Defeating Putin: the development, implementation and impact of economic sanctions on Russia/Implementing sanctions

by House of Commons Treasury Committee

Layout 2

2Implementing sanctions

9. The nature of the economic sanctions being implemented against Russia is quite unprecedented. Tom Keatinge, Director at the Centre for Financial Crime and Security Studies (CFCS), Royal United Services Institute (RUSI), told us that “[ … ] we’re in uncharted territory: using sanctions against a country that is so integrated with the west is unprecedented”.^[1] Dr Justine Walker, Head of Global Sanctions and Risk at the Association of Certified Anti-Money Laundering Specialists, said that “I would also really emphasise the point that we have never used sanctions in this way against another G20 country”.^[2]

Areas of sanctions

10. The inquiry has considered the effectiveness of economic sanctions in six key areas:
    • Energy
    • Central banking
    • International financial messaging (SWIFT)
    • Other financial services sanctions
    • Self-sanctioning
    • Kleptocrats and oligarchs

Energy

11. On 8 March 2022 the UK Government announced that it would phase out Russian oil imports, but not gas imports:

    The UK will phase out imports of Russian oil in response to Vladimir Putin’s illegal invasion of Ukraine by the end of the year. The phasing out of imports will not be immediate, but instead allows the UK more than enough time to adjust supply chains, supporting industry and consumers. The government will work with companies through a new Taskforce on Oil to support them to make use of this period in finding alternative supplies. [ ... ] The UK is not dependent on Russian natural gas, making up less than 4 per cent of our supply. Ministers are also exploring options to reduce this further.^[3]

    According to a UK Government press release, Russian oil makes up 44 per cent of Russian exports and 17 per cent of Russian federal government revenue through taxation.^[4]

12. Speaking before the Government’s announcement on 8 March, Neil Shearing, Group Chief Economist at Capital Economics, told us:

    [ ... ] From an economic standpoint, if the objective is to hit Russia’s economy, it is the energy sector that you need to touch. Clearly, there is a cost for the rest of the world that that entails. When news broke overnight of oil sanctions potentially being imposed, the price of oil spiked to just over $140 a barrel, so there would be a cost to the rest of the world were we to go down that route. [ ... ] but, as a rough rule of thumb, energy is about half of Russia’s exports and about 15% of its economy—more if you include all the associated services.^[5]

    We consider later in this report the impact of energy sanctions, both upon Russia (in this chapter) and upon the UK (in paragraphs 57 to 64 in Chapter 3).

Central banking

13. On 28 February 2022, the UK Government, alongside similar moves by the United States, the European Union and Canada, announced restrictions on the ability of UK nationals and companies to undertake financial transactions involving the Central Bank of the Russian Federation (CBR), the National Wealth Fund, and the Ministry of Finance of the Russian Federation.^[6] According to one estimate, the UK holds 4.5% of the CBR’s reserves.^[7]
14. Mr Shearing described the scale and effect of these sanctions:

    [ ... ] we have seen Russia’s foreign exchange reserves and the foreign assets held at the central bank increased to just over $600 billion. They are parked in different currencies—dollars, euros, yen, sterling and so on. As a result of these sanctions, we have frozen just over half of those reserves, so those can’t be used.

    The central bank cannot process any foreign exchange transactions, defend the rouble when the rouble collapses, sell its foreign exchange reserves and buy the rouble to prevent it falling further, or help domestic companies access foreign currency for transactions. So it has completely frozen the financial system in Russia, with respect to external transactions. As part of the modern global economy—what was the 11th-largest economy in the global economy—that has a huge effect.^[8]

International financial messaging (SWIFT)

15. SWIFT, an acronym for The Society for Worldwide Interbank Financial Telecommunication, is a messaging system which allows banks around the globe to communicate quickly and securely about cross-border payments. It is a member-owned co-operative based in Belgium, made up of global banks.^[9] On 2 March SWIFT announced that it would cut off seven Russian and three Belarusian banks from its system with effect from 12 March 2022:

    Diplomatic decisions taken by the European Union, in consultation with the United Kingdom, Canada and the United States, bring SWIFT into efforts to end this crisis by requiring us to disconnect selected banks from our financial messaging services. As previously stated, [SWIFT] will fully comply with applicable sanctions laws.^[10]

