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UK sanctions updates: wider reporting duties, annual frozen asset returns, new licensing and exceptions, and Russia regime changes (strict-liability penalties and broader trust services)

Published on: 17 December 2024

Published by a LexisNexis Corporate Crime expert
Legal News
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Article summary

Although most of the Amending Regulations took effect on 5 December 2024, some reporting duties for further parts of the economy will not start until May 2025, thereby affording affected market actors (high value dealers, art market participants, letting agents and insolvency practitioners) more than six months to get ready for these adjustments, including putting in place appropriate policies and internal controls where required.

The Office of Financial Sanctions Implementation (OFSI) has already refreshed its general guidance on UK financial sanctions, and its Frequently Asked Questions, to mirror the Amending Regulations, with tailored sector guidance also issued for bodies that will fall within the broadened reporting scope due to take effect next year. Below, we explore in greater depth the changes that are expected to have the broadest practical implications for UK businesses.

Extended reporting obligations

Most significantly, the bar for reporting suspected non-compliance with financial sanctions across all regimes (together with specified maritime / oil-related prohibitions under particular regimes) has moved...

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