The United Kingdom just issued a new statutory instrument, effective immediately, which extends the authority to designate persons and entities under the U.K. sanctions against Russia.

Previously, the U.K. government could designate persons and entities involved in destabilizing Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.

This is now extended to persons and entities:

  1. Carrying on business as a Russian government-affiliated entity.
  2. Carrying on business of economic significance to the government of Russia.
  3. Carrying on business in a sector of strategic significance to the government of Russia.
  4. Owning or controlling directly or indirectly (...), or working as a director (whether executive or non-executive), trustee or equivalent, of:
    1. A Russian government-affiliated entity.
    2. A person, other than an individual, that falls within sub-paragraph (b) or (c).

We are monitoring potential new U.K. designations. Our London-based sanctions team is available to answer questions.

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