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HMRC SANCTIONS - Stop providing trust services to Russians [FROM 21 March 2023]


The H.M. Government has now introduced a prohibition on providing trust services to any person or entity on the consolidated list of designated persons. Any business providing trust services that may be affected by the amendment should consult the Notice below and seek any necessary assistance.

  1. On 21 March 2023, the Foreign, Commonwealth and Development Office updated the U.K. Sanctions List on GOV.UK.
  2. This list provides details of those designated under regulations made under the Sanctions Act.
  3. X1730 entries on the consolidated list have been amended to reflect the designations regarding trust services sanctions.
  1. check whether you provide any trust services to or for the benefit of designated persons set out in the Annex to this Notice;
  2. cease the provision of any trust service(s) to or for the benefit of designated persons set out in the Annex to the Notice unless licensed by the Office of Financial Sanctions Implementation (OFSI) or an exception applies;
    • check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the Annex to this Notice;
  3. freeze such accounts, and other funds or economic resources which are owned or controlled by persons set out in the Annex to this Notice;
  4. refrain from dealing with the funds or economic resources or making them available (directly or indirectly) to designated persons unless licensed by the OFSI;
  5. report any findings to OFSI, together with any additional information that would facilitate compliance with the Russia Regulations;
    • provide any information concerning designated persons' frozen funds or economic resources that OFSI may request pursuant to its powers under the Russia Regulations. Information reported to OFSI may be passed on to other regulatory authorities or law enforcement.

The Russia (Sanctions) (E.U. Exit) Regulations 2019 (S.I. 2019/855) were made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act) and impose various financial sanctions including the freezing of funds and economic resources and further restrictions on persons (both individuals and entities) who have been designated for their involvement in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, or obtaining a benefit from or supporting the Government of Russia.


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