Guidance

Financial sanctions guidance for Russia

Updated 16 May 2024

This guidance is produced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, the authority for the implementation of financial sanctions in the UK. 

This should be considered supplementary to, and not a replacement for, OFSI’s general guidance.

This guidance does not represent legal advice.

If you are unsure about your obligations in a given case, you should consider seeking independent legal advice.

1. What are financial sanctions?

Financial sanctions help the UK meet its foreign policy and national security aims, as well as protect the integrity of its financial system. Financial sanctions include restrictions on designated persons, such as freezing financial assets, as well as wider restrictions on investment and financial services.

Financial sanctions are organised into geographic and thematic regimes. You should consider your exposure to thematic regimes, even if you are operating in a jurisdiction not subject to a geographic regime.  

For general information on financial sanctions, your obligations, and licensing, OFSI provides general guidance available here.

2. The scope of UK financial sanctions

The global nature of the maritime sector means it is important to be aware of the wide-reaching scope of UK financial sanctions.

UK financial sanctions apply to all persons within the territory and territorial sea of the UK and to all UK persons, wherever they are in the world.

This means that:

• all individuals and legal entities who are within or undertake activities within the UK’s territory and territorial sea must comply with UK financial sanctions that are in force
• all UK nationals and legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force, irrespective of where your activities take place

3. Understanding the Russia Regulations

The Russia (Sanctions) (EU Exit) Regulations 2019 (the Regulations) impose financial, trade, transport and immigration sanctions to encourage Russia to cease actions which destabilise Ukraine, including actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

Various amendments to the Regulations have also been published under this regime and should be read alongside this guidance. The Regulations entered into force on 1 January 2020 and replace the previous EU sanctions regime relating to Russia’s actions in Ukraine.  

The names of designated persons (DP) are not included in the Regulations, but instead appear on the OFSI Consolidated List. This enables immediate publication following a decision to make or amend a designation, limiting the opportunity for asset flight. 

Restrictions and obligations

While there are different types of sanctions outlined in the Regulations, this guidance relates to financial and investment restrictions and additional reporting obligations for designated persons and relevant firms.

In addition to asset freezes, which are common among other sanctions regimes, these restrictions include additional unique measures that restrict access to capital markets, loans and credit arrangements, clearing services, dealing in reserves for certain Russian state-owned financial institutions, investments in Russia and investments in non-government controlled Ukrainian territory. There are also restrictions on the provision of trust services. 

They also detail restrictions on investments in relation to the Republic of Crimea and the city of Sevastopol. 

Any exceptions related to each restriction, including instances where you may be able to apply for a licence from OFSI, are also outlined.

To achieve their purposes, the Regulations impose a number of prohibitions and obligations. The Regulations establish penalties and offences to enforce these, which are set out in detail in the corresponding report made under section 18 of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) and the supporting Russia (Sanctions) (EU Exit) (Amendment) regulations which are available on gov.uk. 

Key definitions

For the purposes of the Regulations:

1. A person connected with Russia is defined as:
   
   • an individual who is, or an association or combination of persons who are, ordinarily resident or located in Russia
   • a person, other than an individual who is incorporated or constituted under the law of Russia, or domiciled in Russia

2. “Government of Russia” means:
   
   • the Presidency of the Russian Federation
   • public bodies and agencies subordinate to the President of the Russian Federation, including the Administration of the President of the Russian Federation
   • the Chairman of the Government of the Russian Federation and the deputies of the Chairman of the Government
   • any Ministry of the Russian Federation
   • any other public body or agency of the Government of the Russian Federation, including the armed forces and law-enforcement organs of the Russian Federation
   • the Central Bank of the Russian Federation

Further guidance

This guidance details instances involving financial sanctions only but there is guidance available on the other types of sanctions restrictions detailed in the Regulations, affecting transport, immigration, and trade sanctions in respect of Russia.

That additional guidance is published by the respective UK government departments which includes the Department for Business and Trade, Home Office and the Foreign Commonwealth and Development Office. Guidance on the ban on provision of maritime services related to Russian oil (the “oil price cap”) is available on the OFSI website.

4. Asset Freezes

The Regulations detail financial prohibitions in relation to designated persons. DPs are persons (natural or legal) who are subject to financial sanctions. These sanctions include but are not limited to: asset freezes, restrictions on making funds and or economic resources available to, or for the benefit of, DPs, either directly or indirectly.

