HM Treasury: Financial Sanctions: Frequently Asked Questions (Faqs)

HM TREASURY
FINANCIAL SANCTIONS:
FREQUENTLY ASKED
QUESTIONS (FAQs)
January 2016
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Contents
1 INTRODUCTION ............................................................................................................................... 8
1.1 A note on publication arrangements ...................................................................................... 9
2 UK Financial Sanctions – a guide for beginners ............................................................................ 10
3 The Sanctions and Illicit Finance Team (SIF) ................................................................................. 11
3.1 Who is responsible for sanctions policy in the UK ................................................................ 11
3.2 Who is responsible for administration of financial sanctions in the UK? ............................. 11
3.3 Who is responsible for trade sanctions in the UK? ............................................................... 11
3.4 What is the role of the Financial Conduct Authority (FCA)? ................................................. 11
3.5 How can I contact HM Treasury about financial sanctions? ................................................. 12
3.6 What is the Treasury’s response time to enquiries? ............................................................ 12
3.7 How do I keep up to date with financial sanctions in the UK? ............................................. 13
4 Financial Sanctions – the basics ................................................................................................... 14
4.1 Why does the UK apply financial sanctions? ........................................................................ 14
4.2 What are financial sanctions? .............................................................................................. 14
4.3 How do I know which financial sanctions are in force in the UK? ........................................ 15
4.4 What about other countries’ financial sanctions that may apply to me? ............................ 15
5 Financial sanctions – asset freezing and other measures ............................................................ 16
5.1 What do financial sanctions measures involve? ................................................................... 16
5.2 What does an asset freeze do? ............................................................................................ 16
5.3 What are funds and economic resources? ........................................................................... 16
5.4 Are frozen funds confiscated by HM Treasury? ................................................................... 16
5.5 Can somebody make funds available to a designated person? ............................................ 17
5.6 Can somebody make financial services available to a designated person? ......................... 17
5.7 Can somebody make economic resources available to a designated person? .................... 18
5.8 Can somebody make funds available for the benefit of a designated person? ................... 18
5.9 Can somebody make financial services available for the benefit of a designated person?. 18
5.10 When is it prohibited to make an economic resource available for the benefit of a
designated person? .......................................................................................................................... 19
5.11 What is a “significant” financial benefit? ............................................................................. 19
5.12 Can licensed funds be spent on anything? ........................................................................... 20
5.13 Where can I find advice on indirectly making funds available to a designated person where
funds are made available to an entity owned or controlled by a designated person? .................... 20
6 How do sanctions affect me? ....................................................................................................... 21
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6.1 How do sanctions affect me if I am a designated person? ................................................... 21
6.2 I have commercial dealings with a designated person ......................................................... 21
6.3 I am a private individual or charity ....................................................................................... 21
6.4 I am a student from a country against which financial sanctions are in force ..................... 22
6.5 What does freezing assets mean for a bank that holds funds? ............................................ 22
6.6 I am a lawyer acting for a designated person. Do I have to freeze their funds in my client
account? ........................................................................................................................................... 22
7 Compliance and the Law .............................................................................................................. 23
7.1 What sanctions law applies in the UK? ................................................................................ 23
7.2 Are United Nations Security Council Resolutions and European Union Regulations directly
applicable in UK law? ....................................................................................................................... 23
7.3 Who must comply with financial sanctions in place in the UK? ........................................... 24
7.4 Do financial sanctions apply to the subsidiaries of UK companies outside the UK? ............ 24
7.5 What reporting requirements exist for ‘relevant institutions’? ........................................... 24
7.6 What powers does HM Treasury have to request information? .......................................... 24
7.7 What onward disclosure is allowed? .................................................................................... 25
7.8 What are the consequences for failure to comply with information requests? .................. 25
7.9 Is it an offence to make funds available to a target of financial sanctions legislation? ....... 25
7.10 Circumvention of sanctions .................................................................................................. 26
7.11 What are the penalties for committing an offence under financial sanctions legislation? . 26
7.12 I have carried out a transaction that is subject to financial sanctions; what should I do? .. 26
7.13 What if I did not know I was breaching a prohibition? ......................................................... 26
8 Sanctions targets – designated persons ....................................................................................... 27

8.1 What is a designated person? .............................................................................................. 27
8.2 Should the assets of other persons who are owned or controlled by a designated person be
frozen? ............................................................................................................................................. 27
8.3 How can I tell if a company is owned or controlled by a designated person? ..................... 27
8.4 What is the Consolidated List of Targets? ............................................................................ 28
8.5 What is the relevance of the “AKA’s” on the Consolidated List? ......................................... 28
8.6 Is HM Treasury’s Consolidated List of targets the same as that published by the European
Union or the United States Treasury’s Office of Foreign Assets Control (OFAC)? ............................ 28
8.7 Where can I find the Consolidated List? ............................................................................... 29
8.8 What formats is the Consolidated List available in? ............................................................ 29
8.9 How do I know what has changed when the Consolidated List is updated? ........................ 29
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8.10 How often is the Consolidated List updated? ....................................................................... 30
8.11 How soon should a business implement changes to the Consolidated List? ....................... 30
8.12 Why can’t I access up-to-date lists or notices? .................................................................... 30
8.13 Does the European Union maintain its own consolidated list of targets? ........................... 30
8.14 Does HM Treasury have a web-based Consolidated List search engine? ............................. 30
9 Challenging a designation decision .............................................................................................. 31
9.1 How do I challenge my listing if I am listed by the UK? ........................................................ 31
9.2 How do I apply to be removed or delisted from the United Nations Al-Qaida and Taliban
list or other UN sanctions listing? ..................................................................................................... 31
9.3 How do I apply to be removed or delisted from an EU sanctions listing? ............................ 31
10 Licences and exemptions ......................................................................................................... 32
10.1 What is an exemption? ......................................................................................................... 32
10.2 What is a licence? ................................................................................................................. 32
10.3 What types of licences are available? .................................................................................. 32
10.4 What activities might a licence cover? ................................................................................. 32
10.5 What is a basic expense of an individual? ............................................................................ 33
10.6 How do I apply for a licence? ............................................................................................... 33
10.7 How long does it take to obtain a Treasury licence? ............................................................ 34
10.8 Do I have to pay HM Treasury for a licence? ........................................................................ 34
10.9 Who can apply for a licence? ............................................................................................... 34
10.10 Where can I find out more about the general licences in force? ..................................... 34
10.11 What should I do with any licence issued to me? ............................................................ 34
10.12 Can I check that a licence is valid? .................................................................................... 34
10.13 When can a licence be changed? ..................................................................................... 35
10.14 What do I do with a licence that concerns a delisted person? ......................................... 35
10.15 What can I do if a licence application is refused? ............................................................ 35
11 Financial sanctions – the regimes ............................................................................................. 36
11.1 How many regimes are in force? .......................................................................................... 36
11.2 Where do I find details of the financial sanctions regimes in force in the UK? .................... 36
12 Sanctions – business policies and procedures .......................................................................... 37
12.1 What policies and procedures do I need to put in place? .................................................... 37
12.2 What software do I need to buy? ......................................................................................... 37
12.3 What should I tell a customer whose account is frozen? ..................................................... 38
12.4 Do I need to make reports to the Treasury? ........................................................................ 38
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12.5 I have policies and procedures in place for anti-money laundering (AML) reasons – are they
relevant or sufficient? ...................................................................................................................... 39
13 Target matches and name matches ......................................................................................... 40
13.1 What is the difference between a name match and a target match? .................................. 40
13.2 What are the reporting requirements for target matches? ................................................. 40
13.3 How often do I need to scan my customer database for possible target matches? ............ 40
13.4 Should an institution always contact HM Treasury if it has found a name match or a
possible target match? ..................................................................................................................... 40
13.5 Can I assume a UK-regulated financial services firm is not a designated person? ............... 41
14 Other advice and guidance ....................................................................................................... 42
14.1 Is any other financial sanctions guidance available? ............................................................ 42
14.1.1 The Financial Conduct Authority .................................................................................. 42
14.1.2 The Joint Money Laundering Steering Group [JMLSG] ................................................. 42
14.1.3 Lloyds Insurance Market .............................................................................................. 42
14.1.4 The Law Society ............................................................................................................ 43
14.1.5 HM Revenue and Customs [HMRC] .............................................................................. 43
14.1.6 The Gambling Commission ........................................................................................... 43
14.1.7 The Royal Institute of Chartered Surveyors ................................................................. 43
15 ANNEX A. Glossary of definitions ............................................................................................. 44
16 ANNEX B. Further Guidance for designated persons under Terrorism / Al Qaida regimes ..... 46
16.1.1 Can I be paid interest on my bank account/savings? ................................................... 46
16.1.2 Can someone pay a cheque, or transfer funds, into my frozen account? .................... 46
16.1.3 Can I take out insurance? ............................................................................................. 46
16.1.4 Can I invest my funds? .................................................................................................. 46
16.1.5 Can I have a debit card? ............................................................................................... 46
16.1.6 Can I have a pre-paid card? .......................................................................................... 47
16.1.7 Can someone give/lend me money? ............................................................................ 47
16.1.8 Can someone give my spouse/partner money? ........................................................... 47
16.1.9 Can someone buy me a drink/meal? ............................................................................ 47
16.1.10 Can I accept a gift? ................................................................................................... 47
16.1.11 Can someone lend me something? .......................................................................... 47
16.1.12 Can I borrow a Pay As You Go Oyster card from a friend? ....................................... 47
16.1.13 Can someone pay my bill? ........................................................................................ 48
16.1.14 Can I take employment? .......................................................................................... 48
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17 ANNEX C: trade sector advice ................................................................................................... 49
17.1 GENERAL COMMERCIAL ISSUES ............................................................................................ 49
17.1.1 Can I make payments to a designated person?............................................................. 49
17.1.2 A designated person owes my business money. Can I write off the debt? ................... 49
17.1.3 A designated person owes my business money. Do I need a licence to pursue the
debt? 49
17.1.4 I’ve got a garnishee Order nisi/absolute against a designated person. Can the Treasury
provide me with details of frozen accounts? ................................................................................ 49
17.1.5 Is a licence required to exercise a right of set off?........................................................ 49
17.1.6 Do financial sanctions mean I cannot trade with persons or entities in countries
subject to financial sanctions? ...................................................................................................... 50
17.1.7 How can sanctions affect my ability to export goods? .................................................. 50
17.1.8 I want to sell humanitarian goods, medicines etc to a country subject to financial
sanctions. Will financial sanctions affect that? ............................................................................. 50
17.2 BANKING ............................................................................................................................... 51
17.2.1 I have a designated person as a customer – what should I do? .................................... 51
17.2.2 Do I need a licence to close a frozen account and transfer any balance to the
customer? ..................................................................................................................................... 51
17.2.3 Can I apply interest to an overdrawn, loan or mortgage frozen account? .................... 51
17.2.4 Are financial institutions expected to know if a credit received for a frozen account
relates to a prior contract? What obligation is there on the bank to investigate the source of
credits to frozen accounts? ........................................................................................................... 51
17.2.5 Can firms lend money or provide credit to a designated person? ................................ 52
17.2.6 Can I apply interest to frozen accounts? ....................................................................... 52
17.2.7 I am a bank. Can I credit funds transferred to the account of a designated person?.. 52
17.2.8 Can I credit funds received from a designated person to their frozen account? ......... 52
17.3 INSURANCE ................................................................................................................................. 53
17.3.1 What is the general effect of sanctions on insurance businesses? ............................... 53
17.3.2 What should an insurer do if an existing customer becomes a designated person after
the inception of cover? ................................................................................................................. 53
17.3.3 What is the position if a policy holder names a designated person as a beneficiary?. 54
17.3.4 As an insurer I may not know the identity of every beneficiary of the cover I provide,
because the business is managed under a delegated authority or bordereau arrangement. What
should I do? ................................................................................................................................... 54
17.3.5 As an insurer, I may only receive partial information from third parties. What should I
do? 54
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17.3.6 I provide pensions or other products to an employer, and may not know who the
relevant employees are. What should I do? ................................................................................. 55
17.3.7 I am a reinsurer. What do sanctions mean for me? ..................................................... 55
17.3.8 I am an insurance agent or broker. What do sanctions mean for me? ........................ 55
17.3.9 The Syrian insurance ban refers to “compulsory or third party insurance”. What does
the term ‘compulsory’ mean in this regard? ................................................................................ 55
17.4 Motor insurance ................................................................................................................... 55
17.4.1 Does a firm providing a complimentary vehicle or temporary hire car in relation to a
motor vehicle insurance policy to a designated person require a licence? ................................. 55
17.5 LEGAL SERVICES .................................................................................................................... 57
17.5.1 We are a firm of solicitors acting for a designated person. Do we need a licence? ... 57
17.5.2 Do solicitors acting for a designated person who is funded by legal aid or by other
third parties require a licence to deal with those funds? ............................................................. 57
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1 INTRODUCTION
These FAQs have been produced to help businesses and others understand both the UN/EU-
mandated “country sanctions” regimes and the domestic terrorism measures that apply in the UK.
These FAQs do not supersede or replace the legal requirements, and do not constitute legal advice.
If you are NOT familiar with UK financial sanctions you will find it helpful to read the summary in
Part 2 as an introduction to the issues.
These FAQs should be read in conjunction with the relevant sanctions specific legislation that applies
in each sanctions regime, and which is available via the list of current sanctions regimes at:
https://www.gov.uk/government/organisations/hm-treasury/series/financial-sanctions-regime-
specific-consolidated-lists-and-releases
These FAQs are structured as follows;
• Part 2 – a guide for beginners provides a high level summary

