28 Feb 2022
by Lewis Walmesley-Browne

Russia sanctions: what must tech companies do to comply?

Key information sources to help tech companies comply with new sanctions regulations

The UK government, in coordination with other Western powers, has been announcing a series of economic sanctions against prominent Russian companies and individuals as a result of the Russian invasion of Ukraine.

techUK, via our Trade and Customs Compliance Group, is keeping our members up-to-date on the UK’s latest sanctions announcements as they arise. techUK members are encouraged to get in touch and join the TCCG mailing list to receive latest updates.

As the situation is evolving rapidly, we provide below a list of government websites that UK-based companies can use to ensure compliance with the UK’s sanctions regulations.

Sanctions policies: what are your obligations?

UK-based companies should be assessing their existing and prospective business relationships to ensure that you are in compliance with the latest UK sanctions regulations. These are the steps that must be followed:

  1. Check whether you maintain any accounts or hold any funds or economic resources for designated companies/persons (see the links provided below).
     
  2. Freeze such accounts, and other funds or economic resources and any funds which are owned or controlled by designated persons/companies.
     
  3. Refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the Office of Financial Sanctions Implementation (OFSI).
     
  4. Report any findings to OFSI, together with any additional information that would facilitate compliance with the Regulations.
     
  5. Provide any information concerning the frozen assets of designated persons that OFSI may request. Information reported to OFSI may be passed on to other regulatory authorities or law enforcement.

Sanctions policies: where can you find information about designated persons?

As they are published, Russia-related sanctions information including an up-to-date list of designated persons will be posted here: 
https://www.gov.uk/government/publications/financial-sanctions-ukraine-sovereignty-and-territorial-integrity

And any sanctions on Belarus will be here: 
https://www.gov.uk/government/publications/financial-sanctions-belarus

All other financial sanctions regimes can be found here:

https://www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-lists-and-releases

A consolidated list of all persons globally that have been designated by the UK government can be found here:

https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets/consolidated-list-of-targets

 

Authors

Lewis Walmesley-Browne

Lewis Walmesley-Browne

Head of Programme: Market Access and Consumer Tech, techUK