Financial sanctions—reporting obligations—post-Brexit
Financial sanctions—reporting obligations—post-Brexit

The following Practice Compliance practice note provides comprehensive and up to date legal information covering:

  • Financial sanctions—reporting obligations—post-Brexit
  • Who must report?
  • How and what to report
  • Suspected designated person
  • Frozen assets
  • OFSI powers to require information
  • Breaches
  • Legal professional privilege
  • Reporting conditions under licences
  • Other UK financial sanctions regimes
  • More...

This Practice Note sets out the circumstances in which you may be required to report on frozen accounts belonging to designated persons under financial sanctions regimes made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). It reflects the position post-Brexit.

A designated person is an individual or entity listed by the United Nations (UN) or HM Treasury as being subject to financial sanctions. The consolidated list of designated persons subject to an asset freeze can be found here.

The international financial sanctions regime is implemented in the UK through SAMLA 2018 and various statutory instruments made under it. See Practice Note: Managing trade and financial sanctions compliance, or for law firms, Understanding the financial sanctions regime post–Brexit—a guide for law firms.

Under certain sanctions regimes made under SAMLA 2018, there is a reporting obligation that applies to firms in certain sectors.

Who must report?

Reporting obligations apply to ‘relevant firms’.

Definitions of relevant firms can be found in the ‘Information and records’ part of the statutory instrument for each sanctions regime, which can be found here. Definitions include, eg:

  1. a person who has permission to carry on regulated activity under the Financial Services and Markets Act 2000

  2. an undertaking that by way of business operates a currency exchange office, transmits money (or any representations of monetary value) by any means, or cashes cheques which are made payable to

Related documents:

Popular documents