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This is part of the annual review by the Treasury, through its Office of Financial Sanctions Implementation (OFSI), in order to update its records. It requires reports to be submitted to it of all funds and economic resources held on behalf of clients, who are ‘designated persons’ for the purposes of the legislation. Under the legislation, all funds and economic resources ‘belonging to, owned, held or controlled’ by designated persons, which include individuals, entities or bodies, must be frozen as part of the global action against terrorist financing. The sanctions apply also to persons and entities owned or controlled, directly or indirectly, by a designated person, without them being specified on the list as designated persons.
Consequently, if any client is a designated person or owned or controlled by one, you must provide details to OFSI of the value of all funds and economic resources frozen, whether in the UK or (if subject too UK financial sanctions legislation) overseas, as at close of business on 29 September. You should email your report to email@example.com by 13 October. You are only required to submit a nil return if you submitted a return last year (other than a nil return).
However, there is also an ongoing compliance obligation to check whether you are holding funds or economic resources on behalf of clients listed in the Treasury’s Consolidated List of asset freeze targets and if so, to freeze such funds or economic resources.
For further details about LBS’s services and to discuss the issues mentioned in this article, email Andre Tahmassian-Zarneh (Compliance Consultant) at firstname.lastname@example.org or contact him on 07572 068105.
Failure to comply with the financial sanctions legislation is a criminal offence, which could result in a financial penalty or criminal prosecution.
Client Relationship Manager
T: 0113 385 4483
M: 07432 695 289
The Law Society has issued a practice note about the risks to solicitors posed by this new legislation, which came into force on 30 September.
The SRA has urged all practices to check HM Treasury’s consolidated list of asset freeze targets, which lists designated persons subject to financial sanction under EU or UK legislation.
The practising certificate renewal period opened on Monday 2 October.
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