• Part 3 explains the role of the Sanctions and Illicit Finance team at HM Treasury
• Part 4explains the basic provisions
• Part 5 deals with asset freezing and other measures
• Part 6 asks about sanctions may affect you?
• Part 7 deals with compliance and the law
• Part 8 deals with sanctions targets or designated persons
• Part 9 explains how to challenge a designation decision
• Part 10 deals with licences and exemption
• Part 11 explains about the financial sanctions regimes
• Part 12 discusses the policies and procedures businesses might need
• Part 13 discusses target matches and name matches
• Part 14 deals with advice and guidance from other sources.
In addition, Part 15 includes a short glossary, Part 16 offers further advice specifically for persons
designated under the Terrorism and Al Qaida regimes, and Part 17 includes advice on general
commercial questions and points for the banking, insurance and legal sectors.
These FAQs deal with financial sanctions, such as asset freezing measures. They do not cover other
sanctions measures such as export restrictions or travel bans. Nor do they cover the financial measures
associated with export and import restrictions, such as prohibitions on the provision of financing
or financial assistance connected with prohibited transactions.
COUNTRY SANCTIONS.
“Country sanctions” refers to the various country-specific financial sanctions regimes that apply in
the UK under a UN or EU mandate. These target institutions or people in, or linked to, specific
countries.
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TERRORIST ASSET FREEZING.
The UK operates certain terrorism linked financial sanctions, under UNSCR 1373 (2001) (terrorism)
and UNSCR 1988 (2011) (Al-Qaida). The policy objective of the terrorist asset freezing measures is to
impose those controls that are necessary to protect against terrorist finance risks.
MEANING OF “PERSON” IN THESE FAQ’S.
In these FAQ’s we use the term ‘person’ to refer to a legal or natural persons, that is to say individual
people or entities of any sort.
1.1 A note on publication arrangements

It is our intention to review these FAQs on a six monthly basis, and to publish revised versions where
necessary.
August 2013
Financial Sanctions, HM Treasury
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2 UK Financial Sanctions – a guide for beginners
This is a very high level summary of how financial sanctions work in the UK, and is designed to
serve as a starting point, before users go the main body of these FAQs.
This section provides a brief introduction to UK Financial Sanctions. You should read this section first
if you are not familiar with UK financial sanctions.
Like other advanced economies, the UK operates a range of financial sanctions. These may follow
action at the United Nations, European or domestic (UK) level, because of human rights abuses or
other violations of international norms of behaviour, or to minimise the risk of terrorism within the
UK.
Financial sanctions effect designated person – individuals or entities. Those designated persons
(‘sanctions targets’) are listed in the Consolidated List published on the Gov.UK website.
Financial sanctions invariably include asset freezing measures – these mean that funds are frozen by
the bank or other institutions involved. Unless licensed by the Treasury a designated person can
neither access those funds (ie spend them or pay them away) nor can they be paid or given funds or
economic resources.
In some cases (domestic terrorism designations and dealing with Syria) there are additional
restrictions on providing designated persons with financial services or insurance.
If a person (whether a designated person or not) needs a licence – for example to make or receive a
payment that is blocked by UK financial sanctions - they should write to HM Treasury setting out the
facts. A series of forms is available to help licence applicants provide the necessary information.
Businesses should have policies and procedures to ensure that they comply with their obligations
under sanctions.
Where a business carries out checks it may find that it has a customer with a name (or other details)
identical or similar to those of a designated person. Where this is the case the business needs to
decide as far as possible whether their customer is actually the designated person or not. If the
business decides their customer is a designated person they should freeze the funds (but not send
them to HM Treasury) and report the full facts to HM Treasury using this email address:
financialsanctions@hmtreasury.gsi.gov.uk
If, after examination of all the information they may already have, OR can acquire through additional
enquiries, business remains unsure whether a person is designated they should report all the facts to
HM Treasury.
HM Treasury operates telephone and email enquiry services, but you should study the relevant law
and the full body of theses FAQs before submitting an enquiry.
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3 The Sanctions and Illicit Finance Team (SIF)
3.1 Who is responsible for sanctions policy in the UK

The Foreign and Commonwealth Office (FCO) is responsible for overall policy on international
sanctions including the scope and content of international sanction regimes. There is a general
explanation of sanctions and embargoes here:
https://www.gov.uk/sanctions-embargoes-and-restrictions
3.2 Who is responsible for administration of financial sanctions in the UK?

HM Treasury is the competent authority for the purposes of administering financial sanctions in
force in the UK. This means it administers the UK, EU and UN regimes that require the freezing of
funds and economic resources that belong to or which are owned, held or controlled by persons
who are subject to asset freezes, and also administers restrictions on transfers of funds and on
the provision of certain financial services.
HM Treasury is therefore responsible for:
• the implementation and administration of international (i.e. UN and EU) financial sanctions
in effect in the UK;
• domestic designations under the Terrorist Asset-Freezing etc. Act 2010; and
• licensing exemptions to financial sanctions.
The Treasury produces a range of financial sanctions related material for businesses and others,
including these FAQs. That material is available via the Gov.uk website here:
3.3 Who is responsible for trade sanctions in the UK?

The Department for Business, Innovation and Skills is the UK department responsible for trade
sanctions, such as bans on weapon exports. For an overview of export controls see:
3.4 What is the role of the Financial Conduct Authority (FCA)?

The FCA regulates the financial services industry in the UK. Its aim is to protect consumers, ensure
the industry remains stable and to promote healthy competition between financial services
providers.
The FCA has rule-making, investigative and enforcement powers that are used to protect and
regulate the financial services industry.
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The FCA’s Handbook of Rules and Guidance requires, among other things, that banks establish and
maintain effective systems and controls to prevent the risk that they might be used to further
financial crime, including sanctions violations.
3.5 How can I contact HM Treasury about financial sanctions?

Enquiries concerning financial sanctions should be sent in electronic form to:
financialsanctions@hmtreasury.gsi.gov.uk
Enquiries can be submitted by post to:
Financial Sanctions
Sanctions & Illicit Finance
HM Treasury
1 Horse Guards Road
London SW1A 2HQ
We prefer to receive written enquiries in electronic form (for example as an email or a PDF of a
letter sent in an email), because that is how we manage and record enquiries. It is not necessary to
send a paper copy of a letter sent electronically.
Alternatively, if you have an enquiry about UK financial sanctions, you can call the Treasury Financial
Sanctions helpline on 020 7270 5454. Please note HM Treasury is unable to offer assistance with
complex enquiries over the telephone.
We encourage all of those making enquiries, but especially those most familiar with these regimes
such as lawyers and compliance staff in financial institutions, to considered the relevant legislation
and guidance on the Treasury’s website and form and set out their own view on the issue in their
enquiries.
3.6 What is the Treasury’s response time to enquiries?

HM Treasury aims to respond to general enquiries within two weeks of receipt, prioritising urgent
correspondence as appropriate. However, at times due to large volumes of correspondence it is not
possible to respond within this timeframe.
You are strongly encouraged to look at the Treasury’s website, including this document to see if this
provides the answer to your enquiry before submitting questions to the Treasury.
Please note that whilst the Treasury is willing to assist with enquiries, it does not provide legal advice
and its views are not determinative of questions of law. It is recommended, where necessary, that
independent legal advice is sought.
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3.7 How do I keep up to date with financial sanctions in the UK?
HM Treasury operates a free subscription service which allows subscribers to receive updates
whenever there are changes to financial sanctions effective in the UK.
You can find out how to subscribe at:
https://public.govdelivery.com/accounts/UKHMTREAS/subscriber/new
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4 Financial Sanctions – the basics
4.1 Why does the UK apply financial sanctions?

The UK Government will apply financial sanctions either as part of international or European moves
to bring pressure to bear on target groups or regimes (for example because of measures adopted by
the United Nations) or to meet domestic policy objectives. The UK has an international law obligation
to implement UN sanctions. In practice the EU implements UN regimes by means of a directly
effective EU Regulation which immediately forms part of the UK’s law upon its adoption. The UK
enforces those measures by means of domestic regulations which impose criminal penalties for
breaches of the EU Regulation.
Sanctions are normally used by the international community for one or more of the following
reasons:
• To encourage a change in the behaviour of a target country or regime;
• To apply pressure on a target country or regime to comply with set objectives;
• As an enforcement tool when international peace and security has been threatened and
diplomatic efforts have failed;
• To prevent and suppress the financing of terrorists and terrorist acts.
4.2 What are financial sanctions?

Financial sanctions are normally one element of a package of measures used to achieve one or more
of the above objectives. Current financial sanctions measures typically take the form of targeted
asset freezes on individuals or entities.
Under Chapter VII of the United Nations (UN) Charter, the UN Security Council can take enforcement
measures to maintain or restore international peace and security. Such measures range from financial
sanctions to international military action. Article 41 of the UN Charter allows the Security Council to
decide what measures not involving the use of armed force are to be employed to give effect to its
decisions, and it may call upon the Members of the United Nations to apply such measures. The
range of sanctions can vary from comprehensive financial and trade sanctions to more targeted
measures such as arms embargoes, travel bans, financial or diplomatic restrictions. In the modern
(post-World War 2) era, targeted sanctions are the norm.
In addition, the European Union applies sanctions in pursuit of the specific objectives of the Common
Foreign and Security Policy (CFSP) as set out in the Treaty of the European Union. Sanctions in the
CFSP framework include the interruption or reduction of financial relations with third countries
and restrictions against specific individuals or entities. They also include the interruption or reduction
of diplomatic relations, restrictions on admission and other measures not affecting financial relations
with third countries.
Restrictive measures are applied by the EU either in implementation of sanctions adopted by the UN
Security Council in accordance with Chapter VII of the UN Charter or autonomously within the
framework of the CFSP.
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Finally the UK may apply domestic financial restriction measures. In practice it does this to respond
to certain terrorism threats.
4.3 How do I know which financial sanctions are in force in the UK?
The Treasury publishes material on the gov.uk website about all of the current financial sanctions
regimes that are in force in the UK – see:
Under the individual entries for each country or regime there are details about the regime, crucial
documents such as key UN and EU measures, UK legislation, Treasury notices, and a list of persons
covered by the regime.
You can keep in touch with the main changes to the UK sanctions regime by subscribing to the
Treasury’s Financial Sanctions subscription facility – see paragraph 3.7.
4.4 What about other countries’ financial sanctions that may apply to me?
You may be affected by foreign sanctions, which are sanctions operated by other countries, for
example because of the ownership of your business by a foreign corporation, or because of where or
how you carry on your business.
In addition, the nature of much international trade finance means financial institutions encounter
other financial sanctions regimes.
HM Treasury cannot advise you on compliance with foreign sanctions.
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5 Financial sanctions – asset freezing and other measures
5.1 What do financial sanctions measures involve?

Financial sanctions invariably include an asset freezing regime. Asset freezes comprise two elements:
• A prohibition on dealing with the funds or economic resources belonging to or owned, held
or controlled by a designated person, and
• A prohibition on making funds or economic resources available, directly or indirectly, to, or

for the benefit of, a designated person.
Certain financial sanctions may also involve:
• A prohibitions on providing or performing other financial services (see, for example, the
Terrorism Asset-Freezing etc Act 2010, which prohibits the provision of unlicensed financial
services such as insurance to designated persons ), or
• A prohibition on the provision of insurance or reinsurance to certain Governments or public
bodies, or those acting on their behalf. (See the Syrian regime for details).
5.2 What does an asset freeze do?

