Are the UK’s Russian financial sanctions working?

12 months following the publication of its report ‘Defeating Putin: the development, implementation and impact of economic sanctions on Russia’, the UK’s Treasury Committee is seeking evidence on the UK’s approach to sanctions against Russia.

The deadline for submissions is 28 March 2024, and contributors are encouraged to submit evidence on a number of issues, including overall effectiveness, strategies to mitigate unintended consequences and the effectiveness of OFSI as a regulator, including guidance issued, the licensing regime and international cooperation.

There will be many that will have a great deal to say on all areas covered. For sanctions practitioners, the question that is perhaps the most thought provoking is “whether assets frozen as part of the UK’s financial sanctions on Russia should be confiscated, and whether there are legal precedents for such a move?“. This point has been the subject of much debate, and with the concept of ‘confiscation’ carrying a particular (statutory) meaning in the minds of those of us advising on financial crime matters, the evidence submitted and any resulting reports are certain to make for interesting reading. Watch this space.

You can access the call for evidence here.