16. Pressure from the UK was influential in building international consensus to support this action. On 25 February 2022, the Prime Minister, on a phone call with other NATO leaders, urged leaders to take immediate action regarding SWIFT to inflict “maximum pain” on President Putin and his regime.^[11] On the same day the Defence Secretary, Rt Hon. Ben Wallace MP, said:

    We would like to go further. We’d like to do the Swift system–that is the financial system that allows the Russians to move money around the world to receive payments for its gas–but [ ... ] these are international organisations and if not every country wants them to be thrown out of the Swift system, it becomes difficult.^[12]

17. Natasha de Terán, a payments policy expert who gave evidence to us, described four elements necessary for international transfers to take place: the communications layer, an underlying economic incentive, willing counterparties, and an exchangeable currency or mutually acceptable assets. She described how removing the communications layer from Russian entities could complicate but not necessarily stop all international payments:

    The communications layer [such as SWIFT] is just one of those factors, but so long as there is the economic incentive and there are counterparts, you will sort out the other two things. That said, there is a question of scale. If I am a bank and I need to do a billion dollar oil transaction, I can make that possible by setting up a leased line and by sending a fax. It is problematic. It is risky, because clearly if I tell another bank to act on the receipt of a fax I am opening myself up to fraud and other risks. It is cumbersome. You cannot do an awful lot of low-value transactions that way, so it messes things up, but it only messes things up and complicates things in a terminal sort of way—if that is the aim—if that bank is subject to really multilateral sanctions. That takes us into the application of US secondary sanctions, which are probably the most exhaustive sanctions that there could be. We have not seen those exercised yet.^[13]

Other financial services sanctions

18. Alongside the sanctions imposed by the UK’s international partners on SWIFT, there have also been sanctions imposed by different jurisdictions on individual Russian financial institutions. A complex and sometimes unclear regime has resulted.^[14] Not all Russian banks were subject to sanctions from the outset. Tom Keatinge, Director at the Centre for Financial Crime and Security Studies (CFCS), Royal United Services Institute (RUSI), told us that certain banks were still “untouched” because of the requirement for energy payments to continue to flow.”^[15]

Self-sanctioning

19. Since the start of the invasion, UK-based companies have announced an intention to divest from Russian investments^[16], close their Russian operations^[17] or cease to trade with Russian firms.^[18] Tony Danker, Director-General at the Confederation of British Industry (CBI), describing the scale of this exodus, told us that “Everybody has been digesting this incredibly quickly, but on the whole, I think people universally have been saying that it is time to find ways to get out of Russia”.^[19]
20. Mr Keatinge noted this short-term response of firms to sanctions but suggested that this could change for some firms as uncertainty reduces:

    I think that we all agree that there is quite a lot of self-sanctioning [ ... ] People are deciding not to trade with Russia, not because they are not allowed to, but because they are just not quite sure what on Earth to do right now. There will come a point where that stasis in the system will begin to melt, and we must ensure that people understand what is and is not allowed, very clearly, at that point.^[20]

21. However, Mr Danker, when asked whether this self-sanctioning was a longer-term process of divestment and distancing of business in Russia, told us:

    [ ... ] I do not think companies are trying to make long-term calculations about when this war might end or otherwise. I think they have made that calculation; they have made that judgment; and now they are seeking to exit the market.^[21]

Measures against Russian kleptocrats and oligarchs

22. The UK Government has implemented sanctions against individuals associated with the Russian government.^[22] Such sanctions have included asset freezes, prohibitions on transactions with UK individuals and businesses, travel bans and transport sanctions.^[23] A recent example of this was the designation on 10 March of Roman Abramovich, where the Government noted that “He is one of the few oligarchs from the 1990s to maintain prominence under Putin”.^[24] Over 370 further individuals were sanctioned on 15 March 2022, and the Government stated that it would “have designated over 1,000 individuals and entities since invasion under the Russia sanctions regime” by the end of 15 March 2022.^[25]
23. Prior to those designations, concern had been expressed at the speed of the imposition of sanctions against individuals, and Mr Keatinge told us that, in this area, “the UK is not progressing well in contrast to our peers”.^[26] However, he also cautioned that “We should be going after these individuals, but I repeat: it has become a very unhelpful metric by which to judge how the UK is progressing.”^[27] He argued that “It is unfortunate that we have got so hung up on whether Mr X or Mr Y is subject to sanctions. In reality, as I think we all agree on this panel, what is going to crush—I use that word advisedly—the Russian economy, is not sanctioning Mr X and Mr Y”.^[28]