An asset freeze prevents anyone “dealing” with funds or economic resources which belong to, or
which are owned, held or controlled by, a designated person.
“Deal with”, in relation to funds, (see the glossary for definition of “funds”), includes to move,
transfer, alter, use, allow access to, or deal with in any way that would result in any change in the
funds’ volume, amount, location, ownership, possession, character, destination, or any other change
that would enable the funds to be used. This also includes the management of securities (shares,
bonds, etc) and other assets.
“Deal with”, in relation to economic resources, (see the glossary for definition of “economic
resources”) means exchange, or use in exchange, for funds, goods or services. It is not prohibited for
a designated person to use the economic resource for normal use within the law (e.g. using their car
to do the shopping) but a designated person could not sell or use the resource to generate funds
(e.g. by selling the car or using it for a taxi or courier business) without a licence from the Treasury
(see Section 10).
5.3 What are funds and economic resources?

We define these more fully in the glossary (see section 15). Funds refers to financial assets and
benefits of every kind, including for example, cash, cheques, money orders and other payment
instruments as well as deposits, securities and other financial assets. Economic resources means
assets of every kind.
5.4 Are frozen funds confiscated by HM Treasury?

Frozen funds are NOT confiscated, sequestered or otherwise held by HM Treasury.
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This means that HM Treasury cannot pay the liabilities of a designated person using frozen funds
(although it may be possible for certain liabilities to be met out of frozen funds, if a licensing ground
is available). A freeze just means the funds must stay where they are and cannot be dealt with unless
under licence.
5.5 Can somebody make funds available to a designated person?

No - it is a criminal offence to knowingly – or with reasonable cause to suspect – make funds
available, directly or indirectly, to a designated person. Making funds indirectly available to a
designated person would involve the funds being routed via a third party. So, for example, it would
be a criminal offence to give funds to a designated person’s friend knowing or suspecting that some
or all of the funds will be given to the designated person. However, the Treasury can issue a licence
exempting certain transactions from the restrictions of the asset freeze. If an appropriate licence has
been issued by the Treasury, then the funds can be made available as set out in that licence.
Gifts, loans, or any other transactions that give designated persons the control of funds will be
prohibited without a licence from the Treasury. Gifts, in this context, can include (but are not
limited to) seasonal gifts and birthday presents to designated persons, where the gift would come
within the definition of “funds” (or, in certain circumstances, an “economic resource” - see below at
5.7). A gift voucher would be classed as “funds” in this context.
If the designated person is owed some money, both parties would need to be included in a Treasury
licence for the debt to be settled. For example, if the designated person is a landlord, both they and
their tenant would need to be covered by a licence for rent payments to be made – the designated
person to receive the funds and to make any payments out that they need to make, and the tenant
to make funds available to the designated person.
5.6 Can somebody make financial services available to a designated person?

Under the Terrorist Asset-Freezing etc Act 2010, there is a prohibition on making financial services
available to a designated person. There are some general licences for certain categories of insurance,
(see https://www.gov.uk/government/publications/counter-financing-of-terrorism-general-licenses ) but it
is otherwise prohibited for anyone to make financial services (e.g. banking, insurance or investment
services) available to a person designated under the Terrorist Asset- Freezing etc. Act 2010 without a
licence.
This restriction on providing financial services is not included in legislation covering people
designated under other regimes. However, other prohibitions may be engaged in the provision of
financial services. For example it is not prohibited to provide banking or insurance services to a
designated person (subject to the prohibitions on insurance or reinsurance under the Syria regime),
but any funds should be frozen by the financial services provider and only released to the designated
individual in accordance with a licence from the Treasury. Similarly, the provision of investment
services will be prohibited under the prohibition on dealing with a designated person’s funds as this
would result in a change in the funds’ volume, amount, location, or character.
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5.7 Can somebody make economic resources available to a designated person?
For a definition of ‘economic resources’, see the GLOSSARY. It is a criminal offence to make
economic resources available, directly or indirectly, to a designated person knowing or suspecting
that the designated person is likely to exchange them for or use them to generate funds, goods or
services. It is not, however, prohibited for someone to make an economic resource available to a
designated person for their everyday ‘non-business’ use, where such use will not result in the
designated person generating funds, goods or services.
For example, these measures would not prevent someone lending or giving a designated person a
bicycle, e.g. for recreation purposes. However, if the person knew or suspected that the designated
person would use it to obtain money (e.g. by finding paid employment as a courier or by selling it),
this would be prohibited. Note that engaging in any conduct which circumvents the prohibitions of
the asset freeze is a criminal offence. Thus if someone gave a designated person a bicycle in good
faith for them to use for their own personal use as transport, rather than to generate income, but
the designated person then sold the bicycle, the designated person would be committing a criminal
offence, even though the person who gave them the bicycle would not be.
5.8 Can somebody make funds available for the benefit of a designated person?
It is a criminal offence for a person to knowingly, or with reasonable cause to suspect they are doing
so, make funds available to a third party in circumstances where a designated person thereby
obtains or is able to obtain a significant financial benefit.
The aim of this prohibition is to prevent designated persons having access to significant additional
funds because third parties make payments which the designated person would otherwise have to
make. It is not intended to prohibit all payments to non-designated third parties which may benefit
a designated person, but only those where there is a “significant financial benefit”. So, for example,
where a person settles a debt owed by a designated person to a third party, that person has allowed
the designated person to receive a financial benefit (as the designated person no longer has to pay
the debt). Whether this benefit is significant or not will depend on the facts of the case, taking
account, for example, of the income and assets of the designated person and the size of the debt
(see 5.11 below).
The definition of “financial benefit” is broad. It includes, for example, the discharge of a financial
obligation (a debt, commitment or liability) for which the designated person is wholly or partly
responsible. A designated person would be likely to obtain a significant financial benefit if a third
party paid the household bills of a designated person, such as rent or mortgage, utility bills, or met
the cost of regular shopping where the designated person would otherwise be meeting or
contributing to these, however there is no set threshold at which a financial benefit is considered
“significant”: it will depend on the facts of each case (see 5.11 below).
5.9 Can somebody make financial services available for the benefit of a
designated person?
Under the Terrorist Asset-Freezing etc Act 2010 (TAFA), there is a prohibition on making financial
services available for the benefit of a designated person. Note, however, that the insurance general
licence allows insurance providers to provide insurance policies to designated person. The licence
can be found here: https://www.gov.uk/government/publications/counter-financing-of-terrorism-general-
licenses
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There are no express restrictions on providing financial services for the benefit of persons
designated under other sanctions regimes, although, as set out in 5.6 above, other restrictions may
well in effect prevent the provision of financial services.
It would be prohibited under the Terrorist Asset-Freezing etc Act 2010 for someone to provide
financial services to a third party for the benefit of a designated person if that designated person
thereby obtains a significant financial benefit. A third party could not, therefore allow a designated
person to make transactions through their bank account: this would be a breach of this prohibition
and an offence of circumventing the asset freeze. It would also be prohibited for a TAFA-designated
person to be a named driver on a car insurance policy without a licence from HM Treasury if he
thereby gains a significant financial benefit, e.g. by not having to take out his own insurance.
5.10 When is it prohibited to make an economic resource available for the benefit
of a designated person?
The prohibition makes it a criminal offence for a person to knowingly, or with reasonable cause to
suspect they are doing so, make economic resources available to a third party in circumstances
where a designated person obtains or is able to obtain a significant financial benefit.
The definition of financial benefit is broad. It includes, for example, the discharge of a financial
obligation (a debt, commitment or liability) for which the designated person is wholly or partly
responsible.
The aim of this prohibition is to prevent designated persons gaining access to additional funds
through the provision of economic resources to others. It is not prohibited for someone to make
economic resources available for the benefit of a designated person unless the designated person
obtains a significant financial benefit. So, for example, if someone lent their car to a member of the
designated person’s family, for the purpose of driving the designated person as a passenger this
would clearly be for the benefit of the designated person. However, this would only be prohibited if
the designated person obtained a significant financial benefit from being so driven, e.g. if the
designated person no longer had to spend significant funds on public transport/taxis. As set out
above, the repayment of a loan or discharge of any other financial obligation on behalf a designated
person comes within the definition of “financial benefit” for this purpose. So if someone gave their
car to a third party in settlement of a debt owed to that third party by a designated person this
would be prohibited (as the designated person would no longer have to pay the debt and therefore
would obtain a significant financial benefit from having the economic resource (the car) made
available to the third party on his behalf).
5.11 What is a “significant” financial benefit?

There is no set threshold at which a financial benefit is considered “significant”. It will depend on the
facts of each case, e.g. the individuals’ assets and income, past history and activities. In this context,
it should be noted that a small amount of money can be significant in terrorist financing terms given
the relatively low cost of terrorist attacks.
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If there is any doubt, HM Treasury’s guidance may be sought although it is ultimately for parties to
satisfy themselves as to whether the benefit should be considered significant.
5.12 Can licensed funds be spent on anything?

Under the Terrorist Asset-Freezing etc. Act 2010, unless otherwise stipulated in the licence, licensed
funds can be used in any lawful way.
Under other UN and EU regimes, there are specific exemptions under which licences can be issued. If
the licence requested does not fall within one of the exemptions, then the licence cannot be issued
by HM Treasury. Before asking HM Treasury to issue a licence under these regimes, you should first
look at the UN Security Council Resolution or EU Regulation under which the designated person is
designated and ascertain whether an exemption applies. All regimes allow for the licensing of
payments to meet the basic expenses of designated persons.
If in doubt, HM Treasury’s advice may be sought.
5.13 Where can I find advice on indirectly making funds available to a designated
person where funds are made available to an entity owned or controlled by a
designated person?
Advice issued by the EU is available at:
http://register.consilium.europa.eu/pdf/en/13/st05/st05993.en13.pdf
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6 How do sanctions affect me?
It is your responsibility to comply with financial sanctions. You may want to seek independent legal
advice if you consider it necessary. Sanctions might affect you if:
• You are involved in any sort of financial business with OR making funds or economic
resources available to or for the benefit of any of the targets of financial sanctions;
• You deal with or have any designated persons as customers, suppliers, bankers, financiers or
investors.
6.1 How do sanctions affect me if I am a designated person?

The effect of financial sanctions on you will depend on the scope of the sanctions measure concerned
and your proposed activity. But generally financial sanctions will restrict your ability to make or
receive payments, carry out investments or conduct any other dealing with your funds or economic
resources.
If you are a designated person you will not (without a licence) be able to deal with money, so you
cannot take money from your bank account unless you have been provided with a licence. Nor can
you use any cash or prepaid, debit or credit cards.
If you are designated under the Terrorist Asset-Freezing etc. Act 2010 (“TAFA 2010”) you should read
part 16. You will only be able to access financial services where the provider is licensed. There is
more about the supply of insurance to designated persons in paragraphs 17.3 and 17.4.
6.2 I have commercial dealings with a designated person.

Financial sanctions will restrict your ability to make payments to or deal with funds of a designated
person without a licence. It will also restrict the designated person’s ability to make payments to you
from funds owned, held or controlled by them, without a licence. See also paragraph 17.1.
It is a matter for the commercial judgement of a bank whether it continues to provide banking
services to businesses dealing with designated persons etc.
6.3 I am a private individual or charity.

Private individuals or charities may find financial sanctions affect certain transactions, such as sending
money or economic resources or assets to a designated person or other persons via a designated
person, or they may have to comply with reporting requirements.
Targeted financial sanctions generally include humanitarian exemptions or licensing grounds

because they do not seek to interrupt humanitarian payments, or effect humanitarian bodies or
agencies, or humanitarian transactions such as the sale or donation of hospital equipment, drugs or
medicines etc. This is because targeted financial sanctions are not designed or intended to worsen
the position of the poor or patients in need of hospital and medical care, drugs and medicines etc.
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HM Treasury will treat applications for humanitarian licences (for humanitarian fund transfers,
payments for drugs and medicines etc) as a priority.
HM Treasury reminds businesses that the clear wish of the international community, specifically
expressed in sanctions measures with humanitarian provisions, is NOT to prevent the passage of
humanitarian funds or goods. Accordingly banks or other financial institutions should feel able to
safely undertake humanitarian transactions if they are sensibly managed.
Other financial sanctions administrators (such as the US Treasury’s Office of Foreign Assets Control,
OFAC) publish their own guidance on humanitarian assistance and related exports.
See also paragraph 17.1.8 about humanitarian transactions.
6.4 I am a student from a country against which financial sanctions are in force.
Students may experience difficulties in receiving funds, including sponsorship, from countries where
financial sanctions are in force for a range of reasons, such as disruption to employers or
government departments that pay support, disruption to their family where they receive support
from that source, shortages of funds, or disruption to access to the international banking system, as
well as interruption to the operation of designated banks. Not all of those problems (for example
shortage of funds, or administrative difficulties) will be as a result of financial sanctions.
Sanctions might affect the ability of commercial sponsors or governments to pay students’
educational or living expenses. HM Treasury will consider licence applications in such cases as a
matter of priority. But remember that a licence only permits payments to be lawfully made; a licence
does not mandate or require that a payment is made.
It is a matter for the commercial judgement of a bank whether it continues to provide banking
services to students who are nationals of countries subject to financial sanctions measures.
6.5 What does freezing assets mean for a bank that holds funds?
In practical terms, accounts or other funds held must be frozen (or blocked). They can only be dealt
with, for example released or paid away by the financial institution (or any other person) that holds
them, under the authority of a licence issued by HM Treasury.
An asset freeze does not affect the ownership of funds.
6.6 I am a lawyer acting for a designated person. Do I have to freeze their funds in
my client account?
Yes, funds held must be frozen (or blocked). They can only be dealt with, for example released or
paid away by you under the authority of a licence issued by HM Treasury.
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7 Compliance and the Law
NOTE: For the details of each specific financial sanctions regime, please refer to the relevant EU
Regulation and the UK’s enforcing regulations. Legislation is available via the regime-specific
publications at:
7.1 What sanctions law applies in the UK?

