OFSI updates general guidance with new HM Treasury debt exception
The Office of Financial Sanctions Implementation (OFSI) has updated its Financial sanctions general guidance to reflect the introduction of the HM Treasury debt exception under the Sanctions (EU Exit) (Treasury Debt) Regulations 2025, SI 2025/712. The exception, set out in Section 6.21 of the guidance, permits certain payments involving designated persons under specific UN sanctions regimes, provided the obligation arose prior to the designation and the funds are credited to specified account types. OFSI has also updated the relevant country-specific guidance for Libya, the Central African Republic, South Sudan, Yemen, and Haiti to reflect the application of this exception and the associated compliance requirements.