There are exceptions to some of the asset freezing provisions which apply within certain defined circumstances. Additionally, where a DP’s assets have been frozen, the person or a representative may apply for a licence from OFSI to enable an otherwise prohibited use of frozen funds or economic resources, in certain circumstances. For further information on asset freezes, see OFSI’s general guidance

5. Specific restrictions: financial services and investments

5.1 Transferable securities or money-market instruments

The Regulations detail prohibitions on dealing in certain transferable securities and money market instruments. They prohibit dealing with, directly or indirectly, a transferable security or money market instrument if it has a maturity exceeding 30 days and was issued after 1 August 2014 by the following listed in the box below:

• Sberbank
• VTB Bank
• Gazprombank
• Vnesheconombank (VEB)
• Rosselkhozbank
• an entity incorporated or constituted in a country other than the UK which is owned directly or indirectly by one or more of the banks listed above

The Regulations also prohibit dealing, directly or indirectly, with a transferable security or money market instrument if it has a maturity exceeding 30 days and was issued after 12 September 2014 by any of the following banks set out in the box below:

• OPK Oboronprom
• United Aircraft Corporation
• Uralvagonzavod
• Rosneft
• Transneft
• Gazprom Neft
• an entity incorporated or constituted in a country other than the UK which is owned, directly or indirectly, by one of these entities.

Prohibitions

1. It is prohibited for a person to deal directly or indirectly with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued after 0:01 on 1 March 2022, if it was issued by a person other than an individual which is:
   
   • incorporated and constituted under the law of the UK and
   • owned by a person falling within Schedule 2
   • a person other than an individual acting on behalf or at the direction of 1 and 2 above

2. It is prohibited for a person to deal directly or indirectly with a transferable security or money-market instrument if it is issued after 0:01 on 1 March 2022 by or on behalf of:
   
   • a person connected with Russia that is not:
       - a person falling within schedule 2
       - a person, other than an individual which at 0:01 on 1 March 2022, is domiciled in a country other than Russia, or a branch or subsidiary of such a person wherever located
   • an entity owned or acting on behalf or at the direction of any of the above

3. It is also prohibited to deal with transferable securities or money market instruments that were issued after 0:01 on 16 December 2022 by:
   
   • a person who is not connected with Russia; and
   • for the purposes of an activity mentioned by Regulation 18B (investments in relation to Russia)

Definitions

1. “Money-market instrument” means an instrument of any kind normally dealt with on the money market, such as treasury bills, certificates of deposit and commercial papers, excluding instruments of payment

-s2.”Transferable security” is a security that’s negotiable on the capital markets, including shares in companies and other securities equivalent to shares in companies, partnerships or other entities, and depositary receipts in respect of shares. It also includes bonds or other forms of securitised debt, including depositary receipts in respect of such securities.

Other securities that give the right to purchase or sell any security of a kind mentioned above are also covered by the term. However, these do exclude instruments of payment

5.2 Loan and credit arrangements

You must not, directly or indirectly, grant, or enter into any arrangement to grant a new loan or credit with a maturity exceeding 30 days (a category 1 loan) to:

• Sberbank
• VTB Bank
• Gazprombank
• Vnesheconombank (VEB)
• Rosselkhozbank
• OPK Oboronprom
• United Aircraft Corporation
• Uralvagonzavod
• Rosneft
• Transneft
• Gazprom Neft
• an entity incorporated or constituted in a country other than the UK which is owned by one of the abovementioned entities, or an entity acting on behalf or at the direction of one of the above entities

Some entities listed immediately above which appear in Schedule 2 of the Regulations are also subject to an asset freeze. To see all individuals and entities subject to an asset freeze, please consult OFSI’s consolidated list.

Prohibitions

1. After 0:01 on 1 March 2022, you must not directly or indirectly, grant, or enter into any arrangement to grant any loan or credit with a maturity exceeding 30 days (a category 2 loan) to an entity which is incorporated or constituted under the law of the UK and owned by an entity listed under Schedule 2.