There is no single over-arching piece of financial sanctions legislation in the UK.
With the exception of the domestic Terrorism and Terrorist Financing regime, which is implemented
by primary domestic legislation, for every individual financial sanctions regime there are two types
of legislative instruments:
(1) an EU Regulation which imposes obligations on UK persons to freeze the assets of designated
persons, refrain from making funds and economic resources available to them and any other
financial prohibitions or restrictions. The EU Regulation will either implement a UN-mandated regime
or an autonomous EU regime; and
(2) a set of UK regulations made under section 2(2) of the European Communities Act 1972, which
enforces the EU Regulation by making it a criminal offence in the UK to breach the EU Regulation’s
measures.
Under the Terrorism and Terrorist Financing regime there is:
(1) an EU Regulation, 2580/2001, which gives effect to UN Security Council Resolution 1373(2001),
and which imposes specific financial sanctions against certain listed targets; and
(2) The Terrorist Asset-Freezing etc. Act 2010 which (a) enforces the asset freezes in respect of the
EU-listed targets and (b) provides HM Treasury with powers unilaterally to freeze the funds and
economic resources of those suspected or believed to be involved in terrorist activities, and
restricts the making available, directly or indirectly, of funds, financial services, and economic
resources to, or for the benefit of such persons.
7.2 Are United Nations Security Council Resolutions and European Union
Regulations directly applicable in UK law?
EU Regulations imposing and/or implementing sanctions are part of Community law and have direct
effect in the Member States. EU Regulations either implement UN sanctions regimes or implement
autonomous EU regimes.
A set of UK Regulations made under section 2(2) of the European Communities Act 1972 is required
to introduce criminal penalties for breaches of the EU Regulation into UK law. The EU Regulation
implements the sanctions and the UK Regulations enforce them.
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United Nations Security Council Resolutions are not directly applicable in UK law. However, under
the United Nations Charter, member states are called upon to give effect to any measures decided
upon by the Security Council. The EU implements the 27 Member States’ UN obligations by adopting
an EU Regulation, which gives effect to the UN measures in UK law. A set of UK Regulations is
required to introduce criminal penalties for breaches of the EU Regulation.
7.3 Who must comply with financial sanctions in place in the UK?
All individuals (irrespective of their nationality) and all legal entities (whether incorporated or
established under UK law or under the law of any other jurisdiction) who are within the UK’s
territory must comply with both EU and UK sanctions regulations that are in force.
Any British national or British legal entity established or incorporated under UK law whose activities
are conducted outside the UK’s territory must also comply with the EU Regulation and the UK
Regulations (or TAFA 2010).
7.4 Do financial sanctions apply to the subsidiaries of UK companies outside the

UK?
The UK Regulations do not apply to subsidiaries operating wholly outside the UK and which are not
British legal entities established or incorporated under UK law.
If the subsidiary is incorporated under EU law, it will remain subject to the EU Regulation.
If it is incorporated under the laws of a non-EU country, is outside the territory of the EU, and does
not do business in the EU, it will not be subject to EU sanctions even though its parent company is.
7.5 What reporting requirements exist for ‘relevant institutions’?

Reporting requirements are covered specifically in the relevant UK ‘country sanctions’ regulations.
The general position is that relevant institutions must inform the Treasury as soon as practicable if it
knows, or has reasonable cause to suspect, that a person (i) is a designated person, or (ii) has
committed an offence under the licensing, contravention or circumvention provisions of the
regulations, and the information or other matter on which the knowledge or suspicion is based came
to it in the course of carrying on its business. (A relevant institution means an FCA authorised
business, or an equivalent EEA firm, or any form of money service business (foreign exchange
bureaux, money transmitter or cheque casher)).
7.6 What powers does HM Treasury have to request information?

Information powers are covered specifically in the relevant UK ‘country sanctions’ regulations.
The general position is that HM Treasury may ask any person in or resident in the UK to furnish any
information he has or controls, or to produce any document in his possession or control, which they
may require for the purpose of ensuring compliance with sanctions law. Any person to whom such a
request is made must comply with it within the required time and in the manner specified, subject
to the obligations of legal professional privilege.
This includes the power to take copies of, or extracts from, any document produced and to request
an explanation of the document.
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There are similar powers under TAFA 2010 and the other terrorism measures.
7.7 What onward disclosure is allowed?

HM Treasury carefully protects all of the confidential, commercially sensitive or personal information
it receives in carrying out its sanctions roles, but it may need to share information with third parties,
for example to satisfy itself that licence requests can be met. It will only do so where data protection
or any other law does not prohibit this.
Information provided to HM Treasury under the exercise of its information powers may only be
further disclosed to other parties in limited circumstances, in accordance with the relevant EU
Regulation. The circumstances where HM Treasury may disclose any information obtained by them
under the relevant UK Regulations or TAFA 2010 are
• to any third party with the consent of the person who, in their own right, is entitled to the
information or to possession of the document, copy or extract;
• to any person who is set out in the Schedule to the relevant UK Regulations, including any
person holding or acting in any office under or in the service of the Crown in respect of the
UK Government;
• for the purpose of giving assistance or co-operation, pursuant to the relevant EU Regulation,
to (in the case of UN-mandated regimes) any organ of the UN or the Council of the European
Union, the European Commission or the Government of a Member State ; or
• with a view to the institution of, or otherwise for the purposes of, any proceedings for an
offence under the relevant UK Regulations or TAFA 2010.
7.8 What are the consequences for failure to comply with information requests?
Any person who:
• without reasonable excuse, refuses or fails within the time and in the manner specified (or, if
no time has been specified, within a reasonable time) to comply with any request made
under the relevant UK Regulations/TAFA 2010;
• intentionally furnishes false information or a false explanation to any person exercising his
powers under the relevant UK Regulations/TAFA 2010; or
• with intent to evade the provisions of the relevant UK Regulations/TAFA 2010, destroys,
mutilates, defaces, secretes or removes any document,
is guilty of an offence.
7.9 Is it an offence to make funds available to a target of financial sanctions

legislation?
This is covered specifically in each relevant Regulation and in the terrorism measures.
In general terms, any person to whom the relevant Regulation applies who, without a valid Treasury
licence, makes any funds, economic resources or, in some circumstances, financial (or related)
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services available directly or indirectly to or for the benefit of persons listed under the relevant law is
guilty of an offence.
7.10 Circumvention of sanctions

Circumventing financial sanctions or enabling or facilitating their contravention is prohibited. Specific
details can be found in each relevant UK Regulation and in the terrorism measures.
7.11 What are the penalties for committing an offence under financial sanctions
legislation?
Any person guilty of an offence under the relevant UK Regulations shall be liable on conviction to
imprisonment and/or a fine. The maximum term of imprisonment is currently two years in EU
regimes (seven years under the Terrorist Asset-Freezing etc. Act 2010).
Where any corporate body is guilty of an offence under the relevant UK Regulations, and that
offence is proved to have been committed with the consent or connivance of, or to be attributable
to any neglect on the part of, any director, manager, secretary or other similar officer of the body
corporate, or any person who was purporting to act in any such capacity, that person as well as the
body corporate is guilty of that offence and is liable to be proceeded against and punished
accordingly.
7.12 I have carried out a transaction that is subject to financial sanctions; what
should I do?
If you find that you have carried out an economic transaction that was prohibited by sanctions (for
example by dealing with a designated person’s funds without a licence), you should contact Financial
Sanctions at HM Treasury.
You might also need to contact your regulator, such as the Financial Conduct Authority (FCA), if you
are separately regulated by them.
You may also wish to take independent legal advice.
7.13 What if I did not know I was breaching a prohibition?

A person does not commit an offence if they did not know and had no reasonable cause to suspect
that the funds, economic resources or financial services were being made available, directly or
indirectly, to or for the benefit of a designated person.
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8 Sanctions targets – designated persons
8.1 What is a designated person?

A designated person, sometimes referred to as ‘a listed person’ or ‘a sanctions target’, is a person
listed in a financial sanctions regime, typically in a UN Security Council Resolution or EU Regulations.
The body that decided that the person or entity should be listed will be the UN Security Council or
the European Council. Only under the terrorism regime does the Treasury have a unilateral power to
list people for asset freezes.
Designated persons are persons whose assets are frozen and to whom it is prohibited to provide
funds or economic resources, or, in certain circumstances, insurance or other financial services.
8.2 Should the assets of other persons who are owned or controlled by a
designated person be frozen?
Generally financial sanctions apply to specifically designated persons.
However, there may be cases where the assets of persons who are not expressly listed as a designated
person may nevertheless have to be treated as frozen. This is because a sanctions regime may target
a list of named persons and other, unnamed, persons that are, for example, owned or controlled
by the named persons. This will be a matter of case-by-case analysis and if in doubt, HM Treasury
should be consulted.
Anyone expressly listed as subject to UK financial sanctions will be listed in our Consolidated List.
See paragraph 8.3 for advice on ownership and control.
8.3 How can I tell if a company is owned or controlled by a designated person?

It can be unclear whether an unlisted person and its assets are owned or controlled by a designated
person. There is no absolute legal rule as to when an entity is owned or controlled by another. The
matter must be subject to a case-by-case evaluation, taking into account the degree to which the
entity concerned is owned or controlled.
When considering whether a company is owned or controlled, it may helpful to bear in mind section
1162 of the Companies Act 2006, under which a company is a “parent undertaking” in relation to a
“subsidiary undertaking” if:
• It holds a majority of the voting rights in it; or
• It is a member (i.e. shareholder) of it and has the right to appoint or remove a

majority of its board; or
• It has the right to exercise dominant influence over it by virtue of provisions

contained in the subsidiary undertaking’s articles of association or a control
contract; or
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• It is a member of it and controls alone, under an agreement with other shareholders
or members, a majority of its voting rights; or
• It has the power to exercise, or actually exercises, a dominant influence or control

over it or both of them are managed on a unified basis.
In addition to the analysis above, advice issued by the EU is available at:

http://register.consilium.europa.eu/content/out?lang=EN&typ=ENTRY&i=SMPL&DOC_ID=ST%20906
8%202013%20INIT
8.4 What is the Consolidated List of Targets?

HM Treasury publishes a Consolidated List of designated persons (i.e. named sanctions targets),
which is available at:
https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets
It is a list of persons (individuals and entities) that have been designated as being subject to financial
sanctions by the United Nations and/or the European Union and/or domestically by the UK under
specific legislation.
Other countries may publish their own lists of financial sanctions targets, but only the Consolidated
Llist published by HM Treasury contains the designated persons that are the subject of financial
sanctions in force in the UK.
The Treasury publishes the list as part of its efforts to facilitate compliance with financial sanctions
measures in the UK. Where there is a legal basis for an asset freeze in the UK, the name of the
target will be included on the Treasury’s Consolidated List. Collectively, the individuals and entities
are called financial sanctions targets and other persons are generally prohibited from engaging in
financial dealings with them.
8.5 What is the relevance of the “AKA’s” on the Consolidated List?

