David Postings speech at the Sanctions Conference

David Postings, Chief Executive of UK Finance - speech


Good morning, everyone. I’m David Postings, Chief Executive of UK Finance.

Welcome to the UK Finance Sanctions Conference. Thank you to our sponsors: Dentons, Moody’s Analytics, White & Case, and our speakers for sharing their insights. This conference would not have been possible without your support. 

In February last year I attended a roundtable of sanctions experts called by the Prime Minister in number 10 downing street.

The meeting had been called to discuss potential restrictions against Russia and implications for the banking industry. It was quite a tense meeting and the following day at dawn, Russia invaded Ukraine.

Following this, a flurry of legislative changes were triggered. We were using sanctions to target the Russian government and anyone assisting them.

Since then, sanctions have been introduced on a rolling basis where nothing has been off the table. To date, over 1,600 individuals and 200 entities are subject to UK sanctions under the Russia regime. The UK has targeted over 130 oligarchs with a net worth of over £140 billion and frozen more than £18 billion worth of assets. 

I am extremely proud of the role UK Finance and the sector has played in this effort. But it has not been easy. The sheer volume and scale of sanctions applied are greater than any previous regime. Russia is now the most sanctioned country in the world.

Some of the measures introduced are brand new concepts to some jurisdictions. And given that the work is being undertaken at pace, this has been very challenging.

UK Finance and our members have worked tirelessly with government and stakeholders both here and overseas to significantly reduce business and trade with Russia.

UK Finance has built successful relationships with international allies and has regular dialogue with the G7 nations to ensure we are aligned on sanctions policy. Domestically, UK Finance meets monthly with the Treasury and FCA’s Senior Implementation Group, to discuss matters of importance and exchange feedback.

We also host monthly panels with senior government representatives, alongside our members, to ensure everyone is able to keep pace with the speed of sanctions changes.

To put the scale of change into context, UK Finance tracked almost three times the number of listings updates over 2022 compared to 2021. To action this surge, the Foreign Office, Treasury and industry have had to almost quadruple its staff.

At the time, sanctions experts were difficult to get a hold of in the volume needed. We have come a long way since then, as can be seen through UK Finance’s Women in Sanctions group. It’s a thriving group of now over 400 women across a range of industry sectors.

Meanwhile, we continue to help a much wider audience with our Sanctions School podcast – something for those who have seen the headlines and want to understand how sanctions work. This has been a huge success.

In the UK particularly, we have used our position as a centre for international finance to place pressure on global commerce and investment.

In addition to implementing the sanctions themselves, we have also worked through unintended consequences. For example, issues for UK businesses with Russian offices.  This has not been a straightforward task.

The Russia Oil Price Cap in February and December are a prime example of finance-based sanctions encroaching into the trade space

Indeed, the Oil Price Cap coordination efforts have taken place at UK Finance’s offices. Wally Adeyemo, US Deputy Secretary of the Treasury and Elizabeth Rosenberg, Assistant Secretary for Terrorist Financing and Financial Crimes at the US Department of Treasury, came to speak to our members and industry stakeholders to align on the price cap. 

The G7 nations later imposed the cap, on 5th December last year with UK Finance continuing the dialogue with HM Treasury at our Oil Price Cap working group.

The previously held distinction between sanctions, exports controls and other restrictions have become blurred. The sanctions arena remains complex and at times, contradictory. While relatively straightforward sanctions listings have gone ahead, more complex cases will dominate in the year to come. Critical questions will remain over ownership and control of designated Russian individuals and entities.

As the fighting in Ukraine continues, our sanctions regime will continue its expansion. We need to be ahead of the upcoming challenges and know how to tackle them. This morning’s discussions will go to the very heart of this.

A top priority for the year and area of focus is anti-circumvention and evasion, as the UK adopts a greater focus on extraterritorial sanctions. 

However, we need better alignment between governments worldwide so that any changes are announced in sync, reducing asset flight windows.

The second priority, aligned with the UK government, is the intersection of sanctions with export controls. In addition to sanctions on Russian individuals and entities, the UK has placed export bans on every item that Russia has been found using on the battlefield to date.

While this move is of course positive, we must also assess the impact on global supply chains and due diligence requirements. It is also vital that we respond to suspected sanctions and export controls violations.

There is huge appetite for collaboration between regulators, government and the private sector in addressing these challenges. I know that UK Finance will be at the forefront of these efforts.

We have a full agenda and a stellar line up of speakers to give their thoughts today, including Baroness Penn, the Treasury Lords Minister.

I hope you all enjoy the conference. There is a wealth of expertise in this room so take this opportunity to meet new people and have productive and informative conversations.

The work achieved in the sanctions arena so far has been extraordinary, and I know that we will work together to continue this momentum.

Thank you.

Area of expertise: