PIMFA
Sanctions and Asset Freezing
Financial sanctions are restrictions put in place by the UN or UK to achieve a specific foreign policy or national security objective.
They can:
- limit the provision of certain financial services, and/or
- restrict access to financial markets, funds and economic resources.
Financial sanctions come in many forms. Please see the ‘Sanctions: Types of Financial Sanctions’ infographic below for more information:
UK financial sanctions apply to all persons within the territory of the UK and to all UK persons, wherever they are in the world.
Breaches do not have to fall within the UK to be caught by the legislation, but they do need to have a UK connection.
Firms are required to screen clients against HM Treasury’s sanctions list before providing payments or financial services. Those included on the HM Treasury’s sanction list may be individuals or entities based anywhere in the world, including the UK, that are subject to financial sanctions.
Firms are required to inform the Office of Financial Sanctions Implementation (OFSI) as soon as practicable if they know or reasonably suspect a person is a designated person or has committed offences under financial sanctions regulations, where that information is received in the course of carrying on their business.
A relevant firm that fails to comply with its reporting obligations, as set out in the legislation, will be committing an offence, which may result in a criminal prosecution or a monetary penalty.
Sanctions Lists
- Foreign, Commonwealth & Development Office sanctions list. Contains all individuals, entities and ships designated under the Sanctions and Anti-Money Laundering Act, includes travel bans and transport sanctions
- Office of Financial Sanctions Implementation consolidated list (asset freezes)
- Office of Financial Sanctions Implementation list (persons named in relation to financial and investment restrictions)
