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Defeating Putin: the development, implementation and impact of economic sanctions on Russia
  1. trade sanctions.[1] Other departments also have responsibilities in this area. HM Treasury is also the economics ministry of the UK, which includes the responsibility of “ensuring the economy is growing sustainably”.[2]
  2. While the Financial Conduct Authority is not responsible for enforcing asset freezes or sanctions, it expects financial firms to put in place systems and controls to mitigate the risk of financial crime, which includes ensuring that they meet their financial sanctions obligations.[3]
Our inquiry
  2. On 3 March 2022, we announced that we would begin an inquiry into Russia: effective economic sanctions. We have taken as our terms of reference:
    • The effectiveness of the current economic sanctions that have been imposed in relation to the invasion of Ukraine by Russia
    • Scope for further possible economic sanctions in relation to the invasion of Ukraine by Russia
    • Compliance with the sanctions and the scope for evasion
    • The ability to take enforcement action against breaches, and the effectiveness of the enforcement regime
    • The impact of sanctions on the UK, Russian and world economy
    • The role of financial services in implementing sanctions, the impact of those sanctions on financial services, and the role of regulators.
  3. So far we have held two oral evidence sessions:
    • Monday 7 March 2022: Dr Justine Walker, Head of Global Sanctions and Risk at the Association of Certified Anti-Money Laundering Specialists; Natasha de Terán, payments policy expert; Tom Keatinge, Director at The Centre for Financial Crime and Security Studies (CFCS), Royal United Services Institute (RUSI); and Neil Shearing, Group Chief Economist at Capital Economics; and
    • Monday 14 March 2022: Professor Jagjit Chadha, Director at National Institute of Economic and Social Research (NIESR); Tony Danker, Director-General at the Confederation of British Industry (CBI); Nathan Piper, Head of Oil and Gas Research at Investec (speaking in a personal capacity); and Dr Amrita Sen, Director of Research at Energy Aspects.
    We would like to thank all those who have so far given evidence to us, especially given the speed at which they were called upon to do so.
  4. In a fast-moving and constantly evolving situation, this Report reflects our views on 21 March 2022, when it was agreed.
  1. ↑ Office of Financial Sanctions Implementation, UK FINANCIAL SANCTIONS General guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018, December 2020, p9
  2. ↑ GOV.UK, About us [HM Treasury], accessed 14 March 2022
  3. ↑ Financial Conduct Authority, Financial sanctions, Last updated: 24/02/2022, accessed 15 March 2022
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