OFSI reminder to report frozen assets

OFSI1The UK’s Office of Financial Sanctions Implementation (OFSI) has issued a reminder that all persons who hold or control funds or economic resources belonging to, owned, held, or controlled by a designated person, must submit a report to OFSI with the details of those assets by Friday 13 October 2017.

The report should include details of all funds or economic resources frozen in the UK at close of business on 29 September 2017, as well as those held overseas where they are subject to UK sanctions.

All completed reports should be emailed to ofsi@hmtreasury.gsi.gov.uk using the template found here. For more information, see the OFSI Notice here.

OFSI Publishes Quick Guide to Financial Sanctions

The UK’s Office of Financial Sanctions Implementation (OFSI) has published a quick guide to assist with the understanding of and compliance with financial sanctions. Among other things, the guide covers:

  • What are financial sanctions and why they exist
  • When and how to comply with financial sanctions
  • Where to find further information and guidance

For the quick guide, click here.

UK proscribes aliases of neo-Nazi group National Action

The UK Parliament has decided to proscribe the organisations Scottish Dawn and NS131 for being aliases of proscribed neo-Nazi group National Action (see previous blog).  As a result, from today being a member of, or inviting support for, those organisations is a criminal office with a sentence of up to 10 years imprisonment.

National Action’s online propaganda material featured material suggesting that violent attacks such as those on the Pulse Nightclub in Orlando and the murder of MP Joe Cox should be emulated.

The Home Office’s press release is here.

Government evidence on sanctions post-Brexit

The House of Lords EU External Affairs Sub-Committee has taken evidence from the UK Government on sanctions post Brexit as part of its inquiry into post Brexit sanctions policy (see previous blog).  It heard evidence from:

The Foreign & Commonwealth Office (Paul Williams, Multilateral Policy Director; Andrew Murdoch, Legal Counsellor; Matthew Findlay, Deputy Head of International Organisations Department), Giles Thomson, Deputy Director, Sanctions and Illicit Finance, HM Treasury, and Rena Lalgie, Head of OFSI. You can watch the evidence session here.

Government says UK & EU will be “stronger acting together” on sanctions & foreign policy post Brexit

department_for_exiting_the_european_union_logoThe Department for Exiting the European Union has published a position paper today (one of a number of its Brexit position papers) entitled ‘Foreign policy, defence and development: a future partnership paper’ in which it “discusses options for foreign policy, defence and development collaboration in the future partnership”.  Link here. Key points in the paper are that:

  1. The UK has been central to EU foreign policy, including as regards sanctions where the UK:
  • “has been the most active Member State in proposing autonomous EU sanctions as a foreign policy tool”;
  • “has also been able to encourage cooperation between the EU and like-minded partners, including the United States, increasing the reach and impact of agreed measures”; and
  • many of the asset freezes applied to terrorist organisations by the EU are based on UK national proscriptions or asset freezes.
  1. “The UK and EU will be stronger acting together.” “Given the shared threats and challenges we face, and the UK’s deep commitment to European values, it is in the interests of both the UK and the EU to continue to work together to meet the challenges of the day, including by “upholding the rules-based international order through aligning sanctions regimes”. “The UK and the EU should remain close partners in foreign policy issues.”
  2. The UK “is establishing its own national legal framework for sanctions” (see previous blog) “but continues to see a strong mutual interest in cooperation and collaboration with European partners.” This could be done through “regular dialogue and specific cooperation. The UK and the EU should have regular close consultations on foreign and security policy issues, with the option to agree joint positions on foreign policy issues. This could include cooperation on sanctions listings, including by sharing information and aligning policy where appropriate.”




UK government requests details of frozen funds

OFSI, part of HM Treasury with responsibility for sanctions enforcement in the UK, has asked that any person or entity that holds or controls funds or economic resources belonging to, held, or owned by a sanctioned person report the details of those assets by 13 October 2017.  This is part of HM Treasury’s annual review of frozen assets. The government’s notice is here.

New UK sanctions reporting requirements now in force

As previously  reported, the UK has expanded the scope of requirements to inform HM Treasury of sanctions breaches (see previous blog), and those new requirements came into force yesterday (8 August 2017).

The European Union Financial Sanctions (Amendment of Information Provisions) Regulations 2017 now apply to “certain businesses and professions” including “independent legal professionals”, law firms, auditors, casionos, dealers in precious metals or stones, tax advisors, trust or company service providers, accountants, estate agents and others, who will commit an offence if they do not inform HMT if they know or have reasonable cause to suspect that a person has committed a sanctions offence or is a person who is the subject of an asset freeze.

The explanatory memorandum is here, and updated guidance at pages 17-21 of OFSI’s guidance document here.