UK: RUSSIA SANCTIONS GENERAL LICENCE RE GAZPROMBANK AND AMENDS GENERAL LICENCE RE ALFA BANK JSC, GAZPROMBANK, ROSSELKHOZBANK, SMP BANK AND THE URAL BANK FOR RECONSTRUCTION AND DEVELOPMENT

On 21 April, a Notice from HM Treasury advised that a new General Licence had been granted to allow payments to Gazprombank or a subsidiary for the purpose of making gas available in the EU.  It takes effect from 21 April and expires on 31 May.

It also advised that the General Licence pertaining to Alfa Bank JSC, GazPromBank, Rosselkhozbank, SMP Bank and the Ural Bank for Reconstruction and Development had been amended.  Note that this Licence expires anyway on 23 April. In any case, the amendment reads as follows –

Regarding whether funds owed by the DPs [designated persons] ought to be placed into a blocked account, General Licence INT/2022/1424276 does not contain a requirement that funds becoming payable to the DPs as a necessary part of a person winding down any transactions they have with the DPs be paid into a frozen account. With regard to funds becoming payable to any subsidiary of the DPs as a necessary part of a person winding down any transactions they have with those subsidiaries needing to be paid into a frozen account, OFSI does not provide legal advice but without prejudice to that we suggest you consider how the ownership and control provisions in the Russia Regulations could apply to such payment.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1070507/INT.2022.1630477_Gazprombank_gas_payments_publication_notice.pdf

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1066998/INT20221544176_PN.pdf

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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