Changeflow GovPing Trade & Export PJSC Transneft Wind Down General Licence
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PJSC Transneft Wind Down General Licence

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Published February 24th, 2026
Detected March 6th, 2026
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Summary

HM Treasury has issued a General Licence for the wind-down of transactions involving PJSC Transneft, effective February 24, 2026, and expiring April 9, 2026. This licence exempts certain acts from Russia sanctions prohibitions to facilitate divestment and transaction closure.

What changed

HM Treasury has issued a General Licence (INT/2026/8889196) under the Russia (Sanctions) (EU Exit) Regulations 2019, permitting individuals and entities ('Persons') to wind down or divest from transactions involving PJSC Transneft (the 'DP') or its subsidiaries. This licence is effective from February 24, 2026, and expires on April 9, 2026. It allows for the closing out of positions and any reasonably necessary activity to affect this divestment, provided that the actions do not otherwise breach the Russia Regulations.

Regulated entities, including financial institutions, must maintain accurate records of all activities conducted under this licence for a minimum of six years. The licence provides a specific, albeit short, window for compliance officers to manage and execute the necessary steps for winding down operations related to PJSC Transneft. Failure to comply with the record-keeping requirements or other provisions of the Russia Regulations could result in penalties.

What to do next

  1. Review licence conditions and identify all transactions involving PJSC Transneft or its subsidiaries.
  2. Execute wind-down or divestment activities within the licence period.
  3. Maintain detailed records of all permitted activities for at least six years.

Penalties

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Source document (simplified)

G E N E R A L L I C E N C E – P J S C T r a n s n e f t W i n d D o w n G e n e r a l L i c e n c e INT/2026/88 89196 1. This licence is gra nted under re gulation 64 of the Russia (Sanctions) (EU E xit) Regulations 2019 (” the Russia Regulations”). 2. Any act which wou ld othe rwise breach the prohibitions set out in regulations 11 to 15 of the Russia Regulations is exempt from those prohibitions to the extent required to give effect to the permission s in this licen ce. 3. In this licenc e: The “ DP ” means PJSC Transneft; and A Subsidiary, (ea ch a “DP”) A “ Subsidiary ” me ans Any entity inc orporated a nywhere in the world own ed or controlled, direc tly or indire ctly, by PJSC Trans neft within the mean ing of regula tion 7 of the Russia Regulations. “ Person ” means An individual or a body of persons corporate or unincorporate but does not include a Designated Person. “ Designated Person ” mea ns Any individual or a body of persons (corpora te or unincorporate) designated un der regulation 5 of the Russia Regulations an d/or an y individual or b ody of persons (corporate or unincorporate) owned or controlled directly or indire ctly b y that design ated person within the me aning of re gulation 7 of the Russia Regulations. “ Relevant UK Inst itution ” means A person that ha s permission un der Part 4A of the Financial Se rvices and Ma rkets Act 2000 (per mission to carry on regulated ac tivity). A person that is au thoris ed or registered un der Part 2 of the Payment Se rvices Re gulations (SI 2017/75 2). A person that is au thoris ed or registered un der Part 2 of the Electronic Money Regul ations (SI 2011/99). A person that is a “recognised clearing hou se”, “th ird country central c ounterparty”, “recognised CSD” or “third country CSD ” for th e purposes of s.285 of the Financial Se rvices and Ma rkets Act 2000. A person that is an opera tor of a recognised paym ent system (or that is a service provider in relation to recognised payment systems) f or the purposes of Part 5 of the Banking Act 2009.

Permissions 4. Under this licen ce, subjec t to the conditions below a Person may wind down or divest from any transactions involving the DP to which that Person is a party, including the closing out of any posit io ns, and a Person, a Relevan t UK Institution, or the DP can carry out any activity reasonab ly necessary to affect thi s. Record-keepin g Requiremen ts 5. A DP, a Person, or a Relevan t UK Institution under taking any activity permi tt ed or purporting to ha ve been permitted under this licen ce must keep accu rate, comple te, and readable records, on paper or electronically, of that activit y for a minimu m of 6 year s. General 6. The permissions in t his licen ce do not authorise a ny act which will result in a breach of any part of the Russia Regulations, save as perm itted under this or other l icences granted under the Russ ia Regulations. 7. Information provi ded to HM Treasu ry in conne ction with this lic ence shall be disc losed to third parties only in complian ce with the UK Gen eral Data Pro tection Regul ation and the Data Protection Ac t 2018. 8. This licence takes e ffect from 24 Februa ry 202 6 and expires at 23:59 on 9 April 202 6. 9. HM Treasury ma y vary, revoke, or suspend this li cence at an y time. Signed: Office of Finan cial Sanctions I mplementat ion HM Treasury 24 Februa ry 2026.

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Various
Published
February 24th, 2026
Compliance deadline
April 9th, 2026 (26 days)
Instrument
Guidance
Legal weight
Binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Financial advisers Insurers Fund managers
Geographic scope
INT

Taxonomy

Primary area
Sanctions
Operational domain
Legal
Topics
Russia Sanctions Financial Services

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