News

Trust Services sanctions

09 June 2023

HM Treasury brought the provision of trust services into its financial sanctions regime in December last year.

A number of questions have been raised about this approach since then. So the Office of Financial Sanctions Implementation (OFSI), which is responsible for enforcement of the sanctions regime, has produced a blog to address such issues.

Examples include clarity on the term ‘Persons Connected with Russia’ . OGSI have confirmed this does not include Russian nationals who are not ordinarily resident or located in Russia. The ‘domicile’ test only applies to a person who is not an individual (eg a company).

The General Licence applies to persons designated under the trust services sanctions, it does not apply to trust services provided to or for the benefit of persons connected with Russia.

It includes a reporting obligation to let OFSI know that you are winding down provision of a trust service.

Prior Obligations general licence

OFSI has also issued a new general licence covering prior obligations. Again, a blog explains how the licence works.

The licence took effect from 22 May 2023 and expires on 21 November 2023.

OFSI’s consolidated list provides details of designated persons.