The latest insight on up to date revised sanctions guidance from HM Treasury

HM Treasury in the UK has issued revised sanctions guidance in the last month. The guidance takes the format of frequently asked questions (FAQs) and aims to give more of a steer to those trying to navigate the sanctions minefield. If you haven’t uncovered the new guidance yet, it is well worth a look. The guidance should be a ‘go to’ document for those responsible for sanctions compliance within their business. It is a document that can assist businesses to answer certain common sanctions queries. The guidance will also help businesses to determine whether they need to take matters a step further and gain legal advice.

The following list sets out some of the topics contained in the HM Treasury guidance, that may be useful to local businesses:

  • Can licenced funds be spent on anything?
  • Do financial sanctions apply to subsidiaries of UK companies outside of the UK?
  • How can I tell if a company is owned or controlled by a designated person?

In addition, the FAQs helpfully provide links to guidance issued by other bodies, such as the EU, on subjects such as ‘what amounts to indirect benefit’.

The HM Treasury Financial Sanctions FAQ Guidance (January 2016) can be found at:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/493592/Financial_Sanctions_FAQs__January_2016_.pdf

Advocate Caroline Dutot is a specialist in sanctions matters, having authored the Jersey Financial Services Commission’s guidance on the subject. Advocate Dutot can be contacted by telephone on 01534 481809 or by email on cdutot@ardentchambers.com