Updates to guidance, reporting requirements and correspondent banking relationships
On 21 December 2023, OFSI updated its General, Russia and Enforcement & Monetary Penalties guidance documents to reflect changes to sanctions legislation introduced through the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023, which was laid in Parliament on 14 December. Specifically, the guidance has been updated to reflect the following changes:
- new reporting requirements on relevant firms under Regulation 70 (as amended) of the Russia (Sanctions) (EU Exit) Regulations 2019
- new reporting requirement on designated persons under Regulation 70A of the Russia (Sanctions) (EU Exit) Regulations 2019
- new licensing ground for divestment purposes under the Russia (Sanctions) (EU Exit) Regulations 2019
- amendments to regulations 17A and 59A of the Russia (Sanctions) (EU Exit) Regulations 2019 covering the prohibitions on and exceptions to the processing of payments and correspondent banking relationships
As of 15 December 2023, each of the above changes is now in force except for the new reporting requirements on designated persons which will come into force on 26 December 2023. The guidance documents have also been updated to reflect the clarifications made by the Economic Crime and Corporate Transparency Act 2023 to OFSIs monetary penalty powers under the Policing and Crime Act 2017. Along with these updates, reporting forms are now available on OFSIs GOV.UK page, for the new reporting measures now in place. Following amendments to regulation 17A, a blog has also been issued explaining the new payment processing restrictions.
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