Urgent Frozen Asset List Checks Required

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 ofsi@hmtreasury.gsi.gov.uk 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  andre.zarneh@lbslegal.co.uk or contact him on 07572 068105.