Russian sanctions | London Metal Exchange

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This page sets out the LME’s understanding of how recent US, UK and EU sanctions against Russia and disputed Ukrainian areas may affect the LME’s market.

Background

The LME’s priority in any challenging geopolitical situation is to ensure that an orderly market is maintained, which includes providing a reliable price reflective of global market conditions.
We have robust procedures and the necessary powers in place to take any action that may be required to ensure market stability in response to sanctions that impact the LME market.
The LME maintains a list of global metals brands, and the metal produced by these brands can be placed on warrant and stored at an LME registered warehouse. A warrant is used to settle a relevant LME contract. In the event that any brand is subject to sanctions, we are in a position to respond swiftly and appropriately to take action in respect of the brand. Such action might include suspending the brand, or suspending production from a certain date. Due to the global nature of the LME brand list, continuity of supply can still be achieved even in the event of some brands being sanctioned due to their location.
We are also ready to take the appropriate action should any individual or entity subject to sanctions be active on the LME market.
We continue to monitor the developing situation closely.

Brands

In response to the announcements by the US government on 24 February 2023, which impose – from 10 March 2023 – additional tariffs on imports of certain Russian metals, the LME will implement a suspension on the placing onto warrant of Russian-branded primary aluminium, NASAAC, copper, lead and nickel in US warehouses with immediate effect, in order to minimise the risk of price dislocation. While there is no Russian-branded primary aluminium, copper, lead or nickel on warrant in LME-listed US warehouses, there is currently 400 tonnes of NASAAC on warrant. Therefore, in order to further mitigate the risk of market disorderliness, Russian-branded NASAAC will no longer be able to be used to deliver against NASAAC with immediate effect. It should be noted that there is currently no open interest in NASAAC at this time, so no deliveries are required to be made against the contract. For further information please see LME notice 23/034.

Since the LME published notice 23/034, further guidance on the additional tariffs in respect of certain Russian metals has been issued by the US government and the LME understands that the Russian-branded primary aluminium and aluminium alloy (in the form of NASAAC) will each have a cumulative tariff rate of 270%. The requirements as outlined in notice 23/034 continue to remain in effect, however the LME notes that the tariff rates referred to in the notice for primary aluminium and NASAAC branded metal do not reflect the cumulative tariff rates.

President Biden issued an Executive Order on 22 February 2022, which, among other things, prohibits investment into certain Ukranian regions (non government-controlled Donetsk and Luhansk) and also the importation of goods from those regions. The EU has taken similar action in respect of these regions, and the LME understands that the UK will follow suit in the coming days. There is one aluminium alloy brand URV produced by “TPK Urksplav” Ltd in one of these regions, however the brand is currently suspended and there is no stock on LME warrant. For completeness, we note that there are also two lead brands produced by CJSC "SVINETS" in Donetsk but these are not produced in the affected part of Donetsk and are therefore not impacted by the Executive Order. Further, in the event of sanctions in respect of Belarus, the LME has no Belarussian brands.

Further, the LME notes the sanctions announced by the EU on 28 February 2022 against Mr Alisher Usmanov and by the UK on 10 March 2022 against Mr Oleg Deripaska. Our understanding is that these sanctions do not impact any of the LME’s listed brands.

The LME also notes the Russian restrictions on exports and imports introduced on 8 March 2022. It is our understanding that these restrictions do not include metals and therefore do not affect LME brands.

The EU recently imposed further sanctions on Russia through Regulation (EU) 2022/428, which, amongst other things, imposes prohibitions relating to purchasing, transporting or importing certain iron and steel products which are located in, or originate from, Russia. The LME understands that these sanctions will not impact any of the LME physically deliverable contracts and we are in the process of working with index providers to determine whether they will have any impact on LME steel contracts.

EU Council Regulation No. 833/2014, which came into effect on 8 April 2022, states that it is prohibited (effective 9 April) to purchase, import, or transfer, directly or indirectly, certain listed items including "unwrought lead" into the EU, if they originate in Russia or are exported from Russia. In view of the potentially broad nature of the restrictive measures (outlined in notice 22/136), and the potential application of those measures to those subject to the jurisdiction of the EU, the LME considers that as a precautionary matter it is appropriate to suspend with immediate effect all deliveries of Russian lead into all LME warehouses. There are currently no warrants in the LME’s electronic warrant transfer system related to lead of Russian origin or lead which has been exported from Russia; however, there is one listed Russian lead brand: FRGT PB985R produced by Fregat LLC. Further information can be found in notice 22/136.

As a result of the UK government’s decision in March 2022 to place 35% additional duties on imports of Russian copper, lead, primary aluminium and aluminium alloy, we announced an immediate suspension (see notice 22/097) on placing Russian brands on warrant in LME-listed UK warehouses unless exported from Russia prior to 25 March 2022. While we do not currently have any Russian metal on warrant in LME-listed UK warehouses, the additional duties would mean that any Russian metal delivered into LME-listed UK warehouses could not then be removed from warrant and imported into the UK or shipped elsewhere without significant additional cost, which could introduce significant risk of price dislocation and disorderly market conditions

Following the announcement by the UK in July 2022 of a 35% additional duty on imports of Russian nickel, we have announced an immediate suspension (see notice 22/200) on placing Russian nickel brands on warrant in LME-registered UK warehouses unless exported from Russia prior to 20 July 2022. This is an extension of the warranting restrictions currently in place for Russian produced copper, lead and aluminium in LME-listed warehouses in the UK. This decision has been taken to minimise the risk of any price dislocation, market disruption or disorderly market conditions as a consequence of the UK legislation. The LME currently does not have any Russian nickel on warrant in UK warehouses.

