OFSI has updated its FAQs on financial sanctions. The main newly featured question addresses whether overseas subsidiaries of UK entities are expected to comply with UK sanctions – the answer being that the sanctions apply to UK persons, which technically includes overseas branches but not locally incorporated subsidiaries. However, the guidance also stresses that there must be a connection to the UK – which needs to be considered on a case by case basis but could be -for example – a UK company working overseas or when the UK company is directing the overseas actions of a local subsidiary.