Illicit finance

24. The need for effective economic sanctions has also raised, again, concerns about the flow of illicit finance into the UK from Russia. The Government has recently, if belatedly, taken steps in this area through the Economic Crime (Transparency and Enforcement) Act 2022, which:
    • introduces an overseas entities register for UK property, to give more clarity in future to where beneficial ownership of property lies;
    • strengthens the ability to use Unexplained Wealth Orders for seizing assets;
    • assists OFSI in imposing monetary penalties; and
    • streamlines the process for applying economic sanctions, and reduces the areas in which damages can be paid.^[29]
    We also note that the Government has announced a new “’kleptocracy’ cell” based in the National Crime Agency.^[30]
25. We also note, however, that combatting illicit finance is essentially an objective of antimoney laundering tools rather than sanctions tools. Dr Justine Walker, Head of Global Sanctions and Risk at the Association of Certified Anti-Money Laundering Specialists, drew to our attention this distinction and its consequences:

    In my mind, those are two very different conversations, because the legal framework is very different. If you are trying to prove illicit wealth, and to seize assets on the basis of illicit wealth, you have to have grounds to prove that. However, if this is a sanction to do with proximity to Putin and closeness, it is a different type of conversation.^[31]

26. Our most recent Report on Economic Crime, published in February 2022, included

    recommendations on the introduction of an overseas entities register^[32] and a series of recommendations to tackle money-laundering. A Government response to that Report is due in April 2022.

Sanctions: the impact on Russia

27. We invited witnesses to set out their assessment of the economic impact upon Russia of sanctions already imposed. Prior to our hearing, on 2 March 2022, the National Institute for Economic and Social Research (NIESR) had suggested that sanctions would lead to a 2.6% fall in Russian GDP next year in comparison to its previous forecast.^[33] However, in evidence to us on 14 March 2022, Professor Jagjit Chadha, Director at NIESR, spoke of “a very large hit to activity in the Russian economy” and noted that, if further sanctions were to be imposed to shut off Russian energy exports:

    [ ... ] you could imagine those numbers at least doubling or even tripling from where we posited them last week, so to 5% or more in terms of the contraction in the Russian economy. Once we are into those sorts of numbers, we need to go from a quantitative statement to a qualitative statement, which is to say that that will be a very large hit on the Russian economy, which will be terribly problematic and will have a distributional consequence: it will be particularly damaging for those on fixed incomes or low wages.^[34]

28. Neil Shearing, Group Chief Economist at Capital Economics, held a similar view, telling us that “you will get a fall in GDP of more than 5%, I’m sure, and probably closer to 10%. There is going to be an acute period of pain over the next 18 months to two years in Russia.”^[35] He believed that if energy was included in the sanctions package, the negative impact on growth “[ … ] becomes substantially larger—maybe [shrinking] 15% or 20%, so substantial hits to the real economy. That spreads through the economy but obviously hits Russian consumers particularly”.^[36] But he also noted that “I think that, unless something changes, Russia is now set on a path towards long-term economic isolation; and in those circumstances, there is going to be a period of less acute but persistent economic weakness—stagnation, if you like—for a long period”.^[37]
29. Alongside this hit to economic growth, Professor Chadha noted that “We currently expect [Russian] inflation to go into the region of 20% to 30%”.^[38] The Russian rouble has also devalued, and its exchange rate remains volatile. At the time of writing, it is around 25% lower against the US dollar than it was immediately prior to the invasion.^[39] However, given the lack of complete sanctions on Russian energy, Professor Chadha also noted that high oil and gas prices “[ … ] in foreign exchange terms has provided the Russian economy with a large hedge”.^[40]
30. Mr Shearing described the sanctions on the Russian Central Bank as “unprecedented for a G20 economy” and said that “they are principally what is causing the economic pain right now”.^[41]
31. Dr Amrita Sen, Director of Research at Energy Aspects, described the effect of denial of Russian access to SWIFT on firms’ behaviour:

    Pretty much overnight, even if you take self-sanctioning out of the picture, companies really struggled, because SWIFT is the easiest way for payment. You immediately saw companies backing out and saying, “We are no longer going to deal with Russia”.^[42]

32. The Government observes that Russian oil exports are being harmed by self-sanctions that are not specific to oil and gas production:

    Russian oil is already being ostracised by the market, with nearly 70% of Russian oil currently struggling to find a buyer, and in a competitive global market demand will quickly be met by alternative suppliers.^[43]

