Reporting information to OFSI – what to do

The HM Treasury and Office of Financial Sanctions Implementation (OFSI) have published a new version of their UK FINANCIAL SANCTIONS Guidance: Reporting information to OFSI – what to do. This guidance was initially published in 2017 to provide firms with guidance on the reporting to the OFSI as regards suspected (illicit) activities or other actions that mandate such reporting (i.e. transfer from or to an account whose owner is designated). The guidelines thereby describe in detail
(1) how to report to the OFSI and how to report frozen assets; and
(2) who is subject to the reporting obligation.
This latest version contains new forms to be filed by designated persons pursuant to the new reporting obligations in the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 (EventID 24219) which require individuals that have been subjected to an asset freeze in UK to reveal the value and details of any funds or economic resources they possess in the UK or as UK persons. The new forms may be found on the website and are not enclosed above as our clients are unlikely to make use of such.
The latest version also contains a new form (spreadsheet) titled „Immobilised Assets Reporting Document“ which is to be filed by (legal) persons providing asset management or foreign exchange services that hold funds (on behalf) of designated parties. The spreadsheet must be filed by October 31 of each calendar year with an initial report to be provided as soon as „practicable“. The spreadsheet requires information on the „nature and amount or quantity of those funds or economic resources“.
The new guidance also contains corresponding new filing instructions and explanations.