UK Sanctions Weekly Update – Week of September 4, 2023

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.

1.  Russia Sanctions

• UK sanctions 11 members of the Russia-based Trickbot Cybercrime gang 11 Russian individuals added to the UK Cyber Financial Sanctions list: On September 7, OFSI added 11 individuals to the UK sanctions list in a coordinated effort with the United States. The individuals are connected to the Russian cyber criminal gang behind the Trickbot/Conti ransomware attacks that targeted hospitals and other critical infrastructure during the Covid-19 Pandemic. Those sanctioned have been targeted with asset freezes and travel bans by UK authorities to counter the threat of ransomware both in the UK and abroad. The National Crime Agency (NCA), who conducted a complex investigation into these individuals, assesses that the group was responsible for extorting at least $180 million from victims globally, and at least £27 million from 149 UK victims. (Notice_Cyber_070923.pdf (publishing.service.gov.uk)) (UK sanctions members of Russian cybercrime gang - GOV.UK (www.gov.uk))
• FCA publishes review of the sanctions systems of financial services firms: On September 7, the UK Financial Conduct Authority published a review of the sanctions systems and controls in place in over 90 financial services firms. The review found that (i) there were good practices, such as firms who conducted risk exposure assessments in advance of the Russian invasion of Ukraine, and firms who conducted sample testing and tuning, (ii) governance and oversight needed to be improved in many firms, there was an over-reliance on third party sanctions screening tools, and in some global firms, global policies were not aligned with the UK sanctions regime, (iii) many firms had significant backlogs in the assessment of alerts from sanctions screening, some firms had inadequate internal expertise, and some firms had inadequate screening capabilities, and (iv) there were low quality Customer Due Diligence and Know your Customer assessments and inconsistencies in reporting breaches to the FCA. (https://www.fca.org.uk/publications/good-and-poor-practice/sanctions-systems-and-controls-firms-response-increased-sanctions-due-russias-invasion-ukraine#:~:text=The%20FCA%20is%20responsible%20for,intensified%20our%20focus%20on%20sanctions)
• UK Says It Will Declare Russia's Wagner Group A Banned Terrorist Organisation: On September 6, Great Britain announced that it will declare Russia's Wagner mercenary group a banned terrorist organization, saying it remains a threat to global security even after the death of leader Yevgeny Prigozhin. The government said an order will be introduced in Parliament to proscribe the group under the Terrorism Act. The designation, once approved by lawmakers, will bar membership in or support for Wagner, which has played a major fighting role in Russia's invasion of Ukraine. It has also operated in Syria and several African countries. The ban will allow UK authorities to seize the organization’s assets, though that power is largely symbolic as Wagner is not known to operate in Britain. The move follows a recommendation by Parliament’s influential Foreign Affairs Committee in July that Wagner be outlawed. The committee said British authorities had “underplayed and underestimated” the threat posed by the mercenary group. (The UK says it will declare Russia’s Wagner mercenary group a banned terrorist organization | AP News)