Financial sanctions

Financial sanctions are imposed by the Government and may apply to individuals, entities and governments, who may be resident in the UK or abroad.

Financial sanctions orders prohibit a firm from carrying out transactions with a person or organisation (known as the target). In some cases, the order will prohibit a firm from providing any financial services to the target. 

These measures can vary from the comprehensive – prohibiting the transfer of any funds to a sanctioned country and freezing the assets of a government, the corporate entities and residents of the target country – to targeted asset freezes on individuals/entities.

It is a criminal offence not to comply with a financial sanction unless you have an appropriate licence or authorisation from the Office of Financial Sanctions Implementation[2] (OFSI). Their website contains information about current financial sanctions, including the consolidated list of all those subject to asset freezes or sanctions under UK law.

We are not responsible for enforcing these asset freezes or sanctions, but we do expect your systems and controls to mitigate the risk of financial crime to include those that enable you to meet financial sanctions obligations. These may need to be different from those you might have in place for anti-money laundering purposes, because compliance with sanctions means that you also need to consider to whom payments are being made and whether funds are from an entirely legitimate source.

Notify us if your firm is subject to sanctions 

Under Principle 11, we expect authorised firms and firms operating under the temporary permissions regime (TPR) to notify us[5] if they (or their appointed representatives (ARs) and agents) are subject to sanctions.    

For firms such as electronic money institutions, payment services firms, cryptoasset businesses and annex I financial institutions, this is regarded as a material change of circumstance and we expect to be informed if you or any connected entities are subject to sanctions. 

Dual-regulated firms should also notify the Prudential Regulation Authority (PRA)[6]. 

The sanctions this covers 

Firms should notify us if they, or their ARs and agents, are subject to any sanctions, directly or indirectly. This includes sanctions listed by OFSI and sanctions listed by any other country or jurisdiction.  

A firm could be subject to sanctions in several ways including if: 

• the firm is directly named on a sanctions list 
• the firm is indirectly sanctioned via beneficial ownership/controller/shareholder 
• the firm has directors or employees that are named on a sanctions list 

How to notify the FCA 

Authorised firms should notify us in line with SUP 15 requirements[7] through the usual reporting mechanisms. All firms can notify us via the Contact Centre[8], submitting a SUP 15 notification or by contacting the relevant Supervisor. 

You should provide us with sufficient information, including but not limited to: 

• the country that has imposed the sanction(s) including the relevant sanctions regime 
• when the measures came into force 
• who is affected by the sanction(s)  
• your analysis of how the sanction(s) impact your firm’s activities  

Please also provide any general or specific licences that have been issued by any authority that are relevant.    

We expect firms to notify us without undue delay if they are subject to sanctions.

What to do if you suspect a sanctions breach

For all enquiries about asset freezing or other financial sanctions, or to make a report if you suspect you or a customer of your firm have breached restrictions, contact OFSI by: 

email: [email protected]
post: Office of Financial Sanctions Implementation, HM Treasury, 1 Horse Guards Road, London, SW1A 2HQ​

OFSI also have an email subscription service which you can sign up to and get notified as and when amendments to the financial sanctions regime are made.

If you have information about sanctions evasion or weaknesses in sanction controls, we want you to report it to us. Find out how to report sanctions evasion[9].