On 24 February 2025, the third anniversary of Russia’s further invasion of Ukraine, the UK Government announced 107 new designations targeting individuals, businesses (including several state-owned entities), government officials and vessels in what it labelled its most extensive set of sanctions against Russia since the start of the invasion. According to the UK Foreign, Commonwealth, and Development Office (“FCDO”) press release, this package is aimed at weakening Russia’s military supply chains, revenues fuelling the war against Ukraine, and “kleptocrats” driving profits for Russia.
The FCDO updated the UK Sanctions List to reflect the imposition of sanctions on 34 individuals and 33 entities, subjecting them and any entities they own or control to asset freezes and other financial and investment restrictions. The FCDO also designated 40 additional “shadow fleet” vessels, subjecting them to certain shipping-related sanctions. The full list of 107 designations is available here.
This UK sanctions package is notable for its designations of third-country “enablers and suppliers” to the Russian defence sector and for targeting a non-Russian financial institution carrying on business in the Russian financial sector, leading to the designation of Kyrgyzstan-based OJSC Keremet Bank.
In addition to Keremet Bank, those sanctioned include:
- Russian state-owned entities and an individual involved in the Russian defence sector;
- Russia-based importers of dual-use goods and suppliers to the Russian defence sector;
- non-Russian “enablers and suppliers” to the Russian defence sector from countries such as China, Germany, India, Kazakhstan, Thailand, Turkey and Uzbekistan;
- DPRK officials supporting Russian military action in Ukraine;
- 40 oil tankers involved in transporting Russian oil;
- Russian government officials; and
- entities and individuals active in strategically significant sectors of the Russian economy, such as the energy (specifically coal mining), financial and transport sectors.
In parallel, the Office of Trade Sanctions Implementation (“OTSI”) updated its Countering Russian sanctions evasion guidance for exporters on 25 February 2025, adding a section 6 to the previous guidance specific to exports and potential re-exports of Common High Priority List items. Please see our previous blog posts on OTSI’s initial implementation of guidance and the establishment of OTSI as a new UK Government agency.
