The UK government has recently introduced changes to sanctions legislation through the <span class="news-text_italic-underline">Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024</span>, laid before Parliament on 14 November 2024. These amendments are designed to enhance the enforcement of financial sanctions, improve compliance monitoring and clarify existing legal uncertainties.
Key updates include the extension of reporting obligations to additional sectors such as high-value dealers, art market participants, insolvency practitioners and letting agents. These sectors will now be required to report suspected breaches of sanctions, with new guidance provided for each sector. Additionally, a new requirement for UK persons holding assets owned or controlled by a designated person (“<span class="news-text_medium">DP</span>”) to provide an annual report to the Office of Financial Sanctions Implementation (“<span class="news-text_medium">OFSI</span>”) has been introduced.
Other notable amendments cover the licencing provisions in sanctions legislation, including the creation of new exceptions for insolvency proceedings and required payments, as well as enhanced civil monetary penalty powers for breaches related to land prohibitions. Changes have also been made to clarify the definition of a DP and the scope of the Treasury’s functions in relation to sanctions.
These changes are set to come into force on 5 December 2024, with some provisions, such as the extension of reporting obligations to certain sectors, becoming effective on 14 May 2025. OFSI has updated its guidance documents to reflect these changes, providing further clarity on upcoming obligations for businesses.
This comprehensive update aims to streamline the implementation of financial sanctions and strengthen OFSI's ability to monitor compliance effectively. For further information on the amendments and additional guidance, please visit the OFSI’s <a href="https://ofsi.blog.gov.uk/2024/11/14/changes-to-sanctions-legislation-introduced-through-the-sanctions-eu-exit-miscellaneous-amendments-no-2-regulations-2024/" target="_blank" class="news-text_link">website</a>.
