UK: RUSSIA SANCTIONS – PROHIBITION ON PROVIDING TRUST SERVICES TO OR FOR THE BENEFIT OF CERTAIN PEOPLE OR ENTITIES.

On 21 March, HM Treasury advised that the UK government has acted alongside its international allies to introduce new measures that will prevent Russia from accessing UK trust services. OFSI says that there is there is evidence of UK-based trust and company service providers (TCSP) offering their services to persons to enable them to reduce the impact of sanctions in the event they become subject to them. Changes mean now that the 1,730 persons that are currently designated under regulations imposing an asset freeze are now also designated under regulation 18C (trust services).  This means that it is now prohibited to provide trust services to or for the benefit of these persons, unless permitted by a licence or there is an applicable exception.  The EU Sanctions blog noted that, in addition, 6 entries on the Russia sanctions list, and the entry for PJSC Sberbank.  A new General Licence from HM Treasury provides for a 90-day wind-down period to undertake any activity necessary to terminate an existing arrangement.

https://ofsi.blog.gov.uk/2023/03/21/trust-services-sanctions-update/

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1144418/Trust_Services_General_Licence_INT-2023-2589788.pdf

https://www.europeansanctions.com/2023/03/uk-designates-all-subject-to-trust-services-prohibition-issues-gl/

The Isle of Man followed suit on 21 March –

https://www.gov.im/news/2023/mar/21/financial-sanctions-russia/

https://www.gov.im/news/2023/mar/21/financial-sanctions-russia-general-licence/

https://www.buymeacoffee.com/KoIvM842y

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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