The Andrey Lugovoy and Dmitri Kovtun Freezing Order 2020

Freezing prohibitions

4.—(1) The provisions of this article apply in relation to the following funds (“frozen funds”)—

(a) funds owned, held or controlled by Andrey Lugovoy; and

(b) funds owned, held or controlled by Dmitri Kovtun.

(2) A person must not make frozen funds available to or for the benefit of a specified person.

(3) A person must not make frozen funds available to a person at the direction or instruction of a specified person.

(4) A person must not deal with frozen funds.

(5) For the purposes of this article, making funds available to or for the benefit of a specified person includes—

(a) allowing a specified person to withdraw from an account;

(b) honouring a cheque payable to a specified person;

(c) crediting a specified person’s account with interest;

(d) releasing documents of title (such as share certificates) held on behalf of a specified person;

(e) making available the proceeds of realisation of property belonging to a specified person; and

(f) making a payment to or for the benefit of a specified person.

(6) In this article “deal with” means—

(a) use, alter, move, allow access to or transfer;

(b) deal with in any other way that would result in any change in volume, amount, location, ownership, possession, character or destination; or

(c) make any other change that would enable use, including portfolio management.