On 15 August, OFSI updated its FAQs on UK sanctions by adding 20 new questions and answers to their Russia section. New FAQs 100-119 were previously included in OFSI Russia sanctions guidance, and they have now been added to the FAQs – centralised guidance. New FAQs relate to various aspects of banking, financial and business relationships providing comprehensive coverage of these matters to ensure full compliance with the requirements of UK sanctions legislation.
OFSI clarifies that:
- Russian nationals residing in the UK can open and maintain UK bank accounts as long as they are not designated and free from ownership or control by a sanctioned person (FAQ100).
- Overseas subsidiaries of UK entities shall comply with UK sanctions regime (FAQ101).
- An expired General Licence cannot be relied upon to lawfully make any payment(s) (FAQ102).
- Processing transactions which involve sanctioned financial institutions are prohibited unless it is authorised by OFSI in the form of a licence or there is an applicable exception(FAQ 107).
- A designated person is required to report changes of their funds to OFSI as soon as practicable, and failure to report them will result in civil monetary penalties (FAQs 118 & 119)
Gherson’s previous blogs on OFSI FAQs are available here and here.
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