Guidance

UK Financial Sanctions FAQs (Withdrawn FAQs)

Updated 31 October 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These FAQs have been withdrawn and do not represent current guidance

The FAQs listed on this page have been withdrawn and are provided for reference only.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, OFSI’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Withdrawn FAQs will be listed here.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 ’as of’ 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Withdrawn on: 3 Jul 2025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

54. Why aren’t other sanctions regimes covered by this General Licence? 

The General Licence has been designed bearing in mind the purpose of the Russia and Belarus regimes and the volume of applications made since the invasion of Ukraine. Specific licence applications for other regimes should continue to be made to OFSI.

Withdrawn on: 24 Oct 2025

76. Where can I find more details on my reporting requirements? 

Reporting forms can be found at the following links: Part A and Part B

Withdrawn on: 24 Oct 2025

7. A Russian resident who is not a designated person and not acting on behalf of a designated person holds accounts at a sanctioned bank that is subject to an asset freeze. Can a UK person accept wire transfers from this Russian resident if made from an account held with this sanctioned bank? 

No. If funds are deposited in a sanctioned bank, a transfer of funds from said bank cannot be accepted by a UK person in the absence of an OFSI licence. This is noting that such a transfer would otherwise constitute dealing with funds owned, held or controlled by a designated person (the sanctioned bank) in contravention of Regulation 11. This is the case irrespective of whether the account holder or the person receiving the funds is designated.

Withdrawn on: 31 Oct 2025

49. What has changed? 

General Licence INT/2024/5334756 resets the fees and expenses caps for Parts A and B for the six-month period from 29 October 2024 until the licence expires on 28 April 2025. In addition, OFSI has made three further amendments to the GL. These are:

• The fee and expenses caps have increased. Under each of Part A and Part B of the General Licence, any professional legal fees and any Counsel’s fees paid in relation to any DP must not exceed £2,000,000.00 (including VAT if applicable) per Law Firm (or per Counsel, if engaged under a direct instruction) instructed in total, for the duration of this licence.

• OFSI has introduced a restricted permission to pay into non-UK bank accounts. Funds being paid into non-UK accounts must still satisfy the other relevant conditions of the General Licence (i.e. be in relation to Legal Services provided to a DP etc). UK Law Firms regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, with branches which provide Legal Services in the countries listed, can receive payment into the branch accounts in these countries:

    *    Canada,

    *     any Member State of the European Union,

    *     any Member State of the European Free Trade Association, or

    *    the United States.

• The position relating to the caps applicable for in-house lawyers and directly instructed Counsel has been clarified. The caps apply to all in-house lawyers employed by a DP as if they were, together, a Law Firm. The caps also apply to directly instructed Counsel, per Counsel.

Withdrawn on: 31 Oct 2025