OFSI updates its Financial Sanctions: FAQs

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.

How Gherson can help: Gherson lawyers have over 20 years of experience in advising on compliance with UK laws and regulations, including sanctions compliance. Should you need any assistance, please do not hesitate to contact us for advice or send us an e-mail. Don’t forget to follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2024