Change to HM Treasury's policy in relation to receiving funds from an individual or entity subject to EU Sanctions

July 29, 2014

The UK HM Treasury (“HMT”) is changing its policy in relation to funds received in the UK that have come either directly or indirectly from an individual or entity outside of the EU that is subject to EU Sanctions (a “designated party” or a “designated person”).

HMT has previously taken the view that when funds are received by a non-designated person in the UK, from a designated person outside the EU, the funds did not need to be frozen and a licence was not required for their release. However, from midnight on 31 July 2014, any funds arriving in the UK, or in a UK bank anywhere in the world, which have come from, or via, a designated person based outside the EU, will be required to be frozen in a suspense account, or other separate account, on arrival in the UK bank. In order to release those funds to the intended recipient, a licence will be required from HMT.

Even if funds are not coming directly from a designated entity or individual, but did go through a designated entity (including a designated bank) earlier in the payment route, they will need to be frozen and a licence will be required to release the funds.

If HMT refuses to issue a licence the funds would need to remain frozen.

This policy change brings the UK in line with the policies of other EU Member States.

Read "Change to HM Treasury's policy in relation to receiving funds from an individual or entity subject to EU Sanctions".