Partner Mark Hastings discusses sanctions and freezing orders, in The Times

Writing in The Times, Partner Mark Hastings explores the legal challenge the UK government may be bringing against Roman Abramovich over the proceeds from the sale of Chelsea Football Club, and discusses how this may set an uncomfortable precedent for future cases involving frozen assets.

Mark’s article was published in The Times, 19 June 2025.

Recent news that the UK government is threatening to sue Roman Abramovich has brought the Russian billionaire back into the spotlight. A fortnight after Russia invaded Ukraine, the then Foreign Secretary Liz Truss announced sanctions against seven of the wealthiest Russian oligarchs. Top of her list was Abramovich: the then owner of Chelsea FC saw his assets frozen, a prohibition on transactions with UK individuals and businesses, and the imposition of a travel ban.

Having owned Chelsea since 2003, he was granted a special licence to sell the club, provided he could prove that he would not benefit from the sale. In May 2022, Todd Boehly led a consortium, later known as BlueCo, which bought the club. Currently, the sale proceeds remain frozen in a UK bank account linked to Abramovich: although he cannot access the money, it still belongs to him in law.

Earlier this month, the UK government threatened to sue the former Chelsea owner to ensure that the frozen £2.5bn is ring-fenced to fund humanitarian causes only in Ukraine. Issuing a joint statement, Chancellor Rachel Reeves and Foreign Secretary David Lammy said: “While the door for negotiations will remain open, we are fully prepared to pursue this through the courts, if required, to ensure people suffering in Ukraine can benefit from these proceeds as soon as possible.”

The three-year delay in the funds being released centres on sustained disagreement between the UK government and Abramovich’s lawyers. Through them, the Russian oligarch argues that a much wider set of beneficiaries should receive money: proceeds from the sale should be donated via a foundation “for the benefit of all victims of the war in Ukraine”, according to Abramovich. This would include Russian soldiers and other charitable causes outside Ukraine.

After three years of fruitless discussion, the UK government is now seeking to break the impasse. But following the threat of legal action against Abramovich, with the intention of forcing his hand to agree that the £2.5bn be used as Reeves and Lammy have outlined, the government must now walk a legal tightrope in proving its case: one which neither sets a precedent for asset-freezing cases that undermines the rule of law, nor invites future legal challenges from other sanctioned parties.

An attempt by the UK government to force a release of the sale proceeds will risk a legal confrontation with the established sanctions framework. Legally, they must be dealt with under the terms of the licence granted by the Office of Financial Sanctions Implementation. However, it is conceivable that if the UK government proceeds down this road, other legal avenues might be considered, such as those under international investment treaties, depending on the circumstances.

Manifestly, turning a high-profile Premier League transaction into a High Court test case for sanctions enforcement will not be straightforward. To use one well-worn football management cliché: “There are no easy games at this level.”