On 25 February, the UK Office for Financial Sanctions Implementation published a general licence permitting the wind-down of transactions involving VTB Bank, its UK subsidiary VTB Capital plc, and VTB Capital plc’s UK subsidiaries (collectively, “VTB“).   This follows the UK’s designation of VTB Bank on 24 February (see our earlier post here).

The licence permits any person (other than VTB) to wind down any transaction to which it is a party that involves VTB, including closing out any positions.  The licence also permits UK financial institutions and VTB to carry out any activity reasonably necessary to effect such wind-down activities.  However, the licence does not otherwise permit funds or economic resources to be provided to a restricted party in breach of the UK’s sanctions against Russia.

The general licence expires on 27 March 2022.  A copy of the licence is available here.