Feb 14-24 - UK announces most extensive sanctions package against Russia since 2022, along with other changes

In the last week, the UK has announced several significant SANCTIONS changes/updates:

Key Sanctions Changes

1. Largest Sanctions Package Against Russia: On February 24, 2025, THE UK FOREIGN, COMMONWEALTH, AND DEVELOPMENT OFFICE announced over 100 new sanctions targeting Russian military supply chains, revenues, and key individuals supporting the invasion of Ukraine.

1. https://www.gov.uk/government/news/uk-announces-largest-sanctions-package-against-russia-since-2022

2. Sanctions on Russian Elites: THE HOME OFFICE imposed travel bans on several oligarchs linked to the Kremlin. https://www.gov.uk/government/news/kremlin-linked-elites-face-exclusion-from-uk  - oligarchs included in the list now include:

1. Roman Abramovich: Former owner of Chelsea FC and a prominent figure with close ties to the Kremlin.
2. Alisher Usmanov: A billionaire industrialist and one of Russia’s wealthiest individuals.
3. Igor Sechin: CEO of Rosneft, a prominent Russian oil company and a close ally of Vladimir Putin.
4. Oleg Deripaska: An industrialist interested in aluminium and energy sectors.
5. Viktor Vekselberg: Chairman of Renova Group, a large conglomerate with diverse business interests.

3. General License for International Organisations: On February 21, 2025, THE OFFICE OF FINANCIAL SANCTIONS IMPLEMENTATION (OFSI) issued a general license allowing specific international organisations to receive subscription fees from the Russian government.

1. On February 21, 2025, OFSI issued General License INT/2025/5855272, which authorises certain International Organisations to receive subscription fees and any other payments required from the Government of Russia to retain membership of those organisations, subject to certain conditions, including that the funds are transferred from an account held with Gazprombank.  The international organisations are trade organisations based in the UK with recognised diplomatic status, including the International Renewable Energy Agency, the International Sugar Organisation, and the North Atlantic Salmon Conservation Organisation. The General License expires on 20 February 2030. 

1. 1. 1. (GL_Membership_fees_for_International_Organisations.pdf)
      2. https://assets.publishing.service.gov.uk/media/67b882a1d157fd4b79addce9/GL_Membership_fees_for_International_Organisations.pdf

4. Public Sector Contracts Guidance: Updated guidance was issued on February 18, 2025, advising public sector organisations to consider terminating contracts with suppliers from Russia and Belarus if feasible alternatives are available.

1. On February 18, 2025, the UK Government updated Procurement Policy Note 007 (“PPN”) and related FAQs relating to public sector contracts with suppliers from Russia and Belarus.  The PPN states that in-scope organisations should consider terminating contracts where a Russian or Belarusian prime contractor is identified and a feasible alternative supplier can be sourced. 

1. 1. 1. (PPN 007: Contracts with suppliers from Russia and Belarus (HTML) - GOV.UK; PPN 007: Contracts with suppliers from Russia and Belarus FAQs (HTML) - GOV.UK)
      2. https://www.gov.uk/government/publications/ppn-007-contracts-with-russia-and-belarus/ppn-007-contracts-with-suppliers-from-russia-and-belarus-faqs-html

Other updates

Syria sanctions

• General License for humanitarian relief to Syria and Turkey expires: 
• On February 14, 2025, General Licence INT/2023/2711256 expired.  The General Licence, which allowed specific international organisations and NGOs to carry out activities necessary to facilitate humanitarian assistance in earthquake relief efforts in Syria and Turkey, expired at 23:59 on February 14, 2025.  The General Licence was moved to the UK Government's Expired General Licences page on February 17, 2025.
• (Syria_Humanitarian_GL_INT-2023-2711256_.pdf; Expired General Licences - GOV.UK)
• https://assets.publishing.service.gov.uk/media/667bca1d97ea0c79abfe4c45/Syria_Humanitarian_GL_INT-2023-2711256_.pdf

Global Human Rights Sanctions

• UK Government amends one entry on the UK sanctions list under the Global Human Rights regime: 
• On February 19, 2025, the UK Government amended the entry for Eden Levi under the Global Human Rights regime.  The entry was updated to include Levi's date of birth and national ID number.  Levi remains subject to an asset freeze. 
• (Notice_Global_Human_Rights_190225.pdf)
• https://assets.publishing.service.gov.uk/media/67b59f7e4e79a175a4c2feac/Notice_Global_Human_Rights_190225.pdf

These measures were implemented by various UK government departments, including

• The Foreign, Commonwealth, and Development Office,
• The Home Office, and
• The Office of Financial Sanctions Implementation.

Source: 

1. UK Announces Largest Sanctions Package Against Russia since 2022. https://www.novinite.com/articles/231008/UK+Announces+Largest+Sanctions+Package+Against+Russia+since+2022 .
2. The UK has announced the largest sanctions package against Russia since 2022. https://www.gov.uk/government/news/uk-announces-largest-sanctions-package-against-russia-since-2022 .  
3. Fresh sanctions on Russian elites will ‘bolster UK national security’. https://www.politics.co.uk/news/2025/02/24/fresh-sanctions-on-russian-elites-will-bolster-uk-national-security/ .
4. UK Weekly Sanctions Update - February 17, 2025. https://www.mayerbrown.com/en/insights/publications/2025/02/uk-weekly-sanctions/copy-of-uk-weekly-sanctions-update---week-of-february-17-2025 .  
5. https://assets.publishing.service.gov.uk/media/67b882a1d157fd4b79addce9/GL_Membership_fees_for_International_Organisations.pdf
6. https://assets.publishing.service.gov.uk/media/67b59f7e4e79a175a4c2feac/Notice_Global_Human_Rights_190225.pdf
7. https://www.gov.uk/government/publications/ppn-007-contracts-with-russia-and-belarus/ppn-007-contracts-with-suppliers-from-russia-and-belarus-faqs-html