On August 15, 2024, the Office of Financial Sanctions Implementation updated UK Financial Sanctions Frequently Asked Questions (“FAQs”) concerning sanctions against Russia. Specifically, OFSI provided additional clarity for FAQs 100-119. In FAQ 100, OFSI confirmed that Russian nationals who are UK residents that are not designated under a sanctions regime are not prohibited from opening or maintaining a UK bank account, while OFSI confirmed, in FAQ 102, that UK operators are prohibited from making payments in accordance with a general license that has expired. OFSI also addresses a number of other topics in the FAQs, including the scope of the prohibitions in Regulation 16 and Regulation 17; the right to appeal a civil monetary penalty; and the reporting obligations under regulation 70A(5).
August 16, 2024
OFSI issues updated FAQs to provide additional guidance on sanctions against Russia
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