Make sure you check the HMRC Frozen Asset Review List

Wednesday 05 October 2016

HMRC place financial restrictions on individuals who may pose a threat to the UK, are involved in terrorism or part of other regimes.

If you deal with any of the people listed on the HM Treasury's Frozen Asset Review List you must complete and return a reporting form to Office of Financial Sanctions Implementation  (OFSI) by Friday 14 October

These individuals have been targeted under UK, UN, or EU law for financial sanctions, which includes freezing of assets. The individuals may be linked to terrorism or regimes, and capital measures may sometimes be applied to countries such as Russia to combat their activities aimed at undermining the sovereignty and territorial integrity of Ukraine.

  • Financial sanctions are generally imposed in order to:
    Coerce a regime, or individuals within a regime into changing their behaviour or aspects of it (“offending behaviour”), by increasing the cost on them to such an extent that they decide to cease the offending behaviour;

  • Constrain a target by trying to deny them access to key resources needed to continue their offending behaviour, including the financing of terrorism or nuclear proliferation;

  • Signal disapproval of a target as a way of stigmatising and potentially isolating them, or as a way of sending broader political messages to international or domestic constituencies; and/or

  • Protect the value of assets that have been misappropriated from a country, until such point as they can be repatriated.

The lists are regularly updated and someone from your agency - probably your Money Laundering Reporting Officer (MLRO) - should review the list regularly as part of your customer due diligence and tell OFSI if you hold, or control, funds or economic resources belonging to any individuals on it.

If you're not already registered, please sign up to receive email alerts.

Further information can be found in OFSI’s Guide to Financial Sanctions.