2. After 0:01 on 1 March 2022, you must not directly or indirectly, grant any loan or credit (a category 3 loan) to:
   
   • a person other than an individual, connected with Russia
   • the government of Russia
   • which is not either a category 1 or category 2 loan, or a loan made or granted to a person other than an individual which is domiciled in a country other than Russia

3. After 0:01 on 29 October 2022, you must not directly or indirectly, permit or enter into, any arrangement to grant a loan or credit with maturity exceeding 30 days (a category 5 loan) to:
   
   • a person connected with Russia other than a person who on 29 October 2022 is incorporated or constituted in a country other than Russia; or a person owned by the above
   • a person owned by a person connected with Russia
   • a person which is owned by a person connected with Russia who is an individual

4. After 0:01 on 16 December 2022 you must not directly or indirectly permit, or enter into any arrangement to grant any loan or credit to a person who is not a person connected with Russia (a category 6 loan) where:
   
   • The purpose of the loan is for an activity mentioned by Regulation 18B
   • It is also prohibited to make funds or economic resources available to a person, which is not a person connected with Russia, where the purpose of making those funds or economic resources available is to enable that person to grant a loan that would otherwise be prohibited by Regulation 17

5.3 Correspondent banking relationships

There are prohibitions on correspondent banking relationships.

A UK credit or financial institution must not establish or continue a correspondent banking relationship with:

• a designated person
• a UK credit or financial institution which is owned or controlled directly or indirectly by a DP
• a non-UK credit or financial institution which is owned or controlled directly or indirectly by a DP

A UK credit or financial institution is also prohibited from processing a sterling payment to, from or via a designated person, or a credit or financial institution which is owned or controlled directly or indirectly by the designated person, if it has reasonable cause to suspect that the payment is to, from or via a designated person.

Processing a payment includes clearing and settling a payment. This applies to payment chains or third party payments.

5.4 Foreign exchange reserve and asset management

A UK individual or entity must not provide financial services for the purpose of foreign exchange reserve and asset management to:

• the Central Bank of the Russian Federation
• the National Wealth Fund of Russian Federation
• the Ministry of Finance of the Russian Federation
• a person owned or controlled, directly or indirectly, by any of the persons above
• a person acting on behalf of, or at the direction of, any of the persons above

Foreign exchange reserve and asset management means activities relating to the reserves or assets of the persons listed above. This includes:

• money market instruments (including cheques, bills and certificates of deposit)
• foreign exchange
• derivative products (including futures and options)
• exchange rate and interest rate instruments (including products such as swaps and forward rate agreements)
• transferable securities
• other negotiable instruments and financial assets (including bullion) and special drawing rights

Exceptions

The prohibitions outlined in relation to loans and credit arrangements are not breached if any of the following are granted:

• a relevant loan that makes emergency funds available to meet applicable solvency or liquidity criteria for a relevant subsidiary, as defined in the Regulations
• a relevant loan consisting of a drawdown or disbursement made under an arrangement that was entered in to before either:
      • 15 September 2014 for a category 1 loan
      • 0:01 on 1 March 2022 for a category 2 or category 3 loan

There is an exception for the processing of sterling payments. This does not apply to the processing of a sterling payment for any fee or charge required to permit an aircraft to overfly, land in or take off from Russia.  

The national security or prevention of serious crime exception applies to all prohibitions.

6. Investments in relation to Crimea

Any reference to Crimea in the Regulations means the Autonomous Republic of Crimea and the city of Sevastopol.

Under the Regulations, it is prohibited to directly or indirectly, extend a participation, or acquire any ownership interest, in land located in Crimea. The same restrictions also apply when it comes to acquiring any ownership interest in an entity which has a place of business located in Crimea (a “relevant entity”).

There is also a prohibition on granting any loan or credit to a relevant entity. This prohibition includes entering into any arrangement to grant a loan or credit, or otherwise provide funds, including equity capital, to a relevant entity, or for the purpose of financing any such entity.

It is prohibited to establish a joint venture in Crimea or with a relevant entity.

It is also prohibited to provide any investment services directly related to any of the activities listed above.

Exceptions

Provided that a person notifies HM Treasury no later than five working days before the day on which an act is carried out, no prohibition relating to investments in Crimea are contravened by a person meeting an obligation under a contract that was concluded before 20 December 2014. This includes an ancillary contract necessary to satisfy such a contract. Additionally, the prohibitions on investments in Crimea are not contravened by a person operating outside Crimea where the related investment is not destined for an entity in Crimea.

