UK implements latest Ukrainian sanctions: The EU published its Regulation on the further Ukrainian sanctions (833/2014 - the EU Regulation) on 31 July. Treasury has made the Ukraine (European Union Financial Sanctions) (No 3) Regulations 2014 which prohibit UK persons or entities from purchasing, selling, providing brokering or assistance in the issuance of, or otherwise dealing, directly or indirectly, with transferable securities and money-market instruments with a maturity exceeding 90 days by (i) any of the entities listed in the EU Regulation (Listed Person), (ii) any legal person, entity or body established outside the European Union, more than 50% of the proprietary rights of which are owned by a Listed Person, or (iii) a person acting on behalf of, or at the direction of, a Listed Person. It is also an offence to knowingly take action to circumvent the prohibition, to fail to respond to Treasury's questions and for relevant institutions to fail to notify Treasury of certain matters. See our separate update for further information on these Regulations and the further restrictions imposed by the EU. FCA has reminded firms of its expectations of robust systems and controls to comply with financial crime legislation and the importance of identifying when they deal with politically exposed persons. It also stated that so long as the new sanctions remain in force it does not expect (i) to admit to listing securities issued after 1 August by issuers within the scope of the EU Regulation or (ii) depositaries for GDR issuers within the scope of the Regulation to issue new depositary receipts. (Source: Council Regulation 833/2014the Ukraine (European Union Financial Sanctions) (No 3) Regulations 2014,Treasury Guidance Notice and FCA Guidance Page)

Treasury makes ring-fencing exclusions order: Treasury has made the Financial Services and Markets Act 2000 (Excluded Activities and Prohibitions Order) 2014. The definitions sections in the Order take effect from 1 January 2015 but in the main it takes effect on 1 January 2019. The Order sets out the circumstances in which ring-fenced bodies can carry on activities that would otherwise be prohibited. It sets out each relevant activity and the circumstances in which ring-fenced bodies may engage in it. It also confirmed the ban on relevant institutions setting up a non-EEA subsidiary unless that subsidiary does not carry on any activities that would be regulated activities in the UK. (Source:Treasury Makes Ring Fencing Exclusions Order)