On 6 September 2021, the Office of Financial Sanctions Implementation (“OFSI“) published its 2021 frozen asset reporting notice (see here). The notice is a reminder that all persons that hold or control funds or economic resources belonging to, owned, held, or controlled by a designated person must provide a report to OFSI with the details of these assets by Friday 15 October 2021. This is part of HM Treasury’s annual review of frozen assets to update its records and to capture any changes during the reporting period.

Any report must include the value of all such assets as at close of business on Thursday 30 September 2021. All returns need to be made in the form of a completed template from the GOV.UK website to ofsi@hmtreasury.gov.uk.

There is no need to provide a nil return to OFSI if you do not hold or control funds or economic resources belonging to, owned, held or controlled by a designated person. However, if you submitted a report last year (other than a nil return) and no longer hold those assets, you should submit a nil return.

Author

Adeel Haque is an Associate in Baker McKenzie's London office. He is a member of the International Commercial & Trade and Antitrust & Competition practice groups. Adeel qualified in September 2019 and has spent time working in the Firm's Hong Kong office.