The Consolidated List can include known alternative names – ‘also known as’ or AKA’s. If you are
checking against the Consolidated List you should check against the main or usual name (the prime
alias) AND the AKA’s. The AKA’s represent alternative names.
In some cases HM Treasury may also publish or refer to other nicknames or noms de guerre. These
are intended to assist firms seeking to decide if, for example, a customer is a designated person but
they are not AKA’s in the sense that is explained above.
8.6 Is HM Treasury’s Consolidated List of targets the same as that published by

the European Union or the United States Treasury’s Office of Foreign Assets
Control (OFAC)?
No- these are all different lists.
While there is typically some commonality amongst the lists they are not necessarily the same; nor
should one expect them to be the same as they serve different purposes.
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HM Treasury’s Consolidated List consists of the names of targets that have been listed under United
Nations, European Union and the UK measures which have legal effect in the UK.
Lists provided by non-EU administrations should include names listed under United Nations
sanctions regimes but may not include names listed under European Union imposed sanction regimes
(unless they have been additionally listed in those jurisdictions).
In addition, other lists may include names where domestic sanctions or other measures are in place
in that jurisdiction.
The European Union consolidated list only includes names of individuals and entities that are listed
in annexes to various EU Regulations. This excludes any targets listed independently by the UK under
the TAFA 2010.
8.7 Where can I find the Consolidated List?

The Consolidated List is available at:
https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets
8.8 What formats is the Consolidated List available in?

To assist institutions the Consolidated List of targets is available in the following formats:
• HTML - A basic file format used on the Internet;
• XLS - A file type for documents created using Microsoft EXCEL, a spreadsheet package;
• TXT - An alternative text file to Word;
• CSV - Comma Separated Values, the spreadsheet equivalent of .TXT for word processors; and
• PDF – A widely used document format.
The lists are accessible in all formats via permalinks.
Please refer to the Consolidated List Format Guide for further information. The format guide (which
is being updated) is available at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/205843/fin_sanc_
consolidated_list_format_guide.pdf
Users should remember that these lists are updated from time to time – you should always use the
most up to date version of the list.
8.9 How do I know what has changed when the Consolidated List is updated?
HM Treasury publishes notices on the gov.uk website whenever there are new listings of designated
persons, when designated persons are de-listed, when listings are changed, or when there are other
significant changes to financial sanctions. The Treasury’s usual practice is to publish the details of
persons added or delisted and also to make the changes to individual entries clear.
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8.10 How often is the Consolidated List updated?
There is no predetermined timetable for updating the Consolidated List. Updates are dependent on
when there are changes (i.e. additions, deletions or amendments) to the list of individuals and
entities targeted by the UN, EU and UK.
The Treasury issues an email notification at the same time as the publication of financial sanctions
notices and as the Consolidated List is updated. Details of how to subscribe to the Treasury’s free
subscription service which allows subscribers to receive updates whenever there are changes to
financial sanctions effective in the UK can be found at paragraph 3.7.
8.11 How soon should a business implement changes to the Consolidated List?
Changes to the individuals and entities subject to financial sanctions are usually announced in
notices issued by HM Treasury. The notice will usually explain when the changes are legally effective.
Businesses need to implement such changes (or put new versions of the Consolidated List into
effect) as soon as practical.
8.12 Why can’t I access up-to-date lists or notices?

Frequent or regular users of gov.uk website may inadvertently access out of date versions of the
Consolidated List or may be unable to access new notices. Where that is the case it may be helpful to
refresh your browser to access the most up to date information. Alternatively you may need to
‘clear your cookies’ – that is remove records of previously visited websites that your computer
system may have automatically retained.
8.13 Does the European Union maintain its own consolidated list of targets?
Yes. The European Union has a list of EU sanctions regimes available from its website at:
http://eeas.europa.eu/cfsp/sanctions/docs/measures_en.pdf
The European Union also makes available a list of EU sanctions targets, which is available at:
http://eeas.europa.eu/cfsp/sanctions/consol-list_en.htm
This includes names of persons (individuals and entities) that are listed in annexes to various EU
Regulations. The EU list is not necessarily as up to date, in terms of amendments, as the Treasury’s
Consolidated List.
8.14 Does HM Treasury have a web-based Consolidated List search engine?

No, this type of facility is not currently available. Users of HM Treasury’s website must search the
Consolidated List using either normal search tools or manually. Most Microsoft and Apple programs
have a search function to scan a given file or document for particular text.
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9 Challenging a designation decision
9.1 How do I challenge my listing if I am listed by the UK?

Under section 26 of TAFA 2010 a designated person may appeal to the High Court or, in Scotland,
the Court of Session, any decision of the Treasury to make or vary, or not to vary or revoke, an
interim or final designation, or to renew a final designation.
Under section 27 of the Act a designated person or anyone else affected by a decision of the
Treasury other than decisions to which section 26 applies may apply to the High Court or, in Scotland,
the Court of Session, for the decision to be set aside.
The address for service of legal correspondence for the Treasury is:
The Treasury Solicitor’s Department

One Kemble Street
London, WC2B 4TS.
Phone: 020 7210 3000. DX number: 123242 Kingsway.
9.2 How do I apply to be removed or delisted from the United Nations Al-Qaida
and Taliban list or other UN sanctions listing?
Requests for delisting (where a person is listed by the United Nations) should be sent to the United
Nations focal point for delisting. There is more about the focal point at this address:
http://www.un.org/sc/committees/dfp.shtml
Alternatively a person may petition their state of residence or citizenship. If you wish to petition the
UK, send the petition with the details specified by the UN to
Sanctions Team
International Organisations Department
Foreign and Commonwealth Office
Room E.302
King Charles Street
London, SW1A 2AH
9.3 How do I apply to be removed or delisted from an EU sanctions listing?

You should write in the first instance to the EU at:
relex-sanctions@ec.europa.eu
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10 Licences and exemptions
10.1 What is an exemption?

Some activities which would otherwise amount to a breach of the asset freezing requirements are
automatically exempted under the legislation. For example, funds due to designated persons in
relation to contractual or other obligations entered into prior to the designated persons listing can
be credited to the designated person’s frozen account.
10.2 What is a licence?

A licence is a written authorisation from HM Treasury to allow an activity which would otherwise be
prohibited. A licence may include associated reporting requirements or other conditions.
10.3 What types of licences are available?

Licences allow activity that would otherwise be forbidden to be lawful, so that transactions can be
legally carried out. Generally there are two sorts of licence:
1. General licences. These are available to every potential beneficiary subject to whatever
terms or conditions apply under the sanctions regime concerned; so a general licence allows
every transaction, or category of transaction, that is described in the licence to be lawful,
whoever the persons who are engaging in them. General licences are publicly identified and
are available on the gov.uk web pages.
2. Individual or specific licences. These are granted to specific parties, and may permit specific
transactions or types of spending for example. They are not usually published.
10.4 What activities might a licence cover?

Licences can be granted for a range of purposes. The permitted purposes are typically set out by the
UN or EU, and may include the allowing the release of frozen funds to pay obligations due by the
designated person under a contract entered into prior to their listing, to meet bank charges, to cover
basic household or business expenses and reasonable legal costs. It should be noted that it is not
within the Treasury’s gift to issue a licence for a transaction that is not capable of being authorised
under any of the prescribed licensing grounds in the EU Regulation.
Licences can also allow other arrangements to permit transactions and protect third parties who are
not sanctions targets – for example to allow staff salaries to be paid, to allow humanitarian
transactions, and to allow the assets of designated persons to be safeguarded and managed.
The terms of the relevant EU Regulation typically prescribe the circumstances in which licences can
be issued and the conditions that need to be satisfied in order for HM Treasury to issue a licence.
Treasury will only issue a licence for a transaction which is capable of being authorised under the
prescribed licensing grounds in the relevant legislation. When considering whether to issue a licence,
Treasury will have regard to the policy objectives of the relevant regime.
Treasury licences include the Treasury logo, are numbered, dated and signed ‘Financial Sanctions’.
They are issued electronically in PDF format.
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Treasury licences do not cover activities in other jurisdictions. If you or the activity you are seeking
to have licensed, are subject to more than one sanctions regimes (because of overseas ownership
for example) you may need to apply to the overseas authorities for a separate licence from them.
Treasury licences do not cover trade imports or exports subject to trade sanctions.
10.5 What is a basic expense of an individual?

Where a licence is issued under an exemption for the purpose of meeting basic expenses, “ basic
expenses” are commonly defined as:
“payments for foodstuffs, rent or mortgage, medicines and medical treatment, taxes,
insurance premiums, and public utility charges, or exclusively for payment of reasonable
professional fees and reimbursement of incurred expenses associated with the provision of
legal services, or fees or service charges for routine holding or maintenance of frozen funds
or other financial assets or economic resources” 1
Basic expenses are therefore considered to cover expenditure which is necessary to maintain basic
everyday needs only. In licensing basic expenses the Treasury will consider what is reasonable to
meet the everyday needs of a person in the position of the designated person, taking account of any
specific needs of the individual and their family. However, HM Treasury will not necessarily licence
the full amount requested to allow the designated person to continue to lead a lavish lifestyle,
particularly where this would defeat the purpose of the designation.
10.6 How do I apply for a licence?

Applications for licences must be made in writing, specifying (when appropriate) the relevant licensing
ground in the EU Regulation, and emailed to financialsanctions@hmtreasury.gsi.gov.uk
All applications should ensure that the licence application sets out clearly the grounds on which a
licence is being sought and provide all relevant information, full details of the transaction and
supporting documentation. Please also explain any genuinely urgent circumstances.
1
UNSCR 1452, paragraph 1(a)
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A generic licence application form is available via the following link. This application form should be
used when applying for non-terrorism related licences.
If you seek a licence about a contract between yourself and another party it would be good practice
to liaise with the second party, to ensure that all of the licensing needs of all the parties can be
addressed through one application.
10.7 How long does it take to obtain a Treasury licence?

Licence applications are dealt with as quickly as possible. It is not possible to provide an exact
timeframe as this will depend on the application itself, whether further information is required,
whether liaison with other parties is required and where appropriate that the requisite UN/EU
notification or approval procedures are followed.
The generic licence application form suggests licence applications should be submitted at least four
weeks before the licence is needed. HM Treasury cannot guarantee that licences will be issued
within four weeks of an application being received.
In all cases, the Treasury will aim to keep applicants informed of progress.
10.8 Do I have to pay HM Treasury for a licence?

No. There is no charge made by HM Treasury to issue a financial sanctions licence.
10.9 Who can apply for a licence?

Any person affected by financial sanctions can apply for a licence.
Note that the licence will only allow the transaction to take place where it would be otherwise
prohibited by the sanctions and does not mandate it, so the consent of the owner of the relevant
assets will still be required for the transaction to take place.
10.10 Where can I find out more about the general licences in force?
There is more about general licences, including details of the current general licences, here:
https://www.gov.uk/government/publications/counter-financing-of-terrorism-general-licenses
10.11 What should I do with any licence issued to me?

You should keep any licence granted to you safe. Your bank or other parties to a transaction may ask
to see a copy of the licence. You can pass copies to those parties. However you should consult with
HM Treasury before sharing any licence with parties outside the immediate transaction, such as
foreign governments.
10.12 Can I check that a licence is valid?

Individual licences are not routinely published. HM Treasury will, exceptionally, confirm that a licence
is valid if you have genuine concerns that a licence is not still valid or has been altered.
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10.13 When can a licence be changed?
Licences are issued in the light of the known facts of a particular case. HM Treasury may amend a
licence where the circumstances change or new types of transaction are contemplated. Where a
licence amendment is sought the applicant should make an application setting out the need and the
basis for the change.
10.14 What do I do with a licence that concerns a delisted person?

Where a licence has been issued to allow a business to deal with a designated person and that
designated person is subsequently delisted, the licence is null and void since there is no legal
prohibition under sanctions law that continues to require disapplication by licence. It will
nevertheless be prudent to retain a copy of the licence in case there are enquiries about the basis on
which any transaction took place when sanctions applied.
10.15 What can I do if a licence application is refused?

HM Treasury will usually provide an explanation for any decision to refuse a licence. If you want HM
Treasury to reconsider a decision to refuse a licence you should set out the new facts or analysis you
want HM Treasury to consider.
Where a licence is not granted, the transaction concerned cannot legally proceed.
11 Financial sanctions – the regimes
11.1 How many regimes are in force?

The number of regimes can change from time to time. A full list of the financial sanctions regimes in
force is available here:
11.2 Where do I find details of the financial sanctions regimes in force in the UK?
The gov.uk website lists all the current financial sanctions regimes – see paragraph 11.1.
Each entry on the list of current regimes gives access to full details of that regime, including the
relevant UN and EU decisions, UK legislation, and Treasury information.
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12 Sanctions – business policies and procedures
NOTE; The Financial Services Act 2012 received royal assent at the end of 2012, and came into force
on 1 April 2013. The Act created a new regulatory framework for financial services. It abolished the
Financial Services Authority (FSA). The Act gives the Bank of England responsibility for financial
stability, bringing together macro and micro prudential regulation, creates a new regulatory
structure consisting of the Bank of England's Financial Policy Committee, the Prudential Regulation
Authority and the Financial Conduct Authority (FCA).
The FCA now regulates firms and financial advisers, but a number of publications by the FSA remain
relevant and are referred to below.
12.1 What policies and procedures do I need to put in place?