Additionally, where an activity would otherwise be prohibited in relation to investments in Crimea, a person or their representative may apply for a licence from OFSI to carry out those activities in certain circumstances. OFSI expects that legal and professional advisers will have fully considered the relevant law and formed a view about an application before approaching OFSI for guidance or submitting an application. All applications are assessed against the relevant Regulations and are done so on a case by case basis.

7. Investments in Russia

There are prohibitions on investing in Russia, in addition to the loans and transferable securities prohibitions in the Regulations. You are restricted from making direct acquisitions of any ownership interest in land in Russia and in persons (other than individuals) connected with Russia. You are also prohibited from making indirect acquisitions of any ownership interest in land or persons (other than individuals) connected with Russia (for example acquisitions of ownership interest in third-country firms which own land in Russia or own persons connected with Russia) for the purpose of making funds or economic resources available to or for the benefit of persons connected with Russia. You are also prohibited from direct or indirect acquisitions of any ownership or control interest in persons which are not persons connected with Russia, for that purpose.

The establishment of certain commercial arrangements in Russia is also prohibited. Namely, establishing new branches, offices and subsidiaries in Russia, as well as joint ventures with persons connected with Russia.

Providing investment services directly related to any of the above activities is prohibited.

Where these activities would otherwise be prohibited and the exceptions below do not apply, a person may apply for a licence from OFSI to carry out activities in certain specified circumstances. These can be found in Regulation 7 of the Regulations.

Exceptions

None of these prohibitions will be contravened by a person undertaking an act to meet an obligation under a contract that was concluded before 19 July 2022 (or an ancillary contract necessary for the satisfaction of that contract), provided that person notifies HM Treasury no later than 5 working days before the day on which an act is carried out.

Additionally, the above prohibitions are not contravened by dealing with relevant transferable securities as defined in the Regulations. In particular:

• if this would be prohibited under Regulation 16 of the Russia Regulations
• relevant transferable securities issued by:
      • a person connected with Russia where the security was admitted to trading on a regulated market or multilateral trading facility prior to 19 July 2022
      • securities that are negotiable on the capital market and are issued by persons who are not connected with Russia for the purpose of an activity that is not prohibited by Regulation 18B

8. Trust services

There are prohibitions on providing trust services to or for the benefit of persons connected with Russia and designated persons.

In particular, a UK person anywhere, or person within the UK, must not provide trust services:

• to or for the benefit of a person connected with Russia unless pursuant to an ongoing arrangement pursuant to which that person provided those services to or for the benefit of the person connected with Russia immediately prior to 16 December 2022
• to or for the benefit of a person designated for the purposes of Regulation 18C (trust services)

The provision of trust services means:

• creating a trust or similar arrangement
• providing a registered office, business address, correspondence address, or administrative address for a trust or similar arrangement
• operating or managing a trust or similar arrangement
• acting or arranging for another person to act as a trustee of a trust of similar arrangement

Exceptions

The prohibitions outlined in relation to the provision of trust services do not apply if the trust services are provided in relation to discharging or complying with obligations for purposes including:

• the discharge or compliance with UK statutory or regulatory obligations
• the maintenance of an asset freeze
• dealing with transferable securities or money market instruments where such dealing with is not prohibited by Regulations 16 (securities restrictions) and 18B (investment restrictions)

The trust services restrictions are also not contravened if the services are not provided primarily to, or for the benefit of, a designated person or person connected with Russia and are provided in respect of:

• community amateur sports clubs registered with HMRC
• certain UK charities
• registered pension schemes
• certain activities relating to financial services and markets.

The trust services restrictions also do not apply if the services are not provided primarily to or for the benefit of a designated person and are provided for making funds and economic resources available to or for the benefit of a minor, or vulnerable adult.

9. Licensing

9.1 Asset freezes

Where a transaction involves a designated person who is subject to an asset freeze, you may be able to obtain a licence to allow the activity to take place without breaching financial sanctions.

