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New FAQs added – Transneft ports, payments and insurance
OFSI has published new FAQs (188-195) clarifying how UK financial sanctions apply in relation to Transneft and associated activity. These FAQs provide additional guidance to industry on how relevant prohibitions operate in practice, including when a licence may be required and how firms should approach compliance risks.
The FAQs respond to stakeholder queries and aims to support a consistent understanding of the regime, helping to reduce the risk of circumvention. We encourage insurers, financial institutions and maritime operators to review the guidance and ensure internal processes reflect these considerations.
Here they are:
PJSC Transneft
188. Does insuring a vessel calling at a PJSC Transneft owned or controlled port automatically engage UK sanctions?
No.
UK insurers providing insurance or reinsurance cover for vessels simply calling at PJSC Transneft-owned or controlled ports, in itself, is unlikely to engage UK financial sanctions.
The fact that a UK insured vessel calls at a PJSC Transneft owned or controlled port does not, in itself, automatically engage UK financial sanctions. Although UK financial sanctions do not determine whether a vessel may call at a particular port, UK financial sanctions, however, may still apply to any financial activities connected with such voyages.
Questions relating to port access, shipping routes, or trade restrictions fall outside the scope of UK financial sanctions and are governed by other regulatory frameworks.
For guidance on assessing insurance claims, see FAQs 189-190.
Added on: 11 Jun 2026
189. What are some of the key considerations when assessing insurance claims and payouts relating to PJSC Transneft owned or controlled ports?
Depending on the specific facts of the case, the key considerations are whether a payment under an insurance policy would engage the asset freeze prohibitions, for example regulations 12 and 13 of the Russia Regulations- making funds available to, or for the benefit of, designated persons, including PJSC Transneft.
If so, a licence from OFSI would be required before any such payment can be made.
Added on: 11 Jun 2026
190. Can UK insurers pay claims that do not involve PJSC Transneft or PJSC Transneft owned or controlled ports?
Whether or not such claims can be paid without an OFSI licence will depend on the circumstances and facts of the case.
For example, although a payment may not result in a direct payment to a PJSC Transneft owned or controlled port/entity, firms must assess whether other UK asset freeze prohibitions are engaged, for example regulation 13 of the Russia Regulations- making funds available for the benefit of a designated entity, including PJSC Transneft.
Firms must make their own assessment on whether any indirect benefit arises to a designated person or whether any of the other asset freeze prohibitions are engaged.
Added on: 11 Jun 2026
191. Does compliance with EU or other sanctions regimes ensure compliance with UK sanctions?
No.
Compliance with EU or other sanctions regimes as it relates to PJSC Transneft should not be taken as evidence of compliance with UK financial sanctions. The UK maintains an independent sanctions framework, and firms must ensure full adherence to UK specific requirements.
Added on: 11 Jun 2026
192. Do payments made in connection with calling at a PJSC Transneft-owned or controlled port engage UK financial sanctions?
Potentially.
Primarily, there will have to be a UK nexus in relation to the payment(s). Once this has been established, payments such as port fees and terminal charges, amongst others, may engage UK financial sanctions if for example funds are made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations).
In such cases, the asset freeze prohibitions are likely to apply, and a licence from OFSI may be required. It is for firms (including UK shipowners, charterers or ship managers for example) to assess whether UK financial sanctions are engaged in relation to such payments.
Added on: 11 Jun 2026
193. Can UK financial institutions support transactions linked to voyages involving PJSC Transneft infrastructure?
UK financial institutions (such as banks or other financial firms) must assess transactions on a case-by-case basis.
Where a transaction would result in funds or economic resources being made available to, or for the benefit of PJSC Transneft, the asset freeze prohibitions are likely to apply (Regulations 12 and 13 of the Russia Regulations).
Financial institutions should ensure they conduct appropriate due diligence and consider whether an OFSI licence is required before processing any such transaction.
Added on: 11 Jun 2026
194. Does the involvement of PJSC Transneft infrastructure (e.g. oil pipelines or storage facilities) automatically engage UK financial sanctions (where a UK nexus exists)?
No.
The mere involvement of PJSC Transneft infrastructure in a supply chain does not, by itself, automatically engage UK financial sanctions. However, firms must conduct their own assessment and apply for an OFSI licence should one be required, for example, where involvement of PJSC Transneft infrastructure will result in funds being made available to PJSC Transneft (Regulation 12 of the Russia Regulations).
Added on: 11 Jun 2026
195. Do UK financial sanctions apply to goods (e.g. oil) transported via Transneft infrastructure (e.g. pipelines)?
Not automatically.
