Guidance

Russia sanctions: notes on designations data

Published 10 June 2022

The UK Government publishes data on the UK sanctions relating to Russia’s invasion of Ukraine. This guidance note is to help you understand how the UK Government collates this data on designations and what it means.

The UK Sanctions List provides details of the individuals and entities sanctioned by the UK. These are known as designations. The UK Government has also compiled a timeline of UK sanctions in response to Russia’s invasion of Ukraine.

1. Legislation under which the sanctions are made

The Sanctions and Anti-Money Laundering Act 2018 (The Sanctions Act) is the primary legislation that enables the UK to impose economic and other sanctions, as well as regulations on money laundering and terrorist financing.

Most UK sanctions in the context of Russia’s invasion of Ukraine are made under The Russia (Sanctions) (EU Exit) Regulations 2019. Others are made under The Cyber (Sanctions) (EU Exit) Regulations 2020 and The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019. There are other regulations that can be used but these are beyond the scope of this note. Such regulations include those on anti-corruption; human rights; chemical weapons and other geographical regimes.

If relevant, the UK Government refers to specific sanctions regimes when publishing designations data. Otherwise, data on the UK’s response to the invasion comes from across all regimes.

2. Data collected ‘post invasion’

Reference to UK sanctions since the invasion includes UK sanctions imposed on 22 February 2022, even though the invasion occurred on 24 February 2022.

22 February sanctions are included in our post-invasion data because they represent the UK’s first wave of sanctions in response to Russia’s invasion of Ukraine, notably Russia’s declaration of independence of Donetsk and Luhansk.

3. Designations of individuals (people)

Data on individual people that are sanctioned comes from the UK Sanctions List. When a name is removed from the list, the UK Government also removes it from the full count of individual people sanctioned.

Most individuals are subject to an asset freeze and a travel ban. Some are subject just to an asset freeze. The specific sanctions on each individual are available on the UK Sanctions List.

4. Definition of oligarch

The UK Government uses the following working definition for the purpose of compiling data on UK sanctions in response to Russia’s invasion of Ukraine. A Russian oligarch is a Russian national who is both ultra-high-net-worth and connected to the Putin regime.

5. Oligarch net worth estimates

For global net worth estimates, the UK Government uses the Forbes Billionaires List. For UK reporting up to 21 April 2022, we used the Forbes 2021 Billionaires List. The UK Government converted US dollars into sterling using the IMF daily average 2021 exchange rate of £1 = $1.376, which was calculated using the IMF exchange rate data.

Some oligarchs and their net worths are not included in the Forbes Billionaires List. Our total estimate of oligarchs’ global net worth only includes those oligarchs for whom we have a valuation from the Forbes Billionaires List.

By 21 April, the estimated total global net worth of oligarchs sanctioned by the UK under this method totalled £198 billion. The figure of ’approximately £200 billion‘ was reported in the 21 April press release titled ‘New sanctions targeting Putin’s war leaders’.

For UK reporting after 21 April, the UK Government uses the Forbes 2022 Billionaires List, published on 5 April 2022. We convert US dollars into sterling using the IMF daily average exchange rate of £1 = $1.330. Compared to the 2021 Forbes List, some oligarch valuations have risen but many have fallen in value, and some are not on the 2022 Forbes List.

The estimated total global net worth of oligarchs sanctioned by the UK under this updated method totalled £117 billion. This was reported in the 13 May press release titled ‘UK sanctions the shady network funding Putin’s lavish lifestyle’.

During 2022, the UK Government will continue using the Forbes 2022 Billionaires List as an indication of global net worth. We will continue to use £1 = $1.330 as the exchange rate to maintain consistency and to aid comparison. Note that net-worth valuations are estimates and figures can go up as well as down over time for various reasons.

Note also that the amount of assets frozen by the UK sanction will be only those assets held in the UK financial system and is a smaller amount than the global assets.

6. Oligarch family members

In reporting the number of oligarchs designated, the UK Government also includes sanctioned family members. These include sanctioned spouses, partners, former partners, children, and children’s partners. To date, none of these designated family members have independent Forbes valuations.

7. Entities

The UK Sanctions List includes sanctioned entities. In the context of Russia’s invasion of Ukraine, some of these entities are designated under different sanctions regimes (the Russia regime; the Belarus regime; the Cyber regime).

Some entities are headquartered in Russia, others elsewhere. When referring to sanctioned entities post-invasion, the UK Government includes all entities sanctioned in response to Russia’s invasion of Ukraine, unless noted otherwise.

8. Data on subsidiaries

Some UK Government press releases have referred to sanctioned “individuals, entities and their subsidiaries”. Under the legislation, entities that are owned or controlled by a designated person or entity are subject to the same financial sanctions as the designated entity.

Detailed guidance on ownership and control is in Section 7 of the Russia Sanctions Regulations and also provided by the Office of Financial Sanctions Implementation (OFSI).

For example, sanctioned companies like Rostec and the Tactical Missile Corporation each have numerous subsidiaries.

The UK Government has made estimates of the number of subsidiary companies covered by UK sanctions in order to provide a fuller picture of the extent of sanctioned companies. We make the estimates of subsidiaries using open source research on each unique entity, including the entity’s own website.

The estimate number is added to the number of direct designations on individuals and entities listed on the UK Sanctions List. For example, the 4 May press release titled ‘Russia cut off from UK services’ quoted 1,600 individuals and entities. This number comprised 1,083 individuals; 106 entities (included on the UK Sanctions List at the time) plus an estimate of over 420 subsidiaries of those entities.

9. Banks and their assets

For sanctioned banks and the estimated value of their global assets, the UK Government used Finmarket - Interfax Rankings for 2021, and converted figures from roubles into sterling using the 2021 average IMF exchange rate of £1 = 101.4 roubles. These are pre-invasion estimates. We have included Novicombank, which is a subsidiary of Rostec, sanctioned on the 24 February 2022. Note that asset values can go up, as well as down.

Note also that the amount of assets frozen by the UK sanction will be only those assets held in the UK financial system and is a smaller amount.

10. More information

For questions about the UK Government’s sanctions data, contact the FCDO Communication Team by email in the first instance, on newsdesk@fcdo.gov.uk.