33. Dr Sen agreed that Russia’s ability to export oil and gas is already being harmed by existing technology sanctions and self-sanctions by companies leaving the Russian market. She told us that even though Western technology could be replaced by China or India, “the technology is just not the same [and would mean Russia] will only be able to get maybe 60% to 70%”^[44] of the full yield from its oil compared to using Western technology. Dr Sen also explained that Russian production is likely to be hampered by the economic sanctions imposed. She said:

    Russian production depends heavily on tax breaks given by the Government. These sanctions are crippling for the economy. Our economists think you could get Russian GDP going down by 20%, potentially. I know their official forecast is for 8%. There is no way that the Government will have money for tax breaks, which is what is required to produce in some of these more difficult areas. We absolutely think that, in the longer term, Russian production is crippled. Oil production is about 11 million barrels per day. Maybe it will struggle to get above 8 million or 9 million, even with Chinese and Indian help.^[45]

34. Russia may also be impacted by the EU’s announcement on the 8 March 2022 of its REPowerEU: Joint European action for more affordable, secure and sustainable energy plan outline, which aims to “reduce EU demand for Russian gas by two thirds before the end of the year.” The plan also suggests that “phasing out our [the EU’s] dependence on fossil fuels from Russia can be done well before 2030”.^[46] On the same day that the EU announced its REPowerEU plan, the US announced bans on the importation of Russian crude oil, LNG and coal. It also banned new investment in Russia’s energy sector and prohibitions on Americans financing or enabling foreign companies that are making investment to produce energy in Russia.^[47]
35. As for the potential impact on the Russian consumer, Mr Shearing told us that:

    We have seen some evidence of what I would call mini bank runs. I think that happened last week, and we are seeing less evidence of that this week, so that seems to have been snuffed out quite quickly. In terms of how this will be felt by ordinary Russians, there will be a variety of ways but principally there is going to much higher inflation and a squeeze on real incomes as a result. It is going to be much more difficult to get access to credit because of what is happening in the financial system.^[48]

36. Dr Walker emphasised the impact for Russian citizens:

    We are just seeing people—as in, ordinary citizens—desperately trying to move money. We are hearing from colleagues in Russia about the challenges that they are facing now to access money: the interest rates [which have gone from 9.5% to 20%]^[49] and the impact. So I think the short-term impact that is having is very clear.^[50]

37. Another potential consequence of sanctions could be Russia defaulting on its debts, and the impact of that. Mr Shearing provided the following description of the seeming resiliency of the Russian Government’s finances and the risk of a default:

    Russia’s Government balance sheet is, in order of magnitude, much stronger now. There is much less debt in the system. It is running budget surpluses—partly because of the fortress Russia point that we talked about.^[51] The risk of an enforced default because they simply cannot afford to pay is much lower. There is a question of whether there is a selective default out of choice. Indeed, we have started to see some signs that that might emerge—among local currency bonds to foreign investors I suspect we will see non-payment, certainly of coupons in that area. It is a relatively small part of global financial systems. I do not think it would have major financial contagion. Obviously, in 1998, there was contagion. LTCM, a big hedge fund in the US, collapsed partly as a result of taking big bets on Russian debt. There is less of a big contagion risk this time around, but there is also potential for unanticipated consequences.^[52]

38. There have been suggestions from Russia that it could pay in roubles, even where US

    dollars are required. Fitch has said that such an action would constitute a default.^[53] Were Russia to do so, it would represent its first external debt default since 1917. As reported in Reuters, “Russia’s last major external debt default was over a century ago, when Bolsheviks failed to recognise Tsarist debt after the 1917 revolution”. Russia did previously default on its internal debts in 1998.^[54]

39. Following the invasion of Ukraine by Russia, each of the three major credit rating agencies has downgraded Russia’s long term foreign currency debt, which is now all at “junk” rating level: Fitch’s rating has fallen from ‘BBB’^[55] to ‘C’^[56]; S&P Global’s has fallen from ‘BBB-’^[57] to ‘CC’^[58]; and Moody’s rating has fallen from ‘B3’ to ‘Ca’.^[59]
40. The Russian economy, and its citizens, have already been substantially hit by the significant sanctions imposed by the UK and its international partners, and Russia faces both a significant hit to the size of its economy and significant inflation. One of the boldest moves in the financial sanctions package has been the sanctions levelled at the Russian Central Bank, which appear to have denied access by Russia to half of its reserves. The energy sanctions already imposed are likely to inflict significant damage on the Russian economy. If energy sanctions and reductions in demand are introduced in line with the statements made by the United States, EU, the UK and others then the impact on Russia’s economy could be catastrophic and long lasting.
41. Where there remain elements of the sanctions net around Russia not yet closed, including to allow energy payments and supplies, the Government should consider how to ensure there is minimal leakage.