UK financial sanctions are unlikely to be engaged solely because goods have been transported via infrastructure owned or controlled by a designated person (such as PJSC Transneft).
However, the asset freeze prohibitions for example may be engaged where activities involving those goods (including payments for transport, storage or port services) result in funds being made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations). Firms must conduct their own assessment on whether UK financial sanctions are engaged and apply for an OFSI licence should one be required.
Added on: 11 Jun 2026
Mr. Sanctions’ editorial note: It would be really, really nice if OFSI’s links went directly to the thing they reference. In this case, the link takes you to the start of the Russia FAQ section, even though there is a special heading for these Transneft FAQs. And when there is a sanctions update, that link takes you to a page where you then have to click again to get to the actual PDF. Yeah, it’s a comparatively small thing, but a blogger can dream, can’t he?
Today, Tuesday 09 June, the UK Government has varied the following 3 individuals and 2 entities under the Russia (Sanctions) (EU Exit) Regulations 2019.
Foreign Secretary to set out tougher UK action in response to record settlement expansion and rising settler violence in West Bank, and push for urgent implementation of the 20 Point Peace Plan
UK brings together Australia, Canada, France, New Zealand and Norway to deliver co-ordinated sanctions against networks financing and enabling settler attacks against Palestinians in the West Bank, and firmly advises British businesses against activity in illegal Israeli settlements
UK takes further action to support recovery in Gaza, including providing £1 million for humanitarian demining, and at least £10 million supporting the PA to navigate the fiscal crisis and sustain critical services
In a statement to Parliament today, the Foreign Secretary will announce that the UK, alongside partners (Canada, France and Norway) is imposing new sanctions. The UK will impose sanctions on 6 entities and one individual involved in financing, enabling and carrying out settler violence in the occupied West Bank. Australia and New Zealand published co-ordinated sanctions last week.
Australia, Canada, France, Norway, and the United Kingdom have all taken the historic decision to recognise the State of Palestine, reflecting the rights of the Palestinian people and as part of our common efforts to protect the viability of the two-state solution. Today, they are acting together again in support of the same objectives.
Those designated will face asset freezes and, where appropriate, travel bans and Director Disqualifications. These sanctions will disrupt the flows of finance that have allowed extremist settler groups to act with impunity in the West Bank and demonstrate the UK’s commitment to a two-state solution.
The UK position remains clear: settlements are illegal under international law, they undermine international efforts to secure a just, lasting peace in the Middle East, and they risk doing permanent damage to the prospects of a secure and viable Palestinian state being able to live in peace alongside a secure Israel.
For the first time, the Foreign Secretary has also announced that the UK’s official guidance will explicitly advise businesses against economic and financial activity in illegal settlements. The UK continues to support trade with Israel within 1967 lines, but states that there should be no economic involvement in illegal settlements.
Foreign Secretary Yvette Cooper is expected to say:
Today we are acting with our international partners to sanction those who support and sponsor violence against Palestinian communities in the West Bank.
Settler expansion and violence is illegal and a fundamental threat to the viability of a two-state solution, and to long-term peace and security for Palestinians and Israelis.
These measures show the UK is leading with our partners to target those who are fuelling this violence.
These steps come against a backdrop of continued illegal settlement expansion including the E1 project, which further undermines the viability of a two-state solution, and record levels of settler violence designed deliberately to destroy Palestinian homes and livelihoods in the West Bank.
The UK continues to urge the Government of Israel to end settlement expansion, clamp down on settler violence, prosecute those responsible, and lift ongoing restrictions on the functioning of the Palestinian economy. The UK will not hesitate to take further action if the situation does not improve.
Today’s measures form part of a wider UK effort to advance peace and security in Israel and Palestine. This includes action to support implementation of the 20 Point Plan for Gaza and protect and strengthen a viable Palestinian state.
The Foreign Secretary is also expected to announce today that the UK will provide an additional £1 million for humanitarian mine action in Gaza in addition to the £4 million already contributed. She will call on the Government of Israel to open all crossings and remove arbitrary restrictions on the delivery of humanitarian aid and equipment to ensure that UK aid can reach all those who desperately need it.
She will also announce that she will travel to Paris this week in advance of the Peace Building Conference, which is bringing together Israeli and Palestinian civil society, and international partners dedicated to advancing the two-state solution.
In addition, the Foreign Secretary will confirm at least £10 million in financial and technical assistance to the Palestinian Authority in 2026, including support to navigate the fiscal crisis and sustain frontline services such as healthcare.
