Under the No. 4 Regulations, among other measures, the UK government introduced new reporting measures to enhance the transparency of frozen assets and to further monitor compliance with financial sanctions. These measures, effective in the UK since December 2023, include:

• Immobilised Assets reporting measure: Firms must inform OFSI of any funds or economic resources held for entities like the Central Bank of Russia, the Russian Ministry of Finance, or Russian National Wealth Fund. This provides a clearer picture of these assets, aiding in monitoring and immobilisation efforts.
• Designated Persons asset reporting measure: Individuals designated under the Russia financial sanctions regime must proactively provide details of their UK assets to OFSI. This requirement strengthens compliance efforts and introduces penalties for non-compliance.

OFSI's approach includes robust enforcement tools, and they encourage engagement from businesses and stakeholders to further improve guidance and enforcement policies.

The UK’s Russia sanctions regime is automatically extended, with amendments, to the Overseas Territories under the Russia (Sanctions) (Overseas Territories) Order 2020 (the OT Order). However, the No. 4 Regulations are UK-specific in a number of important matters and as such further amendments must be made to the OT Order to fully implement and give effect to the No. 4 Regulations in the Overseas Territories. The amending measures, which will be cast as an amending Order in Council, are expected imminently from the Privy Council.

OFSI’s blog post can be found here.

Our recent blog post on the UK Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023, can be accessed here.

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023, can be found here.