Reporting information to OFSI – what to do
If you hold certain information, you should contact OFSI as soon as practicable.
Reporting obligations apply to relevant firms (as defined in the UK regulations and referred to below). Relevant firms are required to inform OFSI as soon as practicable if they know or reasonably suspect a person is a designated person or has committed an offence under financial sanctions regulations.
The obligation to report applies where the information is received by a relevant firm in the course of carrying on their business. Reports are essential to help OFSI detect and address illegal activity.
Information received by OFSI may be disclosed to third parties in accordance with provisions set out in the Information and Records part of the regulations and in compliance with applicable data protection laws. You can review OFSI’s general guidance for more information on reporting obligations.
Relevant firms
Definitions of relevant firms can be found in the ‘Information and records’ part of the statutory instrument for each sanctions regime. Details of regimes under the Sanctions and Anti-Money Laundering Act 2018 can be found on the Foreign, Commonwealth and Development Office web pages.
By way of example, relevant firms that are subject to specific reporting obligations as set out in UK regulations made under the Sanctions Act include:
- a person that has permission under Part 4A of the Financial Services and Markets Act 2000 (FSMA 2000) (Permission to carry on regulated activities)
- an undertaking that by way of business operates a currency exchange office, transmits money (or any representations of monetary value) by any means, or cashes cheques which are made payable to customers
- a firm or sole practitioner that is a statutory auditor or local auditor
- a firm or sole practitioner that provides by way of business accountancy services, legal or notarial services, advice about tax affairs or certain trust or company services
- a firm or sole practitioner that carries out, or whose employees carry out, estate agency work
- the holder of a casino operating licence
- a person engaged in the business of making, supplying, selling (including selling by auction) or exchanging articles made from gold, silver, platinum, palladium or precious stones or pearls.
- a cryptoasset exchange provider
- a custodian wallet provider
Further reporting requirements
In December 2023, the UK government introduced an additional reporting requirement for relevant firms under the Russia (Sanctions) (EU Exit) Regulations 2019.
A relevant firm is required to inform OFSI as soon as practicable if it knows, or has reasonable cause to suspect, that it holds funds or economic resources for a person to whom financial services must not be provided to under regulation 18A(1) (a “prohibited person”).
A prohibited person means the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, the Ministry of Finance of the Russian Federation, a person owned or controlled directly or indirectly by these entities, or a person acting on behalf of or at the direction of these entities.
To comply with this requirement, please send a completed version of this form, including any associated documents, to ofsi@hmtreasury.gov.uk.
How to report to OFSI
The compliance reporting form provides details on what information is required for each section. Please email this form, including any associated documents, to ofsi@hmtreasury.gov.uk. You should include “Suspected breach”, “Suspected designated person” or “Frozen assets” in the subject line of your email, whichever is most applicable.
All reports to OFSI involving a person on one or both of the OFSI lists should include their ‘Group ID’ reference number. The Group ID is a unique identifier for a person which can be found in their entry on the Consolidated List or List of Persons Subject to Financial and Investment Restrictions.
For more information and guidance on financial sanctions, please visit our guidance page. .
What is a designated person?
A designated person is an individual, entity or ship, listed under UK legislation as being subject to sanctions.
The list of designated persons subject to an asset freeze can be found on OFSI’s consolidated list of asset freeze targets.
Financial sanctions also apply to persons which are owned or controlled by a designated person, whether directly or indirectly. They may not be designated in their own right, so their name may not appear on the consolidated list. However, those persons or entities are similarly subject to financial sanctions.
For more information on ownership and control see OFSI’s general guidance.
Your report should include information by which the designated person can be identified. For example, aliases or alternative identities that could be used to evade sanctions.
Designated Person reporting requirements
If you are a designated person under the Russia (Sanctions) (EU Exit) Regulations 2019, from December 2023 you are required under regulation 70A(1) to disclose any funds or economic resources you own, hold or control to OFSI. Your initial report must be provided within 10 weeks of the relevant date, which is either:
- the date the legislation comes into force - 26 December 2023, or
- the date of your designation if you have been designated after 26 December 2023
You are encouraged to use these forms to comply with this reporting obligation. There is one form for designated persons who are UK persons and a separate form for designated persons who are not UK persons.
The relevant form, OFSI’s Russia regime guidance, and OFSI’s general guidance provide further information about your obligations. A completed version of the relevant form, along with any additional attachments you wish to provide, should be sent to OFSI@hmtreasury.gov.uk. Before submitting the form, please make sure you sign the declaration in Part 5.
How do I report frozen assets?
Financial sanctions legislation requires that all funds or economic resources belonging to, owned, held or controlled by a designated person must be frozen.
Relevant firms must report to OFSI, as soon as practicable, the nature and amount or quantity of any funds or economic resources they hold for a customer who is a designated person.
Under financial sanctions legislation, OFSI can request such information as it may reasonably require and that you may possess, for the purpose of, amongst other things, monitoring compliance with or detecting evasion of the legislation. Every year OFSI carries out a frozen assets reporting exercise that requires persons that hold or control funds or economic resources belonging to, owned, held, or controlled by a designated person, to provide a report with the details of these assets.
On receipt of these reports, OFSI carries out a review to update its records to reflect any changes to these assets during the reporting period.
For more information on the annual review of frozen assets see the Frozen Assets Reporting webpage.
However, if you freeze any assets outside of this review period you must still contact OFSI as soon as practicable, using the compliance reporting form.
What is a breach?
If you do something which is prohibited by financial sanctions you will have breached financial sanctions and may face enforcement action, which could include criminal prosecution or a monetary penalty.
OFSI works with relevant law enforcement agencies and regulators to consider all suspected breach cases that are reported.
Financial sanctions are widely publicised and businesses, particularly those operating internationally, should routinely consider whether sanctions might affect their activities. Organisations are not able to avoid liability simply by failing to consider their sanctions risks.
You should report suspected breaches to OFSI as soon as practicable. Reporting breaches protects the integrity of financial sanctions and assists government and law enforcement agencies in tackling serious crime.
Consequences of breaching financial sanctions
When deciding how to respond to a breach, OFSI and the relevant enforcement agencies and regulators will take several factors into account. For more information on how OFSI assesses breaches of financial sanctions, see the OFSI enforcement and monetary penalty guidance.
Where a breach has occurred, OFSI may decide to issue a warning letter to the involved parties and request evidence of actions taken to improve future compliance. OFSI can also publicise details of financial sanctions breaches.
OFSI may also refer cases to the appropriate regulators and enforcement agencies who may then decide whether to pursue a prosecution or regulatory action. OFSI is also able to impose monetary penalties in cases where serious breaches of financial sanctions occur.
Designated persons asset reporting privacy policy
Our privacy policy for designated persons asset reporting is found in the below attachment.
Last updated 9 January 2024 + show all updates
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Designated persons Asset Reporting Privacy Policy added.
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Added DP Reporting Template (UK Persons), DP Reporting Template (Non-UK Persons) and Immobilised Assets Reporting Document, including details on to whom and how they apply.
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Compliance reporting form updated
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Updated with expanded reporting requirements
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Updated page and compliance reporting form.
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First published.