UK Finance chief executive David Postings began with an account of the eve of Russia’s invasion, when he attended a crisis roundtable with the prime minister. He shared his insights on how far we have come since, and the role UK Finance and the financial services sector has played in the collective fight against Russia.

This was followed by a keynote from Baroness Penn, the Treasury Lords minister highlighting the rapid expansion of Sanctions investment and recruitment in the UK and abroad, as well as the tireless collaborative efforts of the UK government and the private sector in ensuring the maximum impact of sanctions on the Russian regime.

There was a sense of renewed collective appetite for innovative scope. Moving forward, future Sanctions programmes will continue to see fresh initiatives being put in place, such as the oil price cap introduced in December 2022. The consensus one year on since Russia is positive, but the work to be done cannot be underestimated. There is a continued need for international cooperation to clamp down on circumvention and evasion, and the network of attendees at the conference from a range of governance, law, financial and trade backgrounds from the UK and across the Atlantic was an embodiment of this.

Sanctions evasion, circumvention and enforcement priorities

The opening panel, led by Neil Whiley, our Director of Sanctions, spoke on the progression of sanctions in the past year. A testament to their success was a 90 per cent reduction in semiconductor exports to Russia, an essential battlefield export that had fallen by two-thirds in the last 12 months. Legislation has been solidified, and it is acknowledged that the next steps should be a direct effort to tighten structures and target those determined to circumvent and evade sanctions. The panel observed the importance of diplomatic dialogue in reassuring third party countries that may be tempted to engage with Russia.

Navigating the evolving complexity of Russia sanctions

The second panel reiterated the importance of cross-agency, cross-industry and cross-border information sharing in tackling the everchanging obstacles of a successful Sanctions regime. Led by Rakesh Patel, head of Sanctions Policy Oversight and Export Controls at HSBC, the second panel delved deeper into the complexity of existing and future sanctions. It was useful for attendees to listen and engage with discussions on difficult aspects of arguably subjective legislation such as ownership and control. International colleagues were also afforded the opportunity to share strategies with their UK counterparts, once again reiterating the importance of unity across regions.

The intersection of Sanctions and export controls

The conference gave insight not only into financial sanctions but also to the development of trade sanctions and its growing overlap with export controls at the closing panel led by Simon Armstrong, Director Sanctions Escalation & Alerts Advisory, Barclays. The discussion covered recent updates to sanctions lists, providing professional insight into the chain of command. Thus, providing attendees encouraging feedback on similar issues, paving the way for coordinated contingency planning in the future.

Positive feedback

Attendees praised the “succinct presentation delivery style” that allowed for such a breadth of information to be shared in a relatively compact morning. Not only were the panels highly technical, “knowledgeable and informative” but were “well organised and well structured” for key networking opportunities between each discussion. The chance to listen to government representatives in the panels, “but also to speak with them directly during the networking sessions was a somewhat rare and invaluable opportunity”. Once again, the consensus from colleagues in attendance was overwhelmingly complimentary, and the outstanding “involvement of Baroness Penn, OFSI and other industry experts” was much appreciated.

Conference chair Roger Matthews from Dentons closed by summarising the key takeaways. He said that the reality was that sanctions will be expanding for years to come, and with this comes further challenges to face. However, as has been evident from the Russian invasion, increased obstacles come with a desire to collaborate and innovate. UK Finance will continue to stand at the forefront of such change and facilitate greater joint efforts to produce coherent sanctions policies, in parallel to various other methods aiding Ukraine.

To find out more about sanctions, view our website and listen to our Sanctions School Podcast series.

SAVE THE DATE:

UK Finance Sanctions Conference,

9am-12pm, Wednesday 6 December 2023,

Deloitte London.