On 25 May 2023, the UK Office of Financial Sanctions Implementation (OFSI) published a guidance on how to request variation or revocation of a financial sanction designation under The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 (the Sanctions Act). Designation refers to being identified as a person subject to sanctions under the Sanctions Act.

Key points from the guidance include:

Eligibility for request: If you are a designated person, either you or someone acting on your behalf has the right to request a revocation or variation of your designation.

Submission of request: To request a review, you need to complete a sanctions review request form. The form can be completed by the designated person or someone authorised to act on their behalf. The completed form should be emailed to OFSI@hmtreasury.gov.uk and CounterTerrorism@hmtreasury.gov.uk. If you cannot submit the request by email, you can send it by post to the designated address. The sanctions review request form can be found here.

Required evidence: Along with the completed sanctions review request form, you should provide relevant evidence supporting the request. The evidence should be from reliable sources and preferably verifiable and corroborated. If the evidence is not in English, an official translation with a signed declaration by the translator should be provided.

Review process: Once the request is received, an initial check will be conducted to ensure compliance with the guidance. If the request is complete, the review process will commence, and you will be notified of this. If the request is incomplete, you will be informed of the reasons and may be asked to provide further information. The decision on your application will be made as soon as possible after receiving all necessary information, and you will be notified of the outcome in writing.

Process for designated organisations: Requests from designated organisations or associations are handled similarly to those from individuals. The requester must provide confirmation of their authority to act on behalf of the organisation or association.

Decision timeline: The decision on your application will be made as soon as reasonably practicable after all required information has been received. Exact timelines cannot be provided due to variations in request nature and evidence provided.

Subsequent requests: If a previous request for review has been refused, no further requests can be made unless there is new significant evidence or matter that was not previously considered. In such cases, a new request can be made, indicating the previous refusal and providing details of the significant matter.

Court review: If you disagree with the decision made on your request, you have the option to apply for a court review.

The guidance can be found here.

The sanctions review request form and all the relevant information to this topic can be found here.