Context
HM Treasury has announced that the UK is to bring in further sanctions targeted at the provision of insurance and reinsurance services for Russian companies. Also, The OFSI has recently confirmed that the ‘dual running period’, in which both the old and new versions of the Consolidated Sanctions List and the list of persons named in relation to financial and investment restrictions were updated simultaneously, has ended. The old versions of these lists will no longer be updated, and the links to the old formats were retired on 28th February 2022.
Key points to note
Insurance-related sanctions announcement
- Russian companies in the aviation or space industry will be prevented from making use of UK-based insurance or reinsurance services directly or indirectly.
- Measures will severely limit the benefits Russian entities receive from their access to the global insurance and reinsurance market.
- The UK Government will bring in legislation to prohibit UK based insurance and reinsurance providers from undertaking financial transactions connected with a Russian entity or for use in Russia.; further details of the legislation will be available in due course.
- Similar actions will be taken by the EU.
The new Consolidated Sanctions Lists
- The OFIS Updated guidance in relation to the Consolidated Lists can be viewed here
- The consolidated lists can be accessed here
- The initial Change Notice outlining the change to the Consolidated Lists can be viewed here
- The Consolidated Lists search tool can be found here
- If you use the links available on GOV.UK to access the Consolidated List and the list of persons named in relation to financial and investment restrictions, in their various formats, there are new links to use to access the consolidated list files in the new format:
Consolidated list:
- Get the HTML version of the consolidated list
- Get the delimited version (.csv) of the consolidated list
- Get the XLSX version of the consolidated list
- Get the PDF version of the consolidated list
- Get the plain text version of the consolidated list
- Get the XML version of the consolidated list
The list of persons named in relation to financial and investment restrictions:
- Get the HTML version of the list
- Get the delimited version (.csv) of the list
- Get the XLSX version of the list
- Get the PDF version of the list
- Get the plain text version of the list
- Get the XML version of the list
Next actions
Please be particularly aware of the ever-increasing number of organisations and individuals being added to the lists in relation to Russia, Russian firms and companies and Russian individuals. Increase the breadth of your searches to include individuals involved in Russian entities (so not just a firm or Company, but its Directors and potentially shareholders). Use the links and resource set out above to perform thorough sanctions searches.