Financial sanctions update

On 8 January 2021, the Office of Financial Sanctions Implementation (OFSI) HM Treasury issued 3 Financial Sanctions Notices relating toSyria,Russia and Chemical Weapons (the Notices).

Broadly, under the Notices any entity or person must:

1. Check whether they maintain accounts or hold any funds or economic resources for the persons set out in the Annexes to the Notices
2. Freeze such accounts, and other funds or economic resources and any funds which are owned or controlled by persons set out in the Annexes to the Notices
3. Refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the relevant competent authority (ie the Office of the Governor in the case of Anguilla, the British Virgin Islands and the Cayman Islands)
4. Report any findings to the relevant competent authority together with any additional information that would facilitate compliance with the applicable sanctions legislation
5. Provide any information concerning the frozen assets of designated persons that the relevant competent authority may request – note that information reported to the relevant competent authority may be passed on to other regulatory and law enforcement authorities

Where a relevant person has already reported details of accounts, other funds or economic resources held frozen for designated persons, they are not required to report these details again.

It is important to note that failure to comply with the financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

For further information on the financial sanctions updates that were issued by OFSI in 2020, please see here.

OFSI maintains two lists of those persons and entities subject to financial sanctions under United Kingdom legislation as well as United Nations sanctions which are implemented through various regulations.

The OFSI consolidated list of financial targets that are subject to the asset freeze was updated as at 8 January 2021 and can be found here and the consolidated list of financial sanctions targets in the United Kingdom was last updated on 31 December 2020 and can be found here.