Sanctions legislation update: Annual reporting of frozen assets 02 December 2025
02/12/2025
UK annual frozen asset reporting requirements
1. Under many UK sanctions instruments (including the Russia (Sanctions) (EU Exit) Regulations 2019) given effect in Jersey through the Sanctions and Asset Freezing (Jersey) Law 2019 (“SAFL") and the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the “Sanctions Order"), persons that hold funds or economic resources owned, held, or controlled by a designated person are now required to submit a report by 30 November each year, in respect of any such assets held as of close of business on 30 September of that same year.
Annual reporting requirements in Jersey
2. On 28 November 2025 the Minister for External Relations made the Sanctions and Asset-Freezing (Automatic Implementation of UK Sanctions) (Jersey) Amendment Order 2025 (the “Amendment Order").
3. The Amendment Order modifies the UK requirement, as effective in Jersey, so that reporting is required to be made to the Minister by 31 March each year, in respect of any such assets held as of close of business on 31 December of the previous year. This aligns with the Jersey financial year and other similar reporting requirements.
4. Reporting under this requirement must therefore be made to the Minister by 31 March 2026 on assets held as of 31 December 2025. The FSIU will be publishing guidance, including reporting forms, prior to the start of this reporting period.
5. This requirement is in addition to and does not replace any other reporting obligations of relevant financial institutions under SAFL or the Sanctions Order.
6. The total value of assets reported to the Minister as frozen under the Russia sanctions regime will be published on an annual basis following the introduction of annual frozen asset reporting in Jersey.
7. The Amendment Order comes into force on 05 December 2025.
8. In addition to the above, the Amendment Order also amends the automatic implementation provision of the Sanctions Order. For more information on this, please refer to the automatic implementation of UK sanctions notice on the Jersey Gazette.
Further information
9. Further information on sanctions can be found on Government of Jersey and Jersey Financial Services Commission (JFSC) websites.
10. The UK Sanctions List on GOV.UK.
11. The UK Office of Financial Sanctions Implementation Consolidated List on GOV.UK.
Source:
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.