Guidance, compliance and enforcement

42. Witnesses commented on the importance of compliance and the provision of guidance to private sector firms, on which the burden of implementation largely falls.^[60] Dr Justine Walker, Head of Global Sanctions and Risk at the Association of Certified AntiMoney Laundering Specialists, told us that she did “not think our compliance is probably very good, because the level we ask people to comply to is so complex”. She did, however, point to investment by banks and global corporates in sanctions training and compliance, noting that “At the board level, in many ways, sanctions compliance is seen as a more critical issue than some of the other wider financial crime elements, because if you get it wrong from the US side in particular, it is very significant.”^[61]
43. Tom Keatinge, Director at the Centre for Financial Crime and Security Studies (CFCS), Royal United Services Institute (RUSI), called for “clear communication when the sanctions are issued, details that allow [firms] to understand precisely who or what is being sanctioned, and for them to be able to process that. At the moment, we do not have that to the level we need to have it.”^[62] He saw the US as the “gold standard” for issuing sanctions guidance.^[63]
44. OFSI imposes monetary fines for breaches of sanctions and can pass suspected breaches of sanctions to the National Crime Agency (NCA) for further criminal investigation. The NCA provides support, including developing intelligence and providing specialist operational capability.^[64] OFSI has imposed only six fines since it was set up in March 2016.^[65] During this same period, the equivalent United States Office of Foreign Asset Control imposed 92 civil penalties (Penalties/Settlements) totalling $1,547,911,400.51.^[66] However, Dr Walker cautioned that a “true picture” of OFSI’s work should also look at the number of cases “opened and the number of nonenforcement-type actions that it has issued.”^[67] As we have noted above, the recent Economic Crime (Transparency and Enforcement) Act enables the Government to impose sanctions more quickly^[68] and makes it easier to impose monetary penalties for breaches of sanctions.^[69]

The role of OFSI

45. The Office of Financial Sanctions Implementation (OFSI), which is a part of HM Treasury, states that it “ensures financial sanctions are properly understood, enforced and implemented in the UK”.^[70] OFSI produces guidance for individuals and legal entities setting out its approach to licensing and compliance issues.^[71] The latest published figures for the Office indicate that it has 37.8 full time equivalent staff.^[72]
46. Witnesses questioned whether OFSI currently had the resources to undertake the twin tasks of compliance and enforcement, given the unprecedented scale of the task which it faced.^[73] Mr Keatinge said that:

    If we had had this conversation two weeks ago, I would have said that is absolutely fine, but they are facing a mountain now. There is an important point on this. I have not seen any statements on OFSI, but I have heard the Foreign Secretary say there has been a tripling of capacity in the sanctions unit in FCDO. The question I have is: does that tripling of capacity have the expertise to deal with the challenge that is ahead? I think we need to make sure that whatever OFSI does to expand [ ... ] in order to meet the current challenge, we need to make sure that that expansion is not just people, but people with the necessary expertise.^[74]

47. He added that:

    Obviously, the UK is faced with an unprecedented workload, and as I think we can all agree, OFSI was not set up to deal with what it is facing at the moment. We have to be realistic and, if you like, fair to it. The question is: how do we, as quickly as possible, ramp up capacity and ramp up guidance and everything that is needed?^[75]

    On expertise, and as way of example, he noted in relation to previous sanctions regarding the annexation of Crimea, that he had been told that no one involved with sanctions enforcement at that time could speak Russian.^[76]

48. Dr Justine Walker, Head of Global Sanctions and Risk at the Association of Certified Anti-Money Laundering Specialists, provided the following comparison of the scale of the UK enforcement operation to other countries:

    [ ... ] It is very clear that there has been a long-standing conversation and question around UK enforcement action. In comparison with the US, we see a lot less enforcement action. We are obviously a smaller country. I would also say that if you are comparing numbers, as people are looking at numbers here, the Treasury—the [United States Office of Foreign Assets Control] OFAC side—has hundreds upon hundreds of staff, and it is only covering the OFAC element, not the wider Treasury aspect. We do not have the comparable resources, so it does really depend on who you are comparing us against.

