OFSI updates its Guidance on Financial Sanctions FAQs

On 3 July, the Office of Financial Sanctions Implementation (“OFSI”) updated its UK Financial Sanctions FAQs Guidance by adding 4 new FAQs – 149, 150, 151 and 152, and withdrawing FAQs 123 and 124.

FAQ 149 provides a definition of economic resources which are assets of every kind and may include: precious metals or stones, antiques, vehicles, property, crypto assets, transportation tickets, access to a telecommunications network, as well as provision of services, such as consultancy or property maintenance.

FAQ 150 explains that an OFSI licence is required for a UK company involved in a transaction which is subject to UK financial sanctions even if a Crown Dependency or Overseas Territory licence has already been granted to the subsidiary of this company.

FAQ 151 states that even with an OFSI licence, a UK person is required to obtain an authorisation from the relevant Crown Dependency (CD) or Overseas Territory (OT) authorities for a payment that will be going through a bank account in a CD or OT.

FAQ 152 states that relevant institutions that held securities at designated local Russian registrars should “update their next annual Frozen Asset Report (FAR) to reflect any changes in the custody of these assets, rather than submitting initial reports ‘without delay’.”

On 10 July, the OFSI added FAQ 153 as relate to the term “domiciled”. OFSI has confirmed that the term is used on a case-by-case basis, and significant weight will be attached to an entity’s place of incorporation and constitution. Furthermore, some additional factors will be taken into account, including the entity’s registered office, primary business operations, central management or control, and directors or controlling shareholders.

Gherson lawyers can assist with licence applications to UK regulatory authorities and can advise on regulatory compliance.

Updated: 10 July 2025

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