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On May 1, 2024, the UK’s financial sanctions regulator
– the Office of Financial Sanctions Implementation
(“OFSI“) – launched a new
Frequently Asked Quesstion service, setting out consolidated
responses to frequently asked questions about UK financial
sanctions.
Russia is the key focus, with FAQs dedicated to the UK’s
asset freezing sanctions, other financial prohibitions, and the
Russian Oil Services Ban (which OFSI is responsible for).
There is also a short section on Libya, information on general
licenses, a summary of key definitions (e.g., what would
constitute “dealing” with the funds or economic resources
of a sanctioned person), and details about how UK sanctions apply
in British Crown Dependencies and Overseas Territories.
The FAQs do not cover trade sanctions, which are currently
overseen by the Export Control Joint Unit until the launch of the
Office of Trade Sanctions Implementation
(“OTSI“) expected sometime this
year.
The FAQs are intended to be supplementary to, and not a
replacement for, OFSI’s primary guidance. Indeed, much of the
substance of the FAQs is located in other forms of OFSI
guidance.
Nonetheless, by grouping information together in an easily
accessible format, OFSI is offering another avenue to assist
industry and the public on how to navigate and interpret its often
complex sanctions regimes. Crucially, the launch of the FAQs brings
the UK in line with the United States and the European Union, which
both maintain detailed FAQs about the operation of their Russia
sanctions regimes.
OFSI has stated that it will release new FAQs on an as-needed
basis. OFSI notes that it will not generally accept individual
requests for new FAQs; however, it would look to publish FAQs if
they benefit a significant portion of industry or the public.
OFSI’s engagement team will work closely with industry and the
public to identify specific issues where additional guidance may be
of benefit.
This approach underscores the importance of filtering any
questions that companies may have about unclear elements of the
UK’s sanctions regime to OFSI through industry groups and other
representative bodies, with OFSI now having a clearer means through
which to respond to the public in a practical manner.
Read the press release on OFSI’s website here
and the link to the FAQs is
here.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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