Generally sanctions regulations do not impose specific policy and procedure requirements. Rather,
sanctions legislation criminalises sanctions violations.
The Financial Conduct Authority (FCA) as part of its objective of enhancing the integrity of the UK
financial system includes a requirement on firms to protect themselves from being misused from
Financial Crime which includes compliance with the UK financial sanctions regime. Other regulators
may also have similar requirements on firms they supervise.
All businesses (including non-financial businesses) may find it helpful to look at “Financial Crime: A
Guide for Firms” produced by the FCA. Section 7 of Part I 2 of this guide gives an overview of the
FCA’s expectations of Financial Services firms along with examples of good and bad practice and
some self-assessment questions. Part 2 of the Guide includes a summary of the 2009 thematic
review into financial services firms’ approach to UK financial sanctions 3.
They have also published a very short guide to financial sanctions for small firms. See:
http://www.fca.org.uk/static/fca/documents/fsa-sanctions2.pdf
There is more about financial sanctions guidance in paragraph 14.1, including links to material
published by the FCA.
12.2 What software do I need to buy?

HM Treasury does not require businesses to buy particular software to fulfil their financial sanctions
commitments.
Businesses may find it cost-effective to buy in specialised software or other services from third
parties where, for example, it considers a significant amount of checking against HM Treasury’s
Consolidated List is called for.
2
http://fshandbook.info/FS/html/handbook/FC/link/PDF
3
http://www.fca.org.uk/your-fca/documents/fsa-sanctions-final-report
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It is always for individual businesses whether to buy specialised software or services, or who to buy
them from.
Businesses may buy information or software from separate sanctions data providers and screening
software providers. Overall, firms should ensure that their combined systems are effective.
If you decide that individual checks using an e-verification provider or purchasing screening software
is appropriate for your business, you should understand its capabilities and limits and make sure that
it is tailored to your business needs and risk profile. Some issues to consider would include:
• Does the search facility you have signed up for include the UK consolidated sanctions list?
Most e-verifiers will have the option to include searches against the UK Consolidated List in
the packages they provide, but some simpler anti-money laundering checks may not
automatically include this option. A check against a list of politically exposed persons (PEPs) is
not the same as a sanctions search.
• How often does the search facility or screening software update the list?
• Does the search facility or screening software provide for fuzzy matching?
Fuzzy matching helps to identify any situations where the designated person’s identifiers are
misspelled, incomplete, or missing. They are often tolerant of multinational and linguistic
differences in spelling, formats for dates of birth, and similar data. Other screening protocols
which may be of use include name reversal and number removal screening. Both the FSA
and the JMLSG 4 have recommended the benefits of using fuzzy matching.
12.3 What should I tell a customer whose account is frozen?

Businesses are not legally required to advise customers that their account has been frozen. The
listing authority will have made efforts to inform the designated person that they have been
designated and what that means for them. The Consolidated List is a public document and there is
no prohibition on discussing a customer’s listing with them (as compared to the prohibitions relating
to ‘tipping off’ under the anti-money laundering regime).
It will generally be good practice to tell the customers involved that they are subject to financial
sanctions such as an asset freeze, and to explain the effect of any restrictions to them, and how to
contact the Financial Sanctions Team at HM Treasury.
When discussing matters with your customer you should still be aware that it is a criminal offence to
circumvent, or enable or facilitate circumvention of sanctions.
12.4 Do I need to make reports to the Treasury?

The detail of reporting requirements will usually be announced in a notification issued by the
Treasury.
Certain businesses are subject to statutory reporting requirements – see paragraph 13.2.
4
See 14.1.2
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If you are not subject to statutory reporting requirements HM Treasury nevertheless welcomes a
report if you become aware that you or your customer is dealing with the funds or assets of a
designated person.
You should provide details of such frozen assets when you make a report.
12.5 I have policies and procedures in place for anti-money laundering (AML)
reasons – are they relevant or sufficient?
While there are some apparent similarities, it is important to remember there are also significant
differences between money laundering and sanctions policy and practice.
Anti-money laundering systems are focused on knowing who your customer is and not receiving or
dealing with funds that are the proceeds of crime. Only certain businesses under the Money
Laundering Regulations 2007 are required by law to have such systems in place.
Compliance with sanctions means that you also need to consider to whom payments are being made
and funds may be from an entirely legitimate source. All UK individuals and businesses must comply
with financial sanctions requirements.
Your anti-money laundering client due diligence systems may help to provide you with full
identification details to assist you with checking your clients against the Consolidated List and
ascertaining whether you have an actual target match or simply a name match – see paragraphs
12.2 and 13.1. Your ongoing monitoring systems for anti-money laundering compliance may assist
you in ascertaining whether your clients become a designated person during the course of your
business relationship.
However, compliance with your anti-money laundering obligations will not of themselves ensure
that you are compliant with your financial sanctions obligations.
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13 Target matches and name matches
13.1 What is the difference between a name match and a target match?
A target match is where you are satisfied that the transaction or account held is that of a specific
person who is a target of financial sanctions.
A name match is where you have matched the name of an account holder with the name of a target
included on HM Treasury's Consolidated List. This does not necessarily mean that the account holder
is one and the same as the target.
If you have a name match you need to decide, using the information you have about the account
holder, whether they are a sanctions target or not. There is more about this below.
13.2 What are the reporting requirements for target matches?

All relevant institutions [see glossary] are required to inform HM Treasury of all funds that they have
frozen in accordance with the relevant legislation and provide all relevant information necessary for
ensuring compliance with the legislation, subject to the obligations of legal professional privilege.
Under existing financial sanctions legislation applicable in the UK, a relevant institution is guilty of an
offence if it knows or has reasonable cause to suspect that a person is a listed person or has
committed an offence under the legislation, and the institution does not disclose the information to
HM Treasury as soon as is reasonably practicable after that information comes to its attention.
13.3 How often do I need to scan my customer database for possible target
matches?
Your internal policy and procedures should determine the frequency of scanning. It is each
individuals' or institutions' responsibility to comply with the relevant legislation. However, if you fail
to identify and block a target account, this may lead to a breach of the legislation.
It should be noted that a critical aspect of the listing of a target is that the target’s assets must be
frozen immediately, before they can be removed from UK jurisdiction.
13.4 Should an institution always contact HM Treasury if it has found a name

match or a possible target match?
You are not obliged to contact HM Treasury about name matches, as name matches are not necessarily
target matches.
Positive target matches should always be reported to HM Treasury. In the event that you identify an
account as that of a target of financial sanctions then the account must be frozen and details
reported to Financial Sanctions.
The more likely scenario is that you may identify a name match with one of the persons included on
the Consolidated List. In such cases, you should conduct your own enquiries assessing your Know
Your Customer or Customer Due Diligence information, customer profile and undertaking appropriate
due diligence to assess against the details available on the listed person.
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You may also find it helpful to access the publicly available information about designated persons on
the United Nations sanctions website at http://www.un.org/sc/committees/list_compend.shtml.
The European Union also publishes a Consolidated List of EU sanctions targets at
http://eeas.europa.eu/cfsp/sanctions/consol-list_en.htm
Both the UN and EU lists may offer helpful additional background in the form of narrative reasons
for the listing of the target concerned.
INTERPOL also publish Special Notices concerning certain designated persons which include
photographs. These are available via this link:
http://www.interpol.int/INTERPOL-expertise/Notices/Special-Notices
If, after assessing all available information, you are unable to determine whether a customer is
indeed a listed person and wish to seek guidance from HM Treasury then you should contact the
Treasury by e-mail to: financialsanctions@hmtreasury.gsi.gov.uk
All relevant information held in respect of the customer would be required i.e. full name, date and
place of birth, occupation, address, family details etc, and copies of any identifying documents
(passports etc) seen when the account was opened or later, together with details of the possible
listed target match (including Group ID number).
13.5 Can I assume a UK-regulated financial services firm is not a designated

person?
No, it is possible that a person regulated by a recognised UK or EU supervisory or regulatory
authority could still be a designated person.
Therefore businesses should be alive to this possibility, and should not rely entirely on their regulated
status in deciding whether sanctions checks are appropriate.
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14 Other advice and guidance
14.1 Is any other financial sanctions guidance available?

A number of third parties have produced guidance for their members or for businesses they monitor
or supervise.
14.1.1 Financial Conduct Authority

The Financial Services Authority produced a range of material – see paragraph 12.1. The Financial
Conduct Authority (FCA) assumed the financial crime prevention role of the FSA in 2013.
The FCA has published in April 2013 its document ‘Financial Crime: A Guide for Firms’. This is in 2
parts;
• Part 1 provides the main guidance and is available here :
http://media.fshandbook.info/Handbook/FC1_20130401.pdf
• Part 2 summarises the lessons identified in earlier thematic reviews, including those
conducted by the FSA. Part 2 is available here:
http://media.fshandbook.info/Handbook/FC2_20130401.pdf
Both parts of the Guide include material on sanctions.
In July 2013 the FCA also published a Thematic Review on ‘Bank’s control of financial crime risks in
trade finance’. Part 3.7 of the Review looks specifically at sanctions issues. The Review is available
here:
http://www.fca.org.uk/news/tr13-03-banks-control-of-financial-crime-risks-in-trade-finance
14.1.2 The Joint Money Laundering Steering Group [JMLSG]

The JMLSG is a group of financial services trade bodies, produces detailed anti-money laundering
guidance, and as part of that it produces specialist guidance on compliance with the UK financial
sanctions regime. See section 4 of Part III of the JMLSG Guidance published in October 2010.
http://www.jmlsg.org.uk/industry-guidance/article/jmlsg-guidance-current
14.1.3 Lloyds Insurance Market

The Lloyds Insurance Market provides advice to market participants on financial sanctions, and that
material can be accessed here:
http://www.lloyds.com/the-market/operating-at-lloyds/regulation/economic-trade-and-financial-
sanctions
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14.1.4 The Law Society
The Law Society provides advice in its anti-money laundering practice note
http://www.lawsociety.org.uk/advice/practice-notes/aml/#1
and in advice articles:
http://www.lawsociety.org.uk/advice/articles/
14.1.5 HM Revenue and Customs [HMRC]

HMRC provides advice on sanctions compliance in its anti-money laundering guidance for High Value
Dealers, Money Services Businesses and Trust and Company Service Providers. You can access that
advice via this link: http://www.hmrc.gov.uk/mlr/your-role/resposibilities.htm#5
14.1.6 The Gambling Commission

The Gambling Commission provides advice in its anti-money laundering guidance for casinos:
http://www.gamblingcommission.gov.uk/gambling_sectors/casinos/operating_licence_holders_-
_wh/key_information_for_the_casino/prevention_of_money_laundering.aspx
14.1.7 The Royal Institute of Chartered Surveyors

The Royal Institute of Chartered Surveyors provides advice in its anti-money laundering guidance for
Surveyors, Property Professionals, Relocation Professionals and Residential Managing Agents:
http://www.rics.org/Global/RICS%20Money%20Laundering%20Guidance%20July%202011.pdf
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15 ANNEX A. Glossary of definitions.
These definitions do not constitute legal advice.
TERM USED Interpretation

DESIGNATED In this context, a designated person is an individual or entity listed by the
PERSON UN/EU or HM Treasury as subject to financial sanctions.
ECONOMIC Economic resources means assets of every kind, whether tangible or
RESOURCES intangible, movable or immovable, (such as goods, property, or rights) which
are not funds themselves but can be used to obtain funds, goods or services.
FUNDS Funds means financial assets and benefits of every kind, including but not
limited to:
• cash, cheques, claims on money, drafts, money orders and other
payment instruments;
• deposits with financial institutions or other entities, balances on
accounts, debts and debt obligations;
• publicly and privately traded securities and debt instruments, including
stocks and shares, certificates representing securities, bonds, notes,
warrants, debentures and derivatives contracts;
• interest, dividends or other income on or value accruing from or
generated by assets;
• credit, right of set-off, guarantees, performance bonds or other
financial commitments;
• letters of credit, bills of lading, bills of sale;
• documents evidencing an interest in funds or financial resources;
• any other instrument of export-financing.
LICENCE A written authorisation provided by the Treasury (or any other competent
authority of a member state) which permits a certain transaction or activity
which would otherwise be a breach of sanctions law.
PERSON A reference to persons means legal and natural persons, that is to say
individuals and any incorporated or unincorporated entity such as a company
or partnership, but also including other businesses and groups like voluntary
bodies (charities etc).
RELEVANT Sanctions regulations define a “relevant institution” as
INSTITUTION
(a) a person who has permission under Part 4 of the 2000 Act* (permission to
carry on regulated activities);
(b) an EEA firm of the kind mentioned in paragraph 5(b) of Schedule 3 to the
2000 Act (EEA passport rights) which has permission under section 15 of that
Schedule as a result of qualifying for authorisation under section 12 of that
Schedule(f) to accept deposits; or
(c) an undertaking which by way of business operates a currency exchange

office, transmits money (or any representations of monetary value) by any
44 | P a g e
means or cashes cheques which are made payable to customers.
* ie the Financial Services and Markets Act 2000.
In practice, this will now mean a Financial Conduct Authority authorised

business, or an equivalent EEA firm, or any form of money service business
(foreign exchange bureaux, money transmitter or cheque casher).
TAFA 2010 The Terrorist Asset Freezing Act etc. 2010.
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16 ANNEX B. Further Guidance for designated persons under Terrorism / Al
Qaida regimes.
This part includes some examples of when the prohibitions are (or are not) engaged for non-
licensed activity.
Note: These additional questions are meant to provide real-world examples of the asset freezing
prohibitions. They should be read alongside the guidance on the prohibitions set out in section 5. In
all examples below, the answer assumes that the designated person does not have a licence for the
activity in question.
16.1.1 Can I be paid interest on my bank account/savings?

