date of this Legal Update, the UK has not issued any new general licences in connection with these sanctions restrictions.As a reminder, the blocking sanctions impose the following obligations on UK PersonsAny individuals within the UK, irrespective of nationality; UK citizens, irrespective of where they are located; UK registered legal entities and their branches; and any persons on board any aircraft or vessel under the jurisdiction of the UK (“UK Persons”). UK sanctions restrictions on Russia apply to British Overseas Territories (excluding Bermuda and Gibraltar).:
- to freeze (block) 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 prior authorisation in the form of a licence).
Significance
Despite the UK regulator’s statement that the new sanctions package is the largest since 2022, the sanctions restrictions are being strengthened by expanding existing measures and the list of designated persons, rather than by introducing new sectoral sanctions. Nevertheless, the previously planned course of imposing sanctions on foreign persons involved in circumventing sanctions against Russia and supply chains of sanctioned goods to Russia is also being developed.Particular attention is drawn to the imposition of sanctions by the UK against a foreign financial institution — Kyrgyz KeremetBank OJSC. This step followed similar measures taken by the US, which once again shows that the UK closely monitors the sanctions measures of other countries and takes into account the information received when implementing its own sanctions policy.
