Prepare for the end of the transition period
There are 10 days to go until the end of the Brexit transition period.
Russia: other financial restrictions
Please be aware the persons subject to restrictive measures in view of Russia’s actions destabilising the situation in Ukraine are listed in Schedule 2 of the Russia (Sanctions) (EU Exit) Regulations 2019. More detail is available in Section 1.2 of the accompanying statutory guidance. The entities listed in Schedule 2 are not subject to an asset freeze and therefore do not appear in the Consolidated List of asset freeze targets in the UK
OFSI will continue to publish the Investment Ban Targets in a separate consolidated list, as it currently does, which will reflect the Schedule 2 listings from 1 January 2021. OFSI has also published specific guidance in respect of these restrictions. This guidance will come into effect at 11pm on 31 December 2020, or when the Russia (Sanctions) (EU Exit) Regulations 2019 come into force.
OFSI Bridging Document
On Friday 18 December, OFSI shared information about the publication of a Bridging Document on 31 December 2020. This has been developed following engagement with stakeholders to assist those who carry out automated screening of the Consolidated List. The Bridging Document will be provided to allow those who wish to do so to screen separately against certain administrative fields to minimise the number of flags on a re-screen of the full Consolidated List.
The Bridging Document is not a substitute for the Consolidated List. Use of the Bridging Document is voluntary. It remains the responsibility of the person doing the sanctions screening to ensure that their screening is accurate.
More information can be found on our website here.
OFSI transition blog
Earlier this month OFSI published a blog post on the changes to the UK’s sanctions framework at the end of the transition period at 11:00pm on 31 December.
This blog explains:
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what you need to know about these changes
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what we have already implemented, and
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what you need to do now
Yes, the same blog post that they’ve announced twice already, but…
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