Yes. The prohibitions are not contravened by a financial services provider crediting a frozen account
with (a) interest or other earnings due on the account, or (b) payments due under contracts,
agreements or obligations that were concluded or arose before the account was frozen. This is
because of exceptions in the legislation for these specific transactions (see, for example, Terrorist
Asset-Freezing etc. Act 2010, section 16(1)).
A designated person is not permitted to move their account to one paying a higher rate of interest
without a licence from the Treasury.
16.1.2 Can someone pay a cheque, or transfer funds, into my frozen account?
Banks are allowed to credit funds to frozen accounts.
The person giving you the cheque/transferring the funds will, however, be breaching the
prohibitions if they do not have a licence and know or suspect that that they are making funds
available a designated person. You will also need a licence to deal with such funds in any way.
16.1.3 Can I take out insurance?

Yes. There are no restrictions on providing financial services to persons designated under regimes
other than the Terrorist Asset-Freezing etc. Act 2010, for which there is a general licence. However,
any payments by an insurance provider to any designated person will engage the prohibition on
making funds available and funds can only be released to the designated person in accordance with
a licence from the Treasury.
16.1.4 Can I invest my funds?

No. This is prohibited because it would involve dealing with a designated person’s funds (as it would
result in a change in the funds’ volume, amount, location, or character). This would also contravene
the prohibition on the provision of financial services for those designated under TAFA.
16.1.5 Can I have a debit card?

Designated persons are not prohibited from having debit cards. Their use would need to be in
accordance with a Treasury licence. The decision on whether to issue/maintain a debit card for an
individual rests with the bank. For the reasons set out below a designated person could not be
issued with a credit card.
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16.1.6 Can I have a pre-paid card?
Designated persons would need a Treasury licence to pay money onto a pre-paid card and to use the
money on it. It is a criminal offence for anyone else to pay funds onto a designated person’s pre-
paid card without a licence as this is making funds available to them.
16.1.7 Can someone give/lend me money?

No. Without a licence from HM Treasury this would be a breach of the prohibition on making funds
available to a designated person.
16.1.8 Can someone give my spouse/partner money?

There is no prohibition on someone making funds available to the wife of a designated person,
unless the designated person obtains a significant financial benefit from those funds. So someone
could make funds available to a designated person’s spouse or partner unless they know/reasonably
suspect that those funds will be used for the significant financial benefit of a designated person (e.g.
to settle a loan for which the designated person is liable).
16.1.9 Can someone buy me a drink/meal?

There is no prohibition on making economic resources available to a designated person unless that
person is thereby able to obtain a significant financial benefit. In general therefore it would not be
prohibited for someone to buy a meal or a drink for a designated person. Note, however, that the
cumulative effect would need to be considered by the designated person: if one person were to
frequently buy the designated person’s meals or shopping, thereby saving the designated person a
significant amount of money, this could amount to a significant financial benefit and would be
prohibited.
16.1.10 Can I accept a gift?

It is an offence for someone to make funds available to a designated person without a licence. Thus
a designated person cannot accept a gift of cash, vouchers etc. However it is not prohibited to make
economic resources available to a designated person unless the person making them available
knows or suspects the designated person will use or exchange them for funds, goods or services. So
a designated person can accept a non-cash gift if he doesn’t sell it, use it for business, or otherwise
exchange it, or use it in exchange, for funds, goods, or services.
16.1.11 Can someone lend me something?

A designated person cannot be lent funds (e.g. cash, vouchers & other payment instruments).
However, it would not be prohibited for someone to lend a designated person an economic resource
for normal, lawful, non-income use. For example a designated person could borrow a lawn mower
to cut their own grass but not to use it for a gardening business.
16.1.12 Can I borrow a Pay As You Go Oyster card from a friend?

Yes, unless by lending you the Oyster card you get a significant financial benefit. For example it
would not be prohibited to borrow someone’s Oyster card for occasional travel, but it would be
prohibited to use it on a daily basis if this alleviates the designated person form otherwise having to
meet this significant expense.
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16.1.13 Can someone pay my bill?
It is an offence to make funds available for the benefit of a designated person if they obtain a
significant financial benefit. So it would be prohibited for someone to pay a significant bill for a
designated person (e.g. their monthly energy bill if this would otherwise have to be paid by the
designated person) but not, for example, to pay, on one occasion, for the designated person’s
reasonable share of a bill for a meal.
16.1.14 Can I take employment?

There is nothing stopping a designated person from taking up employment. A licence will be required
for the designated person to be paid any wages and may also be required for associated payments
(e.g. pension contributions).
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17 ANNEX C: trade sector advice
The following paragraphs provide more tailored advice for specific industry sectors. The first section
below deals with general commercial issues, such as making payments to a designated person or
being paid by a designated person.
17.1 GENERAL COMMERCIAL ISSUES
17.1.1 Can I make payments to a designated person?

It may be possible to make payments due under contracts, agreements or obligations, which were
concluded or arose prior to the date the person was designated subject to payment being made to a
frozen account. This can take place without a licence because it is automatically exempted by the
legislation.
Before making such payments you should take steps to establish the facts, and in particular that the
account is frozen as required by the sanctions legislation, in the first instance by seeking
confirmation from the account holding institution. All other payments to a designated person
require a licence.
17.1.2 A designated person owes my business money. Can I write off the debt?
Should you wish to cancel or ‘write off’ the debt obligations e.g. credit card balances, overdrawn
accounts, mortgage or loan accounts, of designated persons you should submit a licence request to
HM Treasury setting out full details of the loan in question, including the outstanding balance and
what action, if any, you have taken to recover monies.
This requirement arises because writing off a debt owed by a designated person may constitute
allowing them to obtain a significant financial benefit, which sanctions prohibit.
17.1.3 A designated person owes my business money. Do I need a licence to pursue the debt?
Pursuing debts owed by designated persons is not prohibited. A licence is not required to appoint a
receiver or to transfer the administration activities related to pursuing a debt for example.
However, a licence will be required for the eventual payment of the debt out of frozen funds and
possibly other related activities e.g. appointing receivers, collecting rental payments or legal costs
and other charges properly due from such funds during the course of recovery.
17.1.4 I’ve got a garnishee Order nisi/absolute against a designated person. Can the Treasury
provide me with details of frozen accounts?
No. However, HM Treasury will consider an application for a licence to release funds from an
identified frozen account.
17.1.5 Is a licence required to exercise a right of set off?

Yes, in all likelihood. A right of set off ensures that the claims that two parties have against each
other are satisfied, provide that payment of such claims is due. The exercise of that right, therefore,
involves at least two claims between the same parties each of whom owes an amount to the other
under separate contract. The set-off reduces one party’s debt by deducting from the amount owed
to that party by the other party and so could amount to the provision of a significant financial
benefit to the listed party.
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17.1.6 Do financial sanctions mean I cannot trade with persons or entities in countries subject to
financial sanctions?
Financial sanctions do not impose general trade bans or restrictions on exporting to, or importing
from, persons or entities in countries subject to financial sanctions. However, financial sanctions will
impact if you are seeking to trade with a designated person or if the payment relating to trade is
routed through a designated bank.
Separately, the adoption of targeted financial sanctions against specific individuals or entities in a
country may also heighten sensitivities about dealing with the country concerned and that may
make it more difficult to make payments to or receive payments from that country.
Exporters may experience other difficulties, for example in getting paid despite holding a licence.
That may be due to importers facing shortages of funds, or exchange control or other restrictions in
their jurisdiction. Those are outside the control of HM Treasury.
Financial sanctions may, in practice, also be accompanied by other restrictions, such as trade sanction.
There is more about other trade sanctions at: https://www.gov.uk/sanctions-embargoes- and-
restrictions
17.1.7 How can sanctions affect my ability to export goods?

Trading with a designated person is likely to engage the financial sanctions prohibitions relating to
funds and economic resources. Specifically financial sanctions prohibit making payments or
economic resources available to that person and dealing with any payments they make. This means
that goods, which will have an economic value, cannot be exported to that person. That is the case
even if the contract for export was signed before the importer was designated; it is not within the
Treasury’s gift to license the release of economic resources to a listed person on the basis that they
are owed under a prior contract.
17.1.8 I want to sell humanitarian goods, medicines etc to a country subject to financial
sanctions. Will financial sanctions affect that?
Modern ‘smart’ or targeted financial sanctions do not usually seek to interrupt, for example, the
export of medicines, foodstuffs or other humanitarian goods to countries against which financial
sanctions may be in force.
So, even where financial sanctions and other restrictions are in place there are generally exemptions
for the export of humanitarian goods, medicines etc .
Nevertheless UK exporters may still need a licence to supply goods (ie making economic resources
available) or to be paid by or through a designated person. HM Treasury will consider licence
applications in such cases as a matter of priority.
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17.2 BANKING
17.2.1 I have a designated person as a customer – what should I do?

You must freeze (i.e. refrain from dealing with) their assets and report details of the assets to HM
Treasury.
Reports of frozen accounts etc should include the following details:
• The full name of the account holder or holders, including how the name is presented on any
debit card etc;
• Details of the account holding institution – the name and address of the bank etc, and its
FSA reference number where applicable;
• The account sort code and number;
• Currency in which the account is maintained;
• The type of account (current, deposit, etc) and whether it is a primary account or sub-
account; and
• The latest account balance/s.
17.2.2 Do I need a licence to close a frozen account and transfer any balance to the customer?
You require a licence to do this if doing so involves transferring frozen funds out of the account
and/or making funds available to the listed person. If closing an account involves no dealing with
frozen funds or making funds available, it is not illegal and no licence is required. However, it is not a
legal requirement that a listed person’s account is closed; the requirement is simply that funds in it
are not dealt with unless under the authority of a licence. The Treasury prefer that banks do not
close listed persons’ accounts as the effect can be to lead to financial exclusion, and reduces the
opportunities to monitor the finances of a designated person.
17.2.3 Can I apply interest to an overdrawn, loan or mortgage frozen account?

Interest may continue to be applied to both credit and debit accounts without a licence as this is
exempt under the legislation.
17.2.4 Are financial institutions expected to know if a credit received for a frozen account relates
to a prior contract? What obligation is there on the bank to investigate the source of
credits to frozen accounts?
Financial sanctions regimes include a provision that allows financial institutions that receive funds
from third parties to credit frozen accounts. Where crediting of funds is permitted, the institution is
required to report details of the credit as soon as possible to the competent authority i.e. HM
Treasury (unless the funds credited are in respect of interest or earnings on the account, in which
case no reporting is required). Full information should be provided when reporting details of credits.
If as part of your normal course of business you are aware of the background to the credit then this
information should be provided also.
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Financial institutions are not however required to undertake separate investigations beyond what
they could be expected to know as the receiving bank.
17.2.5 Can firms lend money or provide credit to a designated person?

Loans and other forms of credit must not be made available to designated persons unless a licence is
obtained.
17.2.6 Can I apply interest to frozen accounts?

