• FAQ 149: Definition of ‘Economic Resources’
  Economic resources are broadly defined as assets of any kind—tangible or intangible, movable or immovable—that are not funds but can be used to obtain funds, goods, or services. Examples include precious metals, antiques, vehicles, property, crypto assets, transportation tickets, access to telecommunications networks, and services such as consultancy or publicity.
  OFSI reference telecommunications and publicity as past examples to illustrate what can be treated as economic resources. Legal advice is recommended to assess specific cases.
• FAQ 150: Licensing requirements for UK companies and subsidiaries in Crown Dependencies or Overseas Territories (CDs/OTs)
  A UK company must obtain an OFSI licence for transactions subject to UK financial sanctions, even if a subsidiary has been granted a licence by a CD or OT. Licences issued by CDs or OTs do not extend to UK persons or entities outside their jurisdiction. Businesses are advised to seek independent legal counsel to ensure compliance with UK financial sanctions.
• FAQ 151: Licensing requirements for UK persons using CD/OT bank accounts
  UK persons using bank accounts in CDs or OTs for activities permitted under an OFSI licence may also need a licence from the relevant CD or OT authority. This applies if the activity would otherwise breach the sanctions regime in the CD or OT. OFSI highlights that:
  • OFSI licences do not grant permissions under non-UK laws.
  • CDs and OTs have their own sanctions enforcement authorities.
    Legal advice and engagement with the relevant CD/OT authority are strongly recommended.
• FAQ 152: Reporting securities held at designated local Russian registrars
  Institutions should update their next annual Frozen Asset Report (FAR) to reflect changes in the custody of securities held at designated local Russian registrars, provided there is no material change in the value of the frozen assets. Initial reports ‘without delay’ are not required in such cases.

FAQs 123 and 124 have been removed from OFSI’s guidance.

For further clarity or compliance advice, OFSI recommends consulting independent legal professionals.

For more information, OFSI’s FAQs page can be found here and the withdrawn FAQs here.