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UK Updates Designation Criteria Under Russian Sanctions Regime

The U.K. adopted an amendment to its Russian sanctions regime that alters the designation criteria for listing an individual or entity. The new criteria expand the definition of "involved in obtaining a benefit from or supporting the Government of Russia," to include working as a "manager" of or "holding the right, directly or indirectly," to nominate a director, trustee or equivalent of a Russian government-affiliated entity; an entity conducting business as a government affiliate; or an entity conducting business of economic significance to the Russian state.

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The amendment further allows the U.K. to designate individuals occupying various Russian government roles if they're involved in "destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine" or "obtaining a benefit from or supporting the Government of Russia." Britain also expanded the definition of being "associated with" to apply to immediate family members of a listed individual.

The changes add a new humanitarian exception to the ban on the outward trade in goods and infrastructure-related services for humanitarian assistance activity in the non-Russian controlled areas of Donetsk and Luhansk. The amendment clarified that aircraft or ships owned by a majority interest in a company are in scope under the sectoral shipping and aircraft restrictions. Other errors and omissions were corrected.