Sanctions Changes, Simplified: The Codified Frozen Assets Review

The UK Government has codified the annual "Frozen Assets Review" under its sanctions regimes, through the Sanctions (EU Exit) (Miscellaneous Amendments) (No 2) Regulations 2024 ("Amending Regulations").

This change applies across all UK financial sanctions regimes, including the Russia sanctions regime, and makes it explicitly clear that failure to comply carries criminal penalties.

In this article, we break down the key requirements, penalties, and steps businesses can take to stay compliant ahead of the annual 30 November deadline.

What is the Frozen Assets Review?

The Frozen Assets Review is an annual process managed by the Office of Financial Sanctions Implementation ("OFSI") to help monitor compliance with UK sanctions law and ensure accurate records of frozen assets.