It announced 18 designations this week, all with immediate effect, imposed on A7-linked individuals and three Georgian companies operating Russia-focused exchanges. The Home Office said the A7 network claimed to have moved more than $90bn last year, about half of Russia’s annual military expenditure.
John Binns, partner at BCL Solicitors, said there was ‘an inevitable arms race in methods to evade and circumvent sanctions’ but sanctions designations were not always well-targeted and could backfire.
Richard Cannon, partner at Stokoe Partnership Solicitors, said: ‘Designations carry severe commercial and reputational consequences and must rest on clear, cogent and verifiable evidence, applied with precision and proportionality.
‘Those who find themselves named or otherwise affected should promptly seek specialist legal advice, preserve relevant records, and engage constructively with Office of Financial Sanctions Implementation and the appropriate authorities to clarify their position and, where justified, seek variation or delisting.’
