The Solicitors Regulation Authority (SRA) is urging solicitors to check the HM Treasury frozen assets review to make sure they are not holding monies belonging to a client that is subject to financial sanctions.
HM Treasury has published its annual frozen assets review. Anyone who is holding frozen assets has until Friday 12 October 2018 to submit a report to the Office of Financial Sanctions Implementation (OFSI).
Reports need to be made to the OFSI using this email address: ofsi@hmtreasury.gov.uk
Sanctions are an important foreign policy and national security tool and solicitors should be aware of their ongoing responsibilities. The profession needs to comply with financial sanctions in place in the UK and to report frozen assets and other relevant information to OFSI immediately.
Those wanting more information should check the Infolegal Article “Sanctions Obligations and the AML Regime” whiuch you will find in the Articles section.
The Treasury has provided an example of what the Annual Review involves (see https://bit.ly/2OibXCk) and additional information on financial sanctions can be found in OFSI’s guide
Anyone who submitted a report last year and no longer hold the assets will need to submit a “nil return”.