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.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

Photo of Sophie Davis Sophie Davis

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.

Sophie also assists companies on compliance with anti-bribery and anti-money laundering laws, foreign direct investment requirements, human rights, environmental and sustainability regulatory requirements. Prior to joining Crowell & Moring, Sophie worked in the international trade and regulatory team in another top international law firm, based in London, as well as for a leading New Zealand law firm.