On May 1, 2024, the UK’s financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – launched a new Frequently Asked Quesstion service, setting out consolidated responses to frequently asked questions about UK financial sanctions. 

Russia is the key focus, with FAQs dedicated to the UK’s asset freezing sanctions, other financial prohibitions, and the Russian Oil Services Ban (which OFSI is responsible for).  There is also a short section on Libya, information on general licenses, a summary of key definitions (e.g., what would constitute “dealing” with the funds or economic resources of a sanctioned person), and details about how UK sanctions apply in British Crown Dependencies and Overseas Territories. 

The FAQs do not cover trade sanctions, which are currently overseen by the Export Control Joint Unit until the launch of the Office of Trade Sanctions Implementation (“OTSI”) expected sometime this year. 

The FAQs are intended to be supplementary to, and not a replacement for, OFSI’s primary guidance. Indeed, much of the substance of the FAQs is located in other forms of OFSI guidance. 

Nonetheless, by grouping information together in an easily accessible format, OFSI is offering another avenue to assist industry and the public on how to navigate and interpret its often complex sanctions regimes. Crucially, the launch of the FAQs brings the UK in line with the United States and the European Union, which both maintain detailed FAQs about the operation of their Russia sanctions regimes.

OFSI has stated that it will release new FAQs on an as-needed basis. OFSI notes that it will not generally accept individual requests for new FAQs; however, it would look to publish FAQs if they benefit a significant portion of industry or the public. OFSI’s engagement team will work closely with industry and the public to identify specific issues where additional guidance may be of benefit.  

This approach underscores the importance of filtering any questions that companies may have about unclear elements of the UK’s sanctions regime to OFSI through industry groups and other representative bodies, with OFSI now having a clearer means through which to respond to the public in a practical manner. 

Read the press release on OFSI’s website here and the link to the FAQs is here.