UK financial sanctions apply to all persons within the territory and territorial sea of the UK and to all UK persons, wherever they are in the world.
All individuals and legal entities who are within or undertake activities within the UK’s territory must comply with UK financial sanctions that are in force.
All UK nationals and legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force, irrespective of where their activities take place.
Companies should consider the international scope of their activities, assess their own exposure, and put appropriate due diligence measures in place to identify and manage potential risks of breaching financial sanctions.
If you know or have reasonable cause to suspect that you have committed a breach, you must inform OFSI as soon as practicable. OFSI values voluntary disclosure and if done by the person who has committed a breach may be considered a mitigating factor when OFSI assess the case.
Entity X is not listed on OFSI’s Consolidated List. However, your research shows that the majority owner of Entity X is designated Entity Y. As the ownership and control criterion has been met, Entity X is also subject to the same restrictions as designated Entity Y.
Person A (an individual) is not listed on OFSI’s Consolidated List. However, your research shows that Person A is a family member or friend of designated Person B and there is evidence that Person B is using Person A to enter into transactions. As Person B is in control of Person A, Person A is also subject to the same restrictions as designated Person B.