The LME notes that on 19 May 2023 the UK government announced its intention to ban imports of Russian-origin copper, aluminium and nickel later this year. The UK government has yet to introduce legislation which implements the aforementioned ban, with the LME continuing to closely monitor for further developments. As outlined above, the LME suspended the warranting of Russian-origin copper, aluminium, nickel and lead in LME-licensed UK warehouses in 2022 due to the 35% additional duties applied on imports of these materials. In the event that the LME considers any further action is required beyond the suspension that is already in place, the LME will communicate this to the market.

The LME is aware that a number of nations, including the US, EU, UK and other G7 countries, have taken measures to revoke Russia’s most-favoured-nation (“MFN”) trade status. The LME has been closely monitoring whether the revocation of Russia’s MFN status by certain States would have an impact on the LME, its members or LME-listed warehouses. The LME notes the recent increase in UK tariffs on Russian origin copper, lead and aluminium, as discussed further above (also see notice 22/097). The LME is also aware that there have been additional tariff increases for certain metals of Russia origin imported into the US, however a number of US tariff increases on metals are not relevant to the grade of metal deliverable against LME contracts. The LME understands that the highest US tariff rate applied for the importation of LME warranted metal of Russian origin remains below 11%, which the LME believes is at a level which should not impede the orderly functioning of the market. The LME will continue to monitor the situation and provide updates if there are any further substantial tariff increases to Russian origin LME warranted metal.

The LME notes the EU’s announcement on 22 July 2022 regarding sanctions against Andrey Kozitsyn, co-founder and CEO of UMMC. The LME understands that the sanctions do not extend to UMMC itself because Mr Kozitsyn does not own or control UMMC for the purpose of the EU sanctions.

However, following the sanctions announced by the UK government on 26 September 2022 in respect of Mr Makhmudov, the LME Special Committee, pursuant to its powers under Regulation 17 of Part 3 of the LME Rulebook, has introduced with effect from 5 October 2022, a temporary imposition of conditions on placing UMMC and Chelyabinsk branded metals on warrant such that the UMMC or Chelyabinsk branded metals shall only be capable of being placed on warrant if the metal owner can demonstrate to the satisfaction of the LME that placing UMMC or Chelyabinsk branded metal on warrant will not constitute a breach of the sanctions. The temporary imposition of conditions shall continue until further notice. The LME will continue to engage with stakeholders and keep the decision of the Special Committee in respect of UMMC and Chelyabinsk branded metal under review. For further details please see Notice 22/239.

Following the UK government’s announcement on 29 June 2022 of sanctions against Vladimir Potanin – who is CEO of, and an indirect minority shareholder in, MMC Norilsk Nickel, the LME has assessed the detail of the sanctions and their impact on LME, its participants, and Norilsk brands. On the basis of the information available to the LME, the LME has determined that Vladimir Potanin does not appear to control the day to day affairs of Norilsk for the purposes of the sanctions. The LME continues to monitor the situation and will act accordingly in the event that new information comes to light or further guidance on these sanctions is issued.

Counterparties

Starting 22 February 2022, the US, EU and UK have announced widespread sanctions against Russian entities and individuals. Neither the LME nor LME Clear have any Russian entities as members. The LME understands that a small number of members may have open positions, directly or indirectly, with Russian individuals or entities which have become subject to sanctions. Where this is the case, the member must ensure that it takes immediate action to achieve sanctions compliance, including ensuring that no payments are made to any sanctioned person. We would make the following points in relation to this:

It is essential that members undertake their own checks against relevant sanctions lists;
The US sanctions include certain general licences authorising wind-down activities in derivative contracts. The UK has also issued a general licence authorising the wind down of any transactions involving sanctioned individuals and entities. The UK sanctions require that funds or economic resources owned, held or controlled (directly or indirectly) by a sanctioned person or entity are frozen and there is also a prohibition on making funds or economic resources available directly or indirectly to or for the benefit of a designated person or entity. Accordingly, if a member is holding a position with or on behalf of a designated person or entity, any payments must be frozen, unless the member obtains a specific licence. The member will need to consider what other action needs to be taken in respect of the position, in accordance with the relevant terms of business;
Members are reminded of their contractual obligations under the LME and LME Clear Rules to comply with all relevant sanctions requirements and to ensure that any business conducted by or through them does not cause the LME or LME Clear to be in breach of any relevant sanctions requirements;
Members who have positions with or for the benefit of any sanctioned entity should contact the LME without delay to confirm the positions they hold and confirm the action they are taking. Currently, we anticipate taking the following action:
- LME Clear removing the “auto-repay” function for the relevant account within LMEmercury so that the member makes manual withdrawals from the account. This should assist with sanctions compliance by ensuring no relevant payments are made automatically: the member can ensure any payments due relating to a position with a sanctioned entity are blocked;
- Re-confirming to the LME and LME Clear that the member will comply with all relevant sanctions requirements and will ensure that any business conducted by or through them does not cause the LME or LME Clear to be in breach of any relevant sanctions requirements (all relevant members will be required to provide a standard form of undertaking wording);

The EU has recently introduced sanctions in relation to Belarus, however the LME and LME Clear do not have any Belarussian entities as members. The LME also understands that its members do not have any open positions, directly or indirectly, with Belarussian individuals or entities which have become subject to sanctions.

We do not believe that the exclusion of some Russian and Belarussian entities from Swift will have any direct impact on the LME’s market, and the existing stock of metal on warrant will be unaffected.

This page will be updated from time to time and any questions should be directed to RM@lme.com.

Note – this web page is intended for information only, does not constitute legal advice and should not be relied upon by any person. Any party that may be affected by the sanctions should obtain their own legal advice.