Background
Sanctioned individuals and entities include:
The Farms Association: provides financial and organisational support to Israeli settler farms and outposts in the West Bank, including those associated with violence, intimidation and forced displacement of Palestinians
Ahavat Gilad: serves as a financial conduit for the Farms Association, channelling donations to settler outposts including those associated with violence against Palestinians
Ari Yshag: fundraises for illegal settler outposts associated with violence, intimidation and forced displacement of Palestinians
Artzenu: promotes, finances and resources settler farms and outposts associated with violence against Palestinians, including fundraising for tactical military equipment for armed settler squads
Shivat Zion Lerigvey Admata: the registered legal vehicle through which Artzenu’s financial activities are conducted, channelling donations to outposts linked to serious human rights abuses
Eyal Hari Yehuda: construction and demolition company that facilitates, supports and is responsible for owners, staff, associates and family members who have used company resources while hired on construction and demolition jobs in the West Bank to destroy Palestinian land and property, as well as physically attack, shoot and kill Palestinians, which has led to the wider displacement of Palestinians
Itamar Yehuda Levi: owner of EYAL HARI YEHUDA COMPANY LTD (also designated today) that facilitates, supports and is responsible for owners, staff, associates and family members who have used company resources while hired on construction and demolition jobs in the West Bank to destroy Palestinian land and property, as well as physically attack, shoot and kill Palestinians, which has led to the wider displacement of Palestinians.
Explainer of business guidance
The overseas business risk service provides information on various risks in overseas markets. We intend these pages to support and guide businesses. You should view them alongside other sources of information. The UK government does not advise on, or undertake due diligence for individual companies.
Today, OFSI has published FAQ 187 on how mandatory corporate actions (MCAs) engage the Russia and Belarus Regulations, providing clarity for those trading transferable securities and money market instruments.
The FAQ explains that new instruments, created through an MCA will not automatically engage Regulation 16 of the Russia Regulations or Regulation 15A of the Belarus Regulations. Whether these provisions apply will depend on the specific facts, and the FAQ includes a worked example illustrating how this assessment may be made.
This guidance supports firms to continue trading whilst remaining compliant with UK sanctions.
Frequently Asked Question 187:
187. For the purposes of regulation 16 of the Russia Regulations and regulation 15A of the Belarus Regulations, how should the “date of issue” of a transferable security or money market instrument be determined, including where instruments or securities issued pursuant to a mandatory corporate action (MCA) relate to securities or instruments issued prior to the dates referred to in regulations 16 and 15A?
These regulations prohibit dealing with transferrable securities and money market instruments issued by certain persons on or after certain specified dates. Dealing with transferrable securities and money market instruments that were issued before the specified dates is not prohibited, provided the activity does not otherwise breach the Russia Regulations or the Belarus Regulations (e.g. by making funds available to a designated person).
In some cases, a new transferable security or money market instrument is created in respect of an instrument or security issued prior to the specified dates referred to above (including in the context of an MCA) which could then potentially be caught by the relevant regulations. Determining whether this is the case is fact-dependent and will be considered by OFSI on a case-by-case basis (but determinations will only be made if relevant to specific OFSI casework). In that consideration, OFSI will place significant weight on whether an issuance (including as part of an MCA) results in finance being raised for the issuer.
For example, regulation 16 or regulation 15A may not apply if:
Shares subject to regulation 16 (or regulation 15A) originally issued prior to the relevant date in regulation 16 (or regulation 15A) become subject to a mandatory stock split after that date;
that stock split does not raise new finance for the company undertaking it; and;
there is no material change to the rights and/or value of the shares.
1 FAQ added: Russia (Sanctions) FAQ on Huobi Global S.A.
OFSI has published a new Frequently Asked Question (FAQ) on the application of UK financial sanctions to the HTX cryptocurrency exchange.
The FAQ explains that, following the UK’s designation of Huobi Global S.A. on 26 May 2026, OFSI considers that the HTX cryptocurrency exchange is subject to UK financial sanctions.
186. Does the designation of Huobi Global S.A. apply to the HTX cryptocurrency exchange?
Yes. On 26 May 2026, the UK designated HUOBI GLOBAL S.A. (“Huobi”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”). Huobi is consequently subject to financial sanctions, as are entities owned or controlled by Huobi.
OFSI considers that the HTX cryptocurrency exchange is subject to the UK’s financial sanctions due to its ownership by Huobi, meeting the condition in regulation 7(2)(a) of the Russia Regulations.
