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OFSI updates sanctions FAQs

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.

Emma Radmore