The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022 (SI 2022/123) entered into force on 10 February 2022 and herald a much more rigorous regime for the imposition of sanctions against specified Russian targets.

The Regulations are made under the Sanctions and Anti-Money Laundering Act 2018 and amend the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855). The current regulations amend the designation criteria in regulation 6 of the 2019 Regulations to specify additional activities for which a person can now be designated. These activities include being involved in destabilising Ukraine or threatening the territorial integrity, sovereignty or independence of Ukraine or obtaining a benefit from or supporting the Government of Russia. The term "involved in destabilising Ukraine or undermining or threatening the territorial integrity or independence of Ukraine" (the prohibited effect) is given a very broad meaning to include promoting any policy or action which has that effect, as well as covering any person who provides financial services or makes economic or other funds, goods or technology available to another that could have that effect. Additionally, the term also covers any person who provides financial services or makes economic or other funds, goods or technology to a person who is responsible for a policy or action which has the prohibited effect. Obstructing the work of international organisation in Ukraine as well as being a company that trades or operates in Crimea is also caught under the new designation criteria in regulation 6.

The term Government of Russia is also given a very wide definition to include any Ministry of the Russian Federation and the Central Bank of the Russian Federation.

The Regulations are intentionally very wide in scope and designed to cause serious economic disruption to the Russian state as well as all those that do economic business with the Russian state. They require careful consideration by any entity which has such a trading relationship as well as an investigation of the ultimate destination for resources which might be supplied to the Government of Russia by a friendly third party entity.