Guidance

UK Financial Sanctions FAQs (Withdrawn FAQs)

Updated 3 July 2025

These FAQs have been withdrawn and do not represent current guidance

The FAQs listed on this page have been withdrawn and are provided for reference only.

Dates of withdrawal are provided for each FAQ. This list is organised by date of withdrawal.

These FAQs are produced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, the authority for the implementation of financial sanctions in the UK. They should be considered supplementary to, and not a replacement for, OFSI바카라 사이트™s primary guidance.

These FAQs do not represent legal advice

If you are unsure about your obligations in a given case, you should consider seeking independent legal advice.

Withdrawn FAQs will be listed here.

2025

123. In light of the Russian Decree 840, which has moved equities held at the Russian National Settlement Depository (NSD) to local registrars, have OFSI extended the deadline for relevant institutions to report those transferred assets under the Frozen Asset Review 2024?

The 바카라 사이트™as of바카라 사이트™ date for frozen assets reported under the Frozen Assets Review 2024 is 30 September 2024. The Russian decree 840 only came into force on the 2 October 2024, so relevant institutions should have collected the information by the 30 September in preparation for the reporting submission deadline.

To support industry stakeholders, a two-week extension has been granted for the reporting submission date, making the new deadline 25 November.

Withdrawn on: 3 Jul 2025

124. In light of the Russian Decree 840, which has moved equities held at the Russian National Settlement Depository (NSD) to local registrars, are relevant institutions still required to treat the transferred assets as frozen?

Presidential Decree 840 is an attempt by the Russian Federation to evade or avoid sanctions on the NSD by requiring the transfer of certain securities to local Russian registrars.

An asset freeze and some financial services restrictions will apply to entities that are owned or controlled, directly or indirectly, by a designated person. Those entities might not be designated in their own right, so their names might not appear on the Consolidated List. However, those entities are similarly subject to financial sanctions.

OFSI cautions that many of the Russian registrars may be captured by other existing designations. Relevant institutions should continue to consider ownership and control and the risks associated with dealing with these assets. Where local registrars are owned or controlled by other designated persons, relevant institutions must treat the assets as frozen.

Therefore, it is advised that you consult the OFSI consolidated list and conduct your own due diligence.

In the interest of reducing uncertainty, the government is exploring options to further clarify this position.

Withdrawn on: 3 Jul 2025