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OFSI frozen asset reporting, due Sunday 30 November 2025

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By Christopher Dyke, Gareth Hall & André Lopes

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Published 01 October 2025

Overview

The Office of Financial Sanctions Implementation (OFSI) has issued confirmation of the annual frozen asset reporting requirements.

Completed reports, confirming frozen assets held which are owned or controlled by a 'designated person' are due on Sunday 30 November 2025.

We set out below a short summary of the reporting obligation, and what OFSI expects to see in completed reports.

 

Who needs to report?

Any person or entity in the UK, or subject to UK jurisdiction, that hold funds or economic resources owned, held, or controlled by a UK designated person must report these funds to OFSI.

 

What must be reported?

Reports must be submitted regardless of sector or regulated status, where such funds are held and reports must include:

  • A description and value of any frozen funds or economic resources held and which are owned or controlled by a UK designated person as of Tuesday 30 September 2025.
  • There is no need to provide a report to OFSI if you do not hold or control funds or economic resources, owned, held, or controlled by a designated person. However, if you submitted a report last year (other than a nil return) and no longer hold those assets, you must submit a nil return report.

Note that accounts blocked solely by other national authorities (e.g. OFAC) do not need to be reported to OFSI.

 

Deadline

Reports must be submitted to OFSI by Sunday 30 November 2025.

Failure to comply with reporting obligations can result in enforcement action, including civil penalties or criminal prosecution. Timely and accurate reporting is essential to demonstrate compliance with UK sanctions regulations.

 

How to report

OFSI encourages use of its online reporting forms.

Reports may also be submitted via email to ofsi@hmtreasury.gov.uk.

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