UK Issues Sanctions Guidance About Transfers From Russian Securities Depository
The U.K. offered guidance this week about how companies should address a recently announced Russian decree that requires securities held at the country's National Settlement Depository to be transferred to local Russian registrars. The move is an attempt by Russia to evade Western sanctions on its National Settlement Depository, the U.K. said in new FAQ 124, warning British companies that the local Russian registrars may also be captured by sanctions.
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“Relevant institutions should continue to consider ownership and control and the risks associated with dealing with these assets,” the U.K.’s Office of Financial Sanctions Implementation said. “Where local registrars are owned or controlled by other designated persons, relevant institutions must treat the assets as frozen.”
The agency said companies should “consult” the U.K.’s sanctions list and “conduct your own due diligence” on transactions or activities involving Russia-related securities. “In the interest of reducing uncertainty, the government is exploring options to further clarify this position,” it said.
The U.S. Office of Foreign Assets Control issued similar guidance in October, saying transfers of securities from Russia’s National Settlement Depository to local registrars doesn’t lift OFAC restrictions on those securities (see 2410110003).