On 23 June 2021, HM Treasury released updated guidance on financial and investment restrictions under the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations”). Whilst the guidance is substantively the same as that released in June 2020, a number of “Frequently Asked Questions” have been added to clarify interpretation of the Regulations. The Frequently Asked Questions reflect some, though not all, of the guidance previously outlined by the European Commission in relation to its interpretation of the EU Russia Sanctions, as outlined in Regulation 833/2014, as amended.

The Frequently Asked Questions adopted from the European Commission guidance address issues including the application of the exception regarding the financing of non-restricted trade, the application of the sanctions to derivatives transactions, and transactions involving loans and credit arrangements involving sectorialy targeted entities.

The individuals and entities subject to financial sanctions remain unchanged.


Tristan Grimmer is a partner in Baker McKenzie's London office and the UK Head of the International Trade Practice Group. He is also a member of the Compliance & Investigations and the International Trade and Competition practice groups. Tristan joined Baker McKenzie as a trainee in March 2004, qualifying in March 2006. He has advised on parallel investigations by authorities in the United States, Switzerland, Brazil and Japan, and has spent time working in Baker McKenzie's Chicago office. Tristan is named as a "Leading Individual" for EU And Competition: Trade, WTO Anti-Dumping and Customs in the UK Legal 500 2023 directory.