On 5, 7, 11 and 14 November 2024, the HM Treasury Office of Financial Sanctions Implementation (“OFSI”) added and amended over 20 FAQs relating to UK restrictive measures and their implementation.
5 November 2024
On 5 November 2024, FAQs 49-51, 55, 61-66, 72-73, 76 and 84 were amended to reflect the new Legal Services General Licence INT/2024/5334756.
These amendments provide further detail on the new General Licence for Legal Fees payments and how the fees and expenses caps apply.
OFSI also explained that General Licence INT/2024/5334756 introduced a restricted permission to pay into non-UK bank accounts, provided that relevant conditions are met.
7 and 11 November 2024
On 7 and 11 November 2024, OFSI added new FAQs 123 and 124 respectively to its FAQs guidance. Both FAQs relate to the equities held at the Russian National Settlement Depository (NSD).
On 7 November 2024, OFSI announced a two-week extension to their original deadline of 11 November 2024 for the relevant institutions to report on frozen funds or economic resources belonging to, owned, held or controlled by a designated person for the Frozen Assets Review 2024 (FAQ 123).
On 11 November 2024, OFSI advised UK companies and financial institutions to exercise increased diligence when dealing with Russian local registrars holding equities moved from the NSD. These entities may not be designated themselves, but could be owned or controlled by designated persons, requiring their assets to be treated as frozen (FAQ 124).
14 November 2024
On 14 November 2024, FAQs 125-131 were added to OFSI FAQs guidance, relating to a new regulatory payments exception coming into force in December.
From 5 December 2024, non-UN designated persons (non-UN DPs) can make certain payments without an OFSI licence, including:
- Payments to HMRC, Revenue Scotland and the Welsh Revenue Authority;
- Fees payable to Companies House, with the exception of fees for
(i) incorporating a firm;
(ii) restoring a firm to a register administered by Companies House.
- Fees payable to the Financial Conduct Authority with some exceptions;
- Council tax payments;
- Business rates or non-domestic rates;
- Business Improvement District levies.
Gherson lawyers have significant experience in engaging with regulatory authorities in the UK and overseas, advising clients on various aspects of OFSI licencing regimes and compliance.
Previous Gherson blogs on OFSI FAQs can be found here:
- OFSI Adds Two New FAQs to UK Financial Sanctions Guidance and Amends General Licence on Water Payments
- OFSI updates its Financial Sanctions: FAQs
- OFSI publishes its first Financial Sanctions FAQs
Updated 14 November 2024
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