Yes. Interest may continue to be applied to both credit and debit accounts without a licence.
17.2.7 I am a bank. Can I credit funds transferred to the account of a designated person?
The prohibition against making funds or economic resources available does not prevent financial or
credit institutions that receive funds transferred by third parties to the frozen account of the listed
person from crediting frozen accounts provided that any additions to such accounts are also frozen.
Financial institutions are required to inform the Treasury of any such transactions without delay.
17.2.8 Can I credit funds received from a designated person to their frozen account?
Financial or credit institutions that receive funds transferred by the designated person to their
frozen account must hold those funds in suspense and apply for a licence to credit the funds to the
frozen account. Where HM Treasury receive applications from restricted persons to allow them to
pay funds their frozen account and license such activity, the licence will also be issued to the
relevant financial or credit institution.
Banks and other institutions must report credits to frozen accounts to HM Treasury.
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17.3 INSURANCE
17.3.1 What is the general effect of sanctions on insurance businesses?

Generally sanctions do not ban the provision of insurance. However it is prohibited to provide
insurance to:
• person designated under TAFA 2010, and

• certain state entities and persons in Syria.
There are special provisions for the insurance supplied to designated persons- see below.
There is more about the financial restrictions in force in respect of Syria at:
https://www.gov.uk/government/publications/financial-sanctions-syria and
https://www.gov.uk/sanctions-on-syria
Additionally, sanctions prohibit the payment of funds to or for the benefit of designated persons,
which would impact on the payment by the designated person and others of insurance premiums
and the payment of claims to a designated person, which could not take place unless licensed.
17.3.2 What should an insurer do if an existing customer becomes a designated person after the
inception of cover?
If the designated person is listed under the domestic terrorism regime (the only regime under which
it is prohibited to provide insurance to listed persons), two general licences are currently in place
which cover insurance.
General licences allow:
• the provision of insurance to designated persons, and
• the immediate and temporary provision of goods and services in respect of an insurance
claim like courtesy cars or emergency hotel accommodation to designated persons.
There is more information on general licences at:
https://www.gov.uk/government/publications/counter-financing-of-terrorism-general-licenses
If someone is listed by the UN or EU under a country sanctions regime, the fact of their designation
does not make any insurance cover that they enjoy at the time of their designation, or any cover
that might be taken out after that date, illegal. However, if they are listed under the Syrian regime,
it may be illegal to provide them with cover regardless of their designation, because of the broad
insurance bans referred to above.
There is no legal requirement to discontinue cover to listed persons. Insurers making an assessment
of whether they wish to discontinue cover to a designated person will wish to take into account the
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potential social harm that might be caused if they terminate a contract that is either not subject to
any restriction or is permitted under a general licence.
17.3.3 What is the position if a policy holder names a designated person as a beneficiary?
Sanctions prohibit the payment of funds to or for the benefit of designated persons. This would,
without a licence, prevent the payment of benefits due under a policy to a beneficiary who is a
designated person.
17.3.4 As an insurer I may not know the identity of every beneficiary of the cover I provide,
because the business is managed under a delegated authority or bordereau arrangement.
What should I do?
The underwriting insurer should take reasonable measures to establish that any third party with
whom it enters into a delegated authority or bordereau arrangement, understands their obligations
to meet the UK financial sanctions obligations, including notification to the underwriting insurer of
any target matches or frozen accounts.
Whilst Insurers may not have knowledge of the identities of the underlying clients /customers and so
be unable, themselves, to identify any potential sanctioned party exposure, the underwriting insurer
should satisfy itself that the third party’s systems and controls are commensurate with the UK
financial sanctions obligation as they apply to the delegated activity.
Insurers should consider measures such as making specific reference to sanctions compliance within
their Terms of Business and/or from time to time requiring positive affirmation from their third
parties of their financial sanctions systems and controls.
17.3.5 As an insurer, I may only receive partial information from third parties. What should I do?
Insurers should undertake reasonable enquiries to identify whether the underlying clients or
claimants may be sanctioned parties.
Insurers should consider their arrangements with introducers and other parties to maximise the
detail of information provided. Should this information then be sufficient to undertake adequate
investigation, then the insurer should investigate the sanctioned party potential as it would in any
other situation where such information is available.
Where, for valid business reasons, this level of detailed information cannot be obtained, insurers
may consider the following approaches:
• For UK focused business, it may be appropriate to compare the partial details received
against those details, on the HM Treasury Consolidated List, relating to UK resident
sanctioned parties (which would be a far lower number of cases than on the full list);
• Similarly, for non–UK business, insurers may focus their investigations in respect of those
entries on the HM Treasury Consolidated List that correspond to the jurisdiction where
underlying client or claimant is suspected to reside.
Where it is impossible to draw a conclusion due to non-availability of additional data the insurer may
lack the requisite knowledge or suspicion to fall foul of any of the sanctions prohibitions.
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17.3.6 I provide pensions or other products to an employer, and may not know who the relevant
employees are. What should I do?
Subject to the precise arrangements it is likely that the contract will be with the employer. The
employer then provides the benefits to the employees further to their contracts of employment.
Insurers should initially focus on the employer when conducting their sanctions checks. Where
specific employees are drawn to the insurers attention (either for special underwriting or for the
direct payment of benefits) sanctions checks should be conducted.
17.3.7 I am a reinsurer. What do sanctions mean for me?

The insurance ban in the Syrian regime apply equally to reinsurers. Reinsurers should satisfy
themselves that they are not breaching these measures.
17.3.8 I am an insurance agent or broker. What do sanctions mean for me?

Like all UK businesses, insurance brokers or agents must comply with financial sanctions because
they are subject to the legal requirements of those sanctions to freeze assets of, and not to make
funds or economic resources available to, designated persons, or to provide cover to those classes of
persons and entities referred to in the Syrian insurance prohibitions.
Separately, agents and brokers may find that the underwriters for whom they act makes it a
contractual requirement that the agent etc complies with UK sanctions or carries out certain sanctions
checks. Generally these contractual arrangements will be an issue for the parties to the contract.
Insurers themselves may want to undertake enquiries so as to be sure that agents or other
intermediaries (to whom they pay commissions etc) are not themselves sanctioned entities.
17.3.9 The Syrian ban refers to “compulsory or third party insurance”.

What does the term ‘compulsory’ mean in this regard?
Compulsory insurance includes not only insurance required by statute but also insurance obtained to
meet any obligation covered by law (including regulations).
It is the responsibility of the insurer to seek sufficient evidence that the cover sought by a designated
entity contributes to satisfying a legal or regulatory requirement, both in terms of the nature of
cover and extent of cover sought.
17.4 Motor insurance
17.4.1 Does a firm providing a complimentary vehicle or temporary hire car in relation to a motor
vehicle insurance policy to a designated person require a licence?
No. Whilst there is a prohibition on making economic resources available to a designated person, if
the person providing the economic resource neither knows nor has reasonable cause to suspect that
the designated person would be likely to exchange the economic resource, or use it in exchange, for
funds, goods or services, the resource can be provided without breaching the prohibition (and
therefore without a licence).
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HM Treasury consider that, in the normal course of this type of business, this test would be met and
therefore the economic resource (e.g. the car) could be provided without a licence. This view also
applies to all other financial sanctions regimes.
However, firms should bear in mind that if there is knowledge or reasonable cause to suspect that
the designated person would be likely to exchange the economic resource, or use it in exchange, for
funds, goods or services then the economic resource should not be provided. In such circumstances
firms should consider their reporting obligations under the financial sanctions legislation. The firm
may also need to consider whether there is an obligation also to report under Proceeds of Crime Act
2002 or the Terrorism Act 2006.
HM Treasury similarly considers that the payment for temporary complimentary/hire vehicles
provided by insurance firms to designated persons in the normal course of this type of business
would not amount to making funds available for the benefit of the designated person and therefore
a licence is not required. This view applies to all financial sanctions regimes.
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17.5 LEGAL SERVICES
17.5.1 We are a firm of solicitors acting for a designated person. Do we need a licence?
The provision of legal services does not require a licence.
However, the payment of legal fees using frozen funds held on behalf of a designated person does
require a licence because this involves dealing with funds that are required to be treated as frozen.
17.5.2 Do solicitors acting for a designated person who is funded by legal aid or by other third
parties require a licence to deal with those funds?
A licence is required both by the Legal Aid Agency and any other third party that pays the listed
person’s legal expenses on their behalf. This is because this breaches the prohibition on making
funds available to an unlisted person (i.e. the solicitor) in circumstances in which the listed person
obtains a significant financial benefit (the discharge of the financial obligation to his or her solicitor).
A general licence permits the Legal Aid Agency (LAA) to make payments to solicitors representing a
designated person where the LAA has assessed that the individual is eligible for legal aid, and for
those funds to be applied by the solicitors to meet the legal costs incurred in the course of advising
and representing the designated person listed under the Terrorist Asset Freezing or Al Qaida regimes.
The general licences for legal aid and to allow third parties to meet legal expenses for certain persons
are available at: https://www.gov.uk/government/publications/counter-financing-of-terrorism-
general-licenses
Under the country sanctions regimes, the Treasury will consider applications for individual licences
to be issued for third parties to pay listed persons’ legal bills and for solicitors to deal with frozen
funds they hold in client accounts on behalf of listed persons in order to meet their fees.
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HM Treasury: Financial Sanctions: Frequently Asked Questions (Faqs)

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HM Treasury: Financial Sanctions: Frequently Asked Questions (Faqs)

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HM TREASURY

8 Sanctions targets – designated persons ....................................................................................... 27

These FAQs are structured as follows;

• Part 2 – a guide for beginners provides a high level summary

MEANING OF “PERSON” IN THESE FAQ’S.

1.1 A note on publication arrangements

3.1 Who is responsible for sanctions policy in the UK

3.2 Who is responsible for administration of financial sanctions in the UK?

HM Treasury is therefore responsible for:

• licensing exemptions to financial sanctions.

3.3 Who is responsible for trade sanctions in the UK?

3.4 What is the role of the Financial Conduct Authority (FCA)?

3.5 How can I contact HM Treasury about financial sanctions?

Enquiries can be submitted by post to:

3.6 What is the Treasury’s response time to enquiries?

You can find out how to subscribe at:

4.1 Why does the UK apply financial sanctions?

• To encourage a change in the behaviour of a target country or regime;

• To apply pressure on a target country or regime to comply with set objectives;

• To prevent and suppress the financing of terrorists and terrorist acts.

4.2 What are financial sanctions?

HM Treasury cannot advise you on compliance with foreign sanctions.

5.1 What do financial sanctions measures involve?

• A prohibition on making funds or economic resources available, directly or indirectly, to, or

Certain financial sanctions may also involve:

5.2 What does an asset freeze do?

5.3 What are funds and economic resources?

5.4 Are frozen funds confiscated by HM Treasury?

5.5 Can somebody make funds available to a designated person?

5.6 Can somebody make financial services available to a designated person?

5.11 What is a “significant” financial benefit?

5.12 Can licensed funds be spent on anything?

If in doubt, HM Treasury’s advice may be sought.

6.1 How do sanctions affect me if I am a designated person?

6.2 I have commercial dealings with a designated person.

6.3 I am a private individual or charity.

Targeted financial sanctions generally include humanitarian exemptions or licensing grounds

See also paragraph 17.1.8 about humanitarian transactions.

An asset freeze does not affect the ownership of funds.

7.1 What sanctions law applies in the UK?

Under the Terrorism and Terrorist Financing regime there is:

7.4 Do financial sanctions apply to the subsidiaries of UK companies outside the

7.5 What reporting requirements exist for ‘relevant institutions’?

7.6 What powers does HM Treasury have to request information?

7.7 What onward disclosure is allowed?

7.9 Is it an offence to make funds available to a target of financial sanctions

7.10 Circumvention of sanctions

You may also wish to take independent legal advice.

7.13 What if I did not know I was breaching a prohibition?

8.1 What is a designated person?

See paragraph 8.3 for advice on ownership and control.

8.3 How can I tell if a company is owned or controlled by a designated person?

• It holds a majority of the voting rights in it; or

• It is a member (i.e. shareholder) of it and has the right to appoint or remove a

• It has the right to exercise dominant influence over it by virtue of provisions

• It has the power to exercise, or actually exercises, a dominant influence or control

In addition to the analysis above, advice issued by the EU is available at:

8.4 What is the Consolidated List of Targets?

8.5 What is the relevance of the “AKA’s” on the Consolidated List?

8.6 Is HM Treasury’s Consolidated List of targets the same as that published by

8.7 Where can I find the Consolidated List?

8.8 What formats is the Consolidated List available in?

• HTML - A basic file format used on the Internet;