OFSI may issue a licence in respect of the asset freeze prohibitions for:

• basic needs
• legal services
• maintenance of frozen funds and economic resources
• extraordinary expenses
• pre-existing judicial decisions
• extraordinary situation
• prior obligations
• consular posts
• humanitarian assistance activity
• medical goods and services
• production or distribution of food for the civilian population
• diplomatic missions

9.2 Securities, loans and credits

OFSI may issue a licence under the securities, loans and credit restrictions for:

• humanitarian assistance activity
• medical goods and services
• production or distribution of food for the civilian population
• diplomatic missions
• space activity
• extraordinary situation

9.3 Correspondent banking relationships and payment processing

OFSI may issue a licence under the correspondent banking relationships and processing payments restrictions for:

• basic needs
• legal services
• financial regulation
• extraordinary situations
• humanitarian assistance activity
• medical goods and services
• production or distribution of food for the civilian population
• diplomatic missions
• space activity

9.4 Foreign exchange reserve and asset management

OFSI may issue a licence under the prohibitions relating to foreign exchanges reserve and asset management for:

• humanitarian assistance activity
• financial regulation
• financial stability
• safety and soundness of a firm
• extraordinary situation

9.5 Investment in Crimea

OFSI may issue a licence under the investments in Crimea restrictions for

• consular posts
• medical and educational purposes
• health and the environment

9.6 Trust services

OFSI may issue a licence under the trust services restrictions for:

• extraordinary situations
• humanitarian assistance activity
• medical goods and services
• production or distribution of food to the civilian population
• diplomatic missions
• safety and soundness of a firm
• financial regulation
• financial stability
• unauthorised unit trusts

9.7 General licences

OFSI has issued General Licences under this regime. For details of the General Licences that are in force, please visit OFSI’s General Licence page.

For more details on OFSI’s specific licences and to find out how to apply for a licence, please visit OFSI’s licensing page.

9.8 Trust services General Licence

OFSI has issued a wind down General Licence which permits a person to undertake any activity, otherwise prohibited by the trust services sanctions, necessary to terminate an arrangement between them and a designated person (designated for the purposes of Regulation 18C) for that person to provide trust services.

The General Licence does not permit activity in breach of the asset freeze or that is exempt under Regulation 60ZZB (1) (b). The wind down period provided for by the General Licence is 90 calendar days, effective from the date of designation of the person to whom the trust services are being provided for the purposes of Regulation 18C, and will expire at 23:59 on the 90th day.

Any persons intending to use the General Licence should first consult the copy of the Licence and refer to OFSI’s general guidance. 

Any person using the General Licence must report the following to OFSI within 30 calendar days of undertaking any activity under the General Licence:

• details of the designated person(s)
• participants to the trust who are owned or controlled by a designated person or who are not owned or controlled by a designated person but are providing trust services to or for their benefit
• value and type of assets
• details of activity undertaken under the General Licence.

The reporting form can be found on our trust services sanctions page and should be emailed to OFSI on completion.

10. Reporting

10.1 Reporting of funds or economic resources for entities listed in Regulation 18A(1) 

If you are a relevant firm and hold any funds or economic resources for a person to whom the provision of certain financial services is prohibited by regulation 18A(1) (“a prohibited person”) you must report this to OFSI as soon as practicable.   

When reporting to OFSI you must include the:  

• nature and amount or quantity of funds and economic resources held
• information or other matter on which the knowledge or suspicion is based

You must complete OFSI’s reporting form and email it to OFSI.

You are also required to submit an annual report to OFSI for so long as the relevant firm continues to hold those funds or economic resources. We provide a standard reporting form to complete and email to us.

The annual report must be made by 31 October and should reflect the nature and amount of quantity of funds and economic resources held as of 30 September in that calendar year.

10.2 Reporting of funds and economic resources owned, held or controlled by designated persons

If you are a designated person (DP) who is designated under the Regulations who is a ”United Kingdom person” within the meaning of s21(2) and (3) of SAMLA, you are required under regulation 70A(1) to disclose any funds or economic resources you own, hold or control and the nature, value and location of those funds or economic resources regardless of where in the world they are located.  

If you are a DP who is not a United Kingdom person you are required to report under regulation 70A(2) the nature, value and location of your UK funds and economic resources.

Your initial report must be provided within 10 weeks of:

• the date the legislation comes into force (26th December 2023)
• the date of designation, whichever is later (the “relevant date”)

Your report should reflect the nature, value and location of your funds and economic resources as at the relevant date.

Any subsequent change in financial circumstances must be reported to OFSI as soon as practicable.

