UK Clarifies When Sanctioned Parties Must Report Changes in Financial Circumstances

The U.K. added a frequently asked question to its Russia sanctions guidance to clarify when certain sanctioned U.K. parties must report to the Office of Financial Sanctions Implementation on changes in their financial circumstances under regulation 70A (5). New FAQ 56 says a party must report to OFSI when "the value of your funds or economic resources, when taken together, has changed" by more than 10,000 pounds ($12,620) since its most recent report to OFSI. Changes also must be reported "if there has been a change to the nature or location of funds or economic resources where those funds or economic resources exceeds" $12,620. This also applies where multiple funds of the same type total more than $12,620.