OFSI’s latest blog alerts firms to the changes they will see at the end of the transition period. It notes that:
- SAMLA provides the UK’s autonomous legal framework for its sanctions regime
- the FCDO has already laid regulations for over 30 regimes in preparation for the transition
- firms should not assume the new regulation will be absolutely identical to the old
- some regimes have been merged, separated or renamed
- OFSI will update the consolidated list at 11pm on 31 December and warns firms that they may need to screen all designations under SAMLA as they accommodate new information and so various fields will change
- the vast majority of licences issued by OFSI under EU Regulations will remain valid until they expire or are revoked but there are some changes to licensing grounds going forwards
- OFSI will update the form firms should use to report suspected sanctions breaches
- TAFA will be repealed at the end of the transition period and replaced with the Counter-Terrorism (Sanctions)(EU Exit) Regulations 2019 in respect of the domestic regime, and the Counter-Terrorism (International Sanctions)(EU Exit) Regulations 2019 in respect of the international regime
- OFSI has published both general guidance and sectoral guidance on the new Russia regime