You must report any funds or economic resources if the value of those funds or economic resources exceeds the value of £10,000. If multiple funds or economic resources of the same type (for example, jewellery, art, bank accounts), taken together exceed £10,000, this must also be reported. 

OFSI’s designated person reporting form can be used to make your report – please complete and email it to us.

It is an offence to, without reasonable excuse, fail or refuse to comply with this obligation. It is also an offence to, knowingly or recklessly, give information which is false in a material particular. However, as noted below, OFSI can impose civil monetary penalties for breaches of regulation 70A on a strict civil liability basis.

The substance of the above guidance, adjusted as appropriate, also applies to the reporting requirements in Regulation 38A of the Belarus Regulations.

11. Powers and penalties

11.1 Powers given to HM Treasury to impose penalties for breaches of Regulation 70A

OFSI has the power to impose a monetary penalty for non-compliance. The permitted maximum for any monetary penalty for non-compliance with this obligation is set out at regulation 88C.

(1A) The Treasury may impose a monetary penalty on a person if they are satisfied, on the balance of probabilities, that the person has committed an offence under regulation 70A (designated persons: reporting obligations).

(5) The amount of the penalty under paragraph (1), (1A) or (3) is to be such amount as the Treasury may determine but it may not exceed the permitted maximum.

(6A) Where it is possible to estimate the value of the funds or economic resources which the Treasury have not been informed of under regulation 70A(1), (2) or (5) (as the case may be), the permitted maximum is the greater of
(a)  £1,000,000
(b)  50% of the value of the funds or economic resources which the Treasury have not been informed of.

(7) In any other case, the permitted maximum is £1,000,000.

OFSI can impose civil monetary penalties for breaches of regulation 70A on a strict civil liability basis. This means there is no requirement for OFSI to consider whether a person acted without reasonable excuse, or with knowledge or recklessness when considering whether to issue a civil monetary penalty. However, OFSI will still need to demonstrate on the balance of probabilities that a breach occurred. This amendment applies to consideration of civil liability and the imposition of a monetary penalty and is not relevant to any assessment of whether a criminal offence has been committed under sanctions regulations.

The obligation is enforced by OFSI through a robust civil enforcement regime backed up by a criminal prosecution option.

The substance of the above guidance, adjusted as appropriate, also applies for breaches of Regulation 38A of the Belarus Regulations.

11.2 Case Assessment Process for breaches of Regulation 70A

OFSI will carry out assessments on a case-by-case basis and will take several factors into account when assessing a case, that can either aggravate or mitigate, when determining the facts and how seriously OFSI view a case. These can include the following:

• the financial value (which may be a reasonable estimate) of the unreported assets
• an assessment of the harm, or the risk of harm, done to the sanctions regime’s objectives
• the behaviour of the designated person including, for example, whether the breach appears to be deliberate or not
• the intentional participation in activities knowing that the object or effect of them is (directly or indirectly) to circumvent any of the prohibitions or to enable or facilitate the contravention of any such prohibition or requirement

OFSI takes circumvention very seriously. It attacks the integrity of the financial system and damages public confidence in the foreign policy and national security objectives that the sanctions regimes support.

The above process also applies for breaches of Regulation 38A of the Belarus Regulations.

11.3 Process for imposing a penalty for breaches of Regulation 70A

The monetary penalty threshold is reached if the case meets the test in r88C(1A) of the Regulations; that is, on the balance of probabilities, there has been a breach.

Due to the strict and non-ambiguous nature of this obligation, OFSI generally considers breaches of this obligation as a serious offence. OFSI will assess each suspected breach on its merits to create a monetary penalty recommendation. If the penalty threshold is reached, we may impose a penalty.

This recommendation is then considered by a decision maker, who can decide to agree, change or reject the recommendation. If OFSI is minded to impose a monetary penalty, this is then communicated to the person on whom OFSI intends to impose the penalty. They have a right to make representations which could change OFSl’s view on whether a monetary penalty should be imposed, or the value of any penalty.

The above process also applies for breaches of Regulation 38A of the Belarus Regulations.

If you find out that a person or organisation you are dealing with is subject to financial sanctions as detailed in the Regulations, you must immediately:

• stop dealing with them
• freeze any assets you are holding for them

Email OFSI with details as soon as possible.