Syed Rahman summarises the Office of Financial Sanctions Implementation’s latest form of guidance.
The UK’s Office of Financial Sanctions Implementation (OFSI) has published its Frequently Asked Questions (FAQs) as a form of additional sanctions guidance.
OFSI has said that its FAQs have been devised to provide easily accessible responses to common questions about sanctions compliance.
While OFSI does not generally accept individual requests for new FAQs, it looks to publish them when they would benefit a significant portion of industry or the public. It has said it may publish FAQs to support a significant policy change, new general licences, enforcement actions or wider implementation problems. All withdrawn FAQs are listed on the GOV.UK website, along with their withdrawal dates.
OFSI’s FAQs come two years after both the United States and European Union introduced a similar information service. They are, according to OFSI, designed to provide “short-form guidance and technical information on UK sanctions”.
There are currently 91 FAQs, including 44 relating to Russia sanctions.
Topics covered by them include:
- UK entities’ subsidiaries outside of the UK and compliance with sanctions.
- The application of fees and expenses caps in relation to designated persons.
- Designated persons’ shares in UK institutions.
- Transactions, transferable securities and processing of payments.
- Reporting obligations.
- The Russian oil services ban, shipping and insurance.
- General licensing changes.
- Crown dependencies and overseas territories.
All the FAQs can be found here.
