New Financial Sanctions Reporting Requirements

Accountants, tax advisers, estate agents and other businesses need to be aware of the European Union Financial Sanctions (Amendment of Information Provisions) Regulations 2017 ("the Regulations") which came into force on 8th August 2017. These Regulations amend 26 separate UK statutory instruments, each of which is intended to implement and enforce European Council financial sanctions regulations in the fields, for example, of Syria, Zimbabwe or Iran.

The Regulations will require persons operating in the UK in any of eight specified business sectors – collectively referred to as "relevant business[es] or profession[s]" - to inform HM Treasury, "as soon as practicable" if the person "knows or has reasonable cause to suspect" that "a person" either (1) is "a designated person" (which is defined as a "person, entity, or body listed in" annexes to the various sanctions regulations), or (2) "has committed an offence" under specified sanctions prohibitions set forth in