Hm Treasury
Reporting obligations apply to relevant firms (as defined in the UK regulations and referred to below). Relevant firms are required to inform OFSI as soon as practicable if they know or reasonably suspect a person is a designated person or has committed an offence under financial sanctions regulations.
The obligation to report applies where the information is received by a relevant firm in the course of carrying on their business. Reports are essential to help OFSI detect and address illegal activity.
Information received by OFSI may be disclosed to third parties in accordance with provisions set out in the Information and Records part of the regulations and in compliance with applicable data protection laws. You can reviewOFSIs general guidancefor more information on reporting obligations.
Relevant firms
Definitions of relevant firms can be found in the Information and records part of the statutory instrument for each sanctions regime. Details of regimes under the Sanctions and Anti-Money Laundering Act 2018 can be found on the Foreign, Commonwealth and Development Office web pages.
By way of example, relevant firms that are subject to specific reporting obligations as set out in UK regulations made under the Sanctions Act include:
- a person that has permission under Part 4A of the Financial Services and Markets Act 2000 (FSMA 2000) (Permission to carry on regulated activities)
- an undertaking that by way of business operates a currency exchange office, transmits money (or any representations of monetary value) by any means, or cashes cheques which are made payable to customers
- a firm or sole practitioner that is a statutory auditor or local auditor
- a firm or sole practitioner that provides by way of business accountancy services, legal or notarial services, advice about tax affairs or certain trust or company services
- a firm or sole practitioner that carries out, or whose employees carry out, estate agency work
- the holder of a casino operating licence
- a person engaged in the business of making, supplying, selling (including selling by auction) or exchanging articles made from gold, silver, platinum, palladium or precious stones or pearls.
- a cryptoasset exchange provider
- a custodian wallet provider
Further reporting requirements
In December 2023, the UK government introduced an additional reporting requirement for relevant firms under the Russia (Sanctions) (EU Exit) Regulations 2019.
A relevant firm is required to inform OFSI as soon as practicable if it knows, or has reasonable cause to suspect, that it holds funds or economic resources for a person to whom financial services must not be provided to under regulation 18A(1) (a prohibited person).
A prohibited person means the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, the Ministry of Finance of the Russian Federation, a person owned or controlled directly or indirectly by these entities, or a person acting on behalf of or at the direction of these entities.
To comply with this requirement, please send a completed version of this form, including any associated documents, toofsi@hmtreasury.gov.uk.
How to report to OFSI
The compliance reporting form provides details on what information is required for each section. Please email this form, including any associated documents, to ofsi@hmtreasury.gov.uk. You should include Suspected breach, Suspected designated person or Frozen assets in the subject line of your email, whichever is most applicable.
All reports to OFSI involving a person on one or both of the OFSI lists should include their Group ID reference number. The Group ID is a unique identifier for a person which can be found in their entry on the Consolidated List or List of Persons Subject to Financial and Investment Restrictions.
For more information and guidance on financial sanctions, please visit our guidance page. .
What is a designated person?
A designated person is an individual, entity or ship, listed under UK legislation as being subject to sanctions.
The list of designated persons subject to an asset freeze can be found on OFSIs consolidated list of asset freeze targets.
Financial sanctions also apply to persons which are owned or controlled by a designated person, whether directly or indirectly. They may not be designated in their own right, so their name may not appear on the consolidated list. However, those persons or entities are similarly subject to financial sanctions.
For more information on ownership and control see OFS