UK adds new Russia sanctions FAQs on 14 May reporting requirements
18/03/2025
Overview
- The UK has added 13 new Russia sanctions FAQs to explain the effect on new sanctions reporting requirements on high value art dealers, art market participants, insolvency practitioners and letting agencies.
- The guidance explains changes that will come into force on 14 May 2025:-
- The guidance expands the definition of relevant firms subject to sanctions reporting obligations to cover these sectors that was announced in November 2024.
SANCTIONS (EU EXIT) (MISCELLANEOUS AMENDMENTS) (NO.2) REGULATIONS 2024
On November 15, 2024, the UK government introduced significant changes to its sanction’s regulations through the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024
These amendments aim to enhance the UK's financial sanctions framework by expanding the definition of "relevant firms" to include high-value dealers, art market participants, insolvency practitioners, and letting agencies
Key changes include:
- Expanded Reporting Obligations: The new regulations require these additional sectors to report suspected breaches of sanctions regulations
- Annual Reporting: All UK persons holding funds or economic resources owned by designated persons must provide an annual report to the Office of Financial Sanctions Implementation (OFSI)
- Enhanced Enforcement Powers: OFSI's enforcement powers have been strengthened, including new civil monetary penalties for breaches related to Russia land prohibitions
- Clarified Legislation: Amendments clarify existing financial sanctions legislation, making it easier for firms to understand and comply with their obligations
These changes are designed to improve compliance, streamline licensing processes, and provide clearer guidance to affected sectors
THE UK HAS ADDED 13 NEW FAQS TO ITS RUSSIA SANCTIONS GUIDANCE
On May 14, 2025, the UK will implement new sanctions reporting requirements that affect high-value art dealers, art market participants, insolvency practitioners, and letting agencies.
To help these sectors understand the changes, the UK has added 13 new FAQs to its Russia sanctions guidance.
These FAQs cover several key points:
- Expanded Reporting Obligations: The new requirements mandate that these sectors report any suspected breaches of sanctions regulations
- Clarified Definitions: The FAQs provide detailed explanations of terms and conditions relevant to the new reporting obligations
- Compliance Guidance: Practical advice on how to comply with the new regulations, including examples of what constitutes a reportable breach
- Annual Reporting: All UK persons holding funds or economic resources owned by designated persons must submit an annual report to the Office of Financial Sanctions Implementation (OFSI)
- Enforcement and Penalties: Information on the enhanced enforcement powers of OFSI, including new civil monetary penalties for breaches
These changes aim to improve compliance and streamline the reporting process for affected sectors, ensuring that they are better equipped to adhere to the UK's financial sanctions framework
References re May 14, 2025, changes
[1] UK Sanctions: A New Package, Guidance and Legal Clarifications https://www.skadden.com/insights/publications/2025/02/uk-sanctions-a-new-package
[2] UK Financial Sanctions FAQs https://www.gov.uk/government/publications/uk-financial-sanctions-faqs
[3] UK announces largest sanctions package against Russia since 2022 https://www.gov.uk/government/publications/uk-financial-sanctions-faqs
References re November 15, 2024
[1] Changes to sanctions legislation introduced through the Sanctions (EU ... https://ofsi.blog.gov.uk/2024/11/14/changes-to-sanctions-legislation-introduced-through-the-sanctions-eu-exit-miscellaneous-amendments-no-2-regulations-2024/
[2] UK government introduces important changes to UK sanctions framework https://sanctionsnews.bakermckenzie.com/uk-government-introduces-important-changes-to-uk-sanctions-framework/
[3] UK Sanctions: A New Package, Guidance and Legal Clarifications https://www.skadden.com/insights/publications/2025/02/uk-sanctions-a-new-package
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.