Context
With under 3 weeks until the end of the Brexit transition period the OFSI has published a blog post on changes to the UK’s sanctions framework at the end of the transition period at 11:00pm on 31st December, which explains what firms need to know about these changes, what has already implemented, and what action firms need to take.
Key points to note
Regulations
- The Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act) provides the legal framework for the UK to impose, update and lift sanctions autonomously.
- While these regulations are intended to deliver substantially the same policy effects as the existing regimes, it should not be assumed that they are identical.
- In many cases the process of recreating the regimes in UK law has necessitated clearer and more specific drafting and therefore the new legislation should be checked to ensure that your activities are still compliant.
- A list of the UK regimes, legislation and guidance already made in preparation for the end of the transition period is available on the Foreign, Commonwealth and Development Office website https://www.gov.uk/guidance/uk-sanctions.
Sanctions lists
- OFSI will continue to maintain its Consolidated Lists of financial sanctions targets on its GOV.UK webpages.
- The lists will be updated with information from FCDO’s UK Sanctions List at 11pm on 31st December 2020
- FCDO will also be updating the UK Sanctions List at the same time.
Compliance
- Firms should continue to use the compliance form on the OFSI website to report any suspected breach of financial sanctions.
- This form will be updated at 11:00pm on 31st December and OFSI will be accepting submissions as usual.
- There is no change to the maximum penalties for breaches of financial sanctions.