Media & Resources
In the framework of another set of sanctions the UK prohibited to provide trust services to persons “connected with Russia”
DATE: December 28, 2022 | AUTHOR: AT
On December 16, 2022, a new set of UK sanctions against Russia came into force (The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022).
This set imposes a prohibition on providing the following trust services:
- the creating trusts or similar arrangement;
- the providing a registered office address, business address, correspondence address or administrative address for a trust or similar arrangement;
- the operation or management of a trust or similar arrangement;
- acting or arranging for another person to act as trustee of a trust or similar arrangement.
The prohibition is applied to providing services to persons “connected with Russia”
- an individual who is ordinarily resident in Russia;
- an individual who is located in Russia;
- a legal entity which is incorporated or constituted under the law of Russia;
- a legal entity which is domiciled in Russia.
The services must not be provided even if the person "connected with Russia" is a beneficiary of the trust or similar arrangement, is referred to as a potential beneficiary in the constituent documents of the trust or similar arrangement, or there are reasons to believe that the person will receive a significant financial benefit from the trust or similar arrangement.
The prohibition is not applied when arrangement for providing trust services arose before December 16, 2022.
Please note that the list of the jurisdictions applying UK sanctions against the Russian Federation includes all UK overseas territories (including the British Virgin Islands and the Cayman Islands), as well as the UK Crown Dependencies – Man, Guernsey and Jersey Isles.
These changes, as well as similar EU sanctions, encourage Russian beneficiaries to reconsider their ownership structure and develop new approaches to asset management.