Financial Sanctions: Russia

Wednesday, 26 June 2024

This news release is issued to publicise the amendment of 4 entries under the Russia sanctions regime.

The Russia (Sanctions) (EU Exit) Regulations 2019 have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 ('the Regulations'), which are made under the Sanctions Act 2024. This regime imposes financial, trade, aircraft, shipping and immigration sanctions for the purposes of encouraging Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine. 

Individuals and entities who are designated under this regime are included on the UK sanctions list.

Types of sanctions applicable under this regime:

  • Asset freeze
  • Other financial and investment restrictions
  • Trade
  • Immigration
  • Aircraft
  • Ships

On 26 June 2024 the Foreign, Commonwealth and Development Office updated the UK sanctions list. This list provides details of those designated under sanctions legislation.

Amendment

The following entries have been amended on the Consolidated List and are still subject to an asset freeze or trust services sanctions.

Deleted information appears in [square brackets]. Additional information appears in italics.

Individuals

  1. BARCHUGOV, Pavel Sergeevich
    DOB: 29/03/1973. POB: Rostov-on-Don, Russia Position: Former Senior Managing Director at Sberbank Other Information: (UK Sanctions List Ref): RUS1601. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 21/03/2023. (UK Statement of Reasons): [Pavel Barchugov is an 'involved person' under the Russia (Sanctions) (EU Exit) Regulation 2019 because he has been, and is, involved in obtaining a benefit from or supporting the Government of Russia by: (1) working as a manager or equivalent of a person (other than an individual) which is carrying on business in a sector of strategic significance to the Government of Russia, namely SBERBANK which carries on business in the financial services sector;  (2) she has been, and is, involved in obtaining a benefit from or supporting the Government of Russia by working as a director, manager or equivalent of a Government of Russiaaffiliated entity, namely SBERBANK (the Government of Russia directly holds more than 50% of the shares in SBERBANK and/or more than 50% of the voting rights in SBERBANK).] Pavel Sergeevich Barchugov is an 'involved person' under the Russia (Sanctions) (EU Exit) Regulations 2019 because he has been involved in obtaining a benefit from or supporting the Government of Russia by: (1) working as a director or equivalent of an entity, Sberbank, which is or has been carrying on business in a sector of strategic significance to the Government of Russia, namely the financial services sector;  (2) working as a director, manager or equivalent of a Government of Russiaaffiliated entity, namely Sberbank (Gender): Male Listed on: 26/09/2022 UK Sanctions List Date Designated: 26/09/2022 Last Updated: [21/03/2023] 26/06/2024 Group ID: 15545

  2. DENISOV, Konstantin Name (non-Latin script): Константин Денисов
    DOB: [25/04/1959.] 25/04/1960 Nationality: Russia Position: Member of ROSATOM’s Management Board Other Information: (UK Sanctions List Ref): RUS1727. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 21/03/2023. (UK Statement of Reasons): Konstantin DENISOV is an 'involved person' under the Russia (Sanctions) (EU Exit) Regulations 2019 because he has been, and is, involved in obtaining a benefit from or supporting the Government of Russia by working as a manager or equivalent of a person (other than an individual) which is carrying on business in a sector of strategic significance to the Government of Russia, namely ROSATOM which is carrying on business in the energy and defence sector. (Gender): Male Listed on: 24/02/2023 UK Sanctions List Date Designated: 23/02/2023 Last Updated: [21/03/2023] 26/06/2024 Group ID: 15765

Entity

  1. FRACTAL MARINE DMCC
    Address: Dubai, United Arab Emirates. Other Information: (UK Sanctions List Ref): RUS2063. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 22/02/2024. (UK Statement of Reasons): FRACTAL MARINE DMCC is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 based on the following ground: FRACTAL MARINE DMCC is or has been involved in obtaining a benefit from or supporting the Government of Russia by carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian energy sector. Listed on: 22/02/2024 UK Sanctions List Date Designated: 22/02/2024 Last Updated: [22/02/2024] 26/06/2024 Group ID: 16392

What you must do

If you suspect a person or entity is a match to a person or entity included in the UK Sanctions List, and you hold or otherwise deal with funds or economic resources of that person:

  1. You must freeze the assets immediately

  2. You must review the information you hold for that person against the UK Sanctions List to ensure you do not have a false positive identification

  3. Do not deal with those assets or make them available to, or for the benefit of the designated person unless:
    • You have a legal exemption
    • You have a licence

  4. You must report the frozen assets to the FIU

If you have a suspicion or knowledge that there has been a breach of sanctions law, or any attempted transactions that you have blocked, report your suspicions to the FIU.

Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.

Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for the designated person, you are not required to report these details again.

Note: determining if a customer is on the UK Sanctions List includes whether any corporate entity is owned or controlled, directly or indirectly, by a person on the UK Sanctions List.

Further guidance on false positives and delistings and what to do can be found in the Financial Sanctions General Guidance page.

Further Information

Further information on the sanctions regime related to Russia and other sanctions related guidance can be found on the Sanctions and Export Control website on the Sanctions Guidance page.

Contact details for enquiries

If you require any further information or guidance, please contact the Sanctions Team on:

Telephone: +44 1624 648109

Email: sanctions@gov.im

Please note: We are unable to provide legal advice. You may need to seek independent legal advice.

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