On Nov. 14, UK GVT introduced amendments to sanctions legislation.
UK GVT issued Sanctions (EU exit (miscellaneous amendments) (no.2) regulations 2024 (StIn 2024/1157) which make miscellaneous amendments to various existing sanctions regs, made under Sanctions and anti-money laundering act 2018.
On same day, UK OFSI issued a blog which provided an overview of the amendments.
Follows UK GVT May 2024 issued miscellaneous changes to sanctions, see #212247.
Overview
Measures will improve ability of UK OFSI to implement and enforce financial sanctions.
Amendments will improve OFSI’s intelligence on industry’s compliance with sanctions.
Strengthen OFSI’s enforcement powers, enable OFSI to deal with licensing applications more efficiently, and clarify financial sanctions legislation where there is uncertainty.
Key Changes
Definition of firms subject to sanctions reporting obligations expanded to include high-value dealers, art market participants, insolvency practitioners, letting agencies.
Existing requirements on relevant firms and involved persons to report suspected offenses to a requirement to report suspected breaches of sanctions regulations.
Requirement for UK persons that hold funds or economic resources owned, held, or controlled by a designated person, to provide annual report to OFSI with asset details.
New civil monetary penalty powers for breaches in relation to Russia land prohibitions.
An amendment to certain asset freeze prohibitions to explicitly apply to persons owned or controlled by named DPs; updated definition of designated person in licenses.
A modification to reporting requirements in relation to the assets of prohibited persons listed in regulation 18A of the Russia regulations.
An amendment to the disclosure to the Treasury provisions in most financial sanctions regulations to clarify the scope of UK Treasury’s functions in connection with sanctions.
Regs 18C and 71 of Russia regulations amended to clarify that serving as a nominee shareholder, when involving a trust or similar arrangement, is prohibited trust service.
Amended Regulations
Amendments to Venezuela (sanctions) (EU exit) regulations 2019 (StIn 2019/135); Democratic People’s Republic of Korea (sanctions) (EU exit) regulations 2019 (StIn 2019/411); Democratic Republic of Congo (sanctions) (EU exit) regulations 2019 (StIn 2019/433); South Sudan (sanctions) (EU exit) regulations 2019 (StIn 2019/438).
All changes except for one will come into force on Dec. 5, 2024.
The extension of reporting obligations to high value dealers, art market participants, letting agents and insolvency practitioners will come into force on May, 14, 2025.