    If you compare us against somewhere like the US, we do not meet that. If you compare us against many of our European partners, we look quite good, so it depends on what you are looking at. Yes, I would accept that there is maybe a reason to look at the enforcement numbers. Enforcement does focus compliance thinking.^[77]

    The US OFAC was reported to have had 204 staff in 2020, against authorisation for 259 full time equivalents.^[78]

49. The sanctions against Russia are without precedent given the size of its economy and its integration with the West. The implementation of sanctions requires compliance action by the private sector. We are therefore concerned that guidance for those who have to implement sanctions has, at least in the initial stages, appeared to have lagged behind that available in the United States. The Government must, as a priority, ensure that its guidance is clear, precise and readily available, to allow the effective implementation of sanctions across the private sector.
50. The Government is right to see economic sanctions as a critical weapon in resisting Putin’s war. As such the Government needs to consider increasing the Office of Financial Sanctions Implementation’s resources without delay and to provide surge capacity in the form of staff with appropriate expertise.

Sanctions evasion: Cryptocurrencies

51. Following the imposition of financial sanctions on Russia, there was a concern that cryptocurrencies might be used to evade those sanctions. However, Mr Keatinge, while accepting that “we need to keep an eye on the crypto ball”, noted that “the volume of financial access that the Russian Government will need to evade sanctions is not something that the crypto sector could support.”^[79] He went to add: “I am not convinced that, right now, [focusing on cryptocurrency] is a major determinant of our objective—which is to crush the Russian economy and make Vladimir Putin think again or make him unable to fund his military—or that it will change that calculation”.^[80]
52. On 11 March 2022, OFSI, the FCA and the Bank of England issued a joint statement on sanctions and the cryptoasset sector, which included a reminder to firms that:

    Financial sanctions regulations do not differentiate between cryptoassets and other forms of assets. The use of cryptoassets to circumvent economic sanctions is a criminal offence under the Money Laundering Regulations 2017 and regulations made under the Sanctions and Anti-Money Laundering Act 2018.^[81]

53. We welcome the reminder from the regulatory authorities to cryptoasset firms that cryptoassets are within the scope of the sanctions regime. We recommend that the Government take a watchful approach to how cryptocurrencies are used to potentially evade sanctions, and ensure it has the knowledge and expertise to effectively monitor developments in this area.

Secondary sanctions

54. Secondary sanctions are intended to put pressure on third parties to stop them carrying out business with a sanctioned entity. If the third party fails to stop dealing with the sanctioned entity, it will also be cut off from the sanctioning country.^[82]
55. Witnesses noted the additional foreign policy concerns and economic costs that secondary sanctions might entail. Mr Keatinge explained that imposing secondary sanctions on third party countries who are “sitting on the fence at the moment” could “antagonise them” when “they clearly might play a role in resolving this conflict.”^[83] When asked about imposing economic sanctions on Chinese companies if they help Russia to evade the worst of the sanctions, Tony Danker, Director-General at the Confederation of British Industry replied: “I think that is a political judgment, but I think the one thing that we have learned from this discussion is that there is no such thing as cost-free economic warfare. I would ask the policy makers to think thoughtfully about some of these responses.”^[84]
56. We note the caution expressed by witnesses about the impact of possible secondary sanctions. This is largely a matter for the Foreign, Commonwealth and Development Office, which will need to take into account the economic cost to the UK, but also the extent to which Russia circumvents Western sanctions through non-sanctioned Russian reserves and her trade with other countries.

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2. Q2
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29. Economic Crime (Transparency and Enforcement) Act 2022; and ECONOMIC CRIME (TRANSPARENCY AND ENFORCEMENT) BILL EXPLANATORY NOTES, prepared by the Home Office, March 2022
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32. Treasury Committee, Eleventh Report of Session 2021—22, Economic Crime, HC 145, para 247
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50. Q65
51. Mr Shearing had said in answer to Q32: “‘Since the Crimea annexation in 2014, Russia has been running a programme that people have called “fortress Russia” in terms of the economy—running large external surpluses, building up large stocks of foreign assets and cutting external liabilities, therefore diminishing vulnerability to measures like this.”
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60. See for example Mr Keatinge Q9
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62. Q93
63. Q9
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