Russia Sanctions: This week the United Kingdom updated the listings for several sanctioned persons by making 17 amendments to designated individuals and 10 amendments to designated entities. The amendments included revisions to dates of birth, addresses, and descriptions.
General Licenses: On August 5, 2022, the United Kingdom issued general license (“GL”) INT/2022/2055384. The GL allows UK persons to use the retail banking services of credit institutions and financial institutions designated under Regulation 5 of the Russian Regulations to make or receive payments that are exclusively for the purpose of winding down business operations in Russia. Authorized payments include the payment of “staff salaries, taxes, regulatory fees and other fees to official government bodies, and payment of bills or invoices.” The GL includes a reporting requirement. Any person making or receiving a payment pursuant to the GL must report to HM Treasury (i) the amount(s) and purpose of payments, (ii) the payment method used, and (iii) the date on which the payments were made.
Enforcement: The U.S. Department of Justice (“DOJ”) obtained a seizure warrant (the “Seizure Warrant”) from the U.S. District Court for the Southern District of New York authorizing the seizure of an airplane (the “Airplane”) belonging to sanctioned Russian oligarch Andrew Skoch. The Airplane is an Airbus A319-100, and is estimated to be worth more than $90 million. OFAC designated Skoch as a Specially Designated National (“SDN”) in April of 2018. The investigation was coordinated through DOJ’s Task Force KleptoCapture, which was established in March 2022 to enforce U.S. sanctions, export controls, and other economic countermeasures imposed by the United States in response to Russia’s invasion of Ukraine, including through criminal prosecutions and the seizure and forfeiture of assets. In an affidavit in support of the Seizure Warrant, a Bureau of Industry and Security law enforcement agent claimed that the Airplane was subject to seizure and forfeiture as property involved in a money laundering transaction or attempted money laundering transaction.