My Lords, I thank the noble Lords, Lord Addington and Lord Collins, for their strong support. That sends out a very strong message, not just to Russia and Mr Putin but to those who are trying to circumvent the impact of sanctions.
I assure the noble Lord, Lord Addington, that, partly as the sanctions come into play and we identify where the gaps are, we are monitoring the impact of these with our key partners to ensure that when it comes to the circumvention of the new rules—those who are trying to get round sanctions—we can close those loopholes, as I said in my introduction.
We co-ordinate with our key allies. The noble Lord, Lord Collins, asked about differences that arise. Because of the different governance regimes that exist, there are occasions when we may be slightly ahead of others. Sometimes the American system does not require the same level of governance in terms of imposing the sanctions. What we are seeking to do is to work very closely with our allies.
On the issue of enforcement, which both noble Lords raised, first and foremost we are working with our G7 partners to ensure effective implementation of sanctions on Kremlin-related entities and elites, including through the Russian Elites, Proxies, and Oligarchs Task Force. Following further commitments by the former Prime Minister in February, the Government have also continued to work on this issue and have delivered the economic crime Act to crack down further. One issue, which will be subject to further debates as we seek further to strengthen these provisions, is whether it is done through the register of overseas entities, reforming our unexplained wealth orders or our ability to take action. I fully accept that we need to keep this under very close scrutiny to ensure that any gaps can be addressed.
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On 22 September 2022, the Government introduced the Economic Crime and Corporate Transparency Bill, which includes the fundamental reform of Companies House, reforms to prevent abuse in limited partnerships, and additional powers, which I know that noble Lords are aware of. Just to complete that element and to reassure the noble Lord, Lord Addington, we will keep this under review. If there are further areas that we need to act on, we will certainly take those measures as appropriate.
On sanctions circumvention, the actual package itself, as I said in the introduction, amends existing financial measures and restrictions on various financial instruments to close loopholes and prohibit this with regard to Russia via third countries. That is an issue that we have debated in your Lordships’ House. More broadly, in 2023, we will continue to bear down on Russia, ratcheting up economic pressure by implementing further sanctions and by leaning in to tackle Russia’s attempts to circumvent measures that are in place.
Just anecdotally, when I was working in the City and there were restrictions on particular countries, the private sector itself was involved, because of the added burden, challenges and requirements for compliance. We are beginning to see that very much: companies are themselves taking action to not deal with those that have associations. This package amends existing financial measures, restrictions on investments, loans, securities and money market instruments, to address those very issues, particularly the issue that we raised before about third-party actions.
To pick up the point that the noble Lord, Lord Collins, raised about the EU announcing that designated people are circumventing sanctions, we welcome the EU’s focus on this. On the issue of offences, it is a criminal offence under UK sanctions legislation intentionally to participate in circumvention of any sanctions prohibitions, including financial or trade sanctions, or to enable or facilitate the breach of sanctions prohibitions—and, yes, we have the powers to fine, prosecute and impose civil monetary penalties.
On the issue of whether there would be further sanctions in this regard, I do not want to speculate at this point, but I note what the noble Lord said. On the severity of certain sanctions and broader issues of the criminality of Russia’s actions, as the noble Lord will be aware, we are looking at that specifically. Tomorrow I hope, together with the Attorney-General, to brief the APPG on Ukraine specifically to look at what further actions we can take in holding to account those who perpetrate these crimes.