Today, on 17 July, OFSI has launched new online forms for submitting licence applications, reporting suspected breaches, and other key reporting such as frozen assets. This is a significant step forward in our drive to modernise and streamline our services, making our processes clearer, faster and more accessible for everyone who needs to contact us. The new forms are designed to make it easier for you to provide the information we need and to help us respond more quickly and efficiently. For now, the new online forms will operate alongside our existing processes during a transition period. While use of the online forms is not yet mandatory, we encourage all users to familiarise themselves with the new forms and start using them as soon as possible. To support this, we have also published downloadable versions of the new forms to preview the questions, which can also be completed and sent to us by email. Using these templates will help you get used to the new format and requirements ahead of the full transition. OFSI will provide ample notice before the old forms are phased out permanently, through e-alerts and updates to our website. OFSI values your feedback. Please let us know what you think about our online forms by emailing ofsi@hmtreasury.gov.uk. Your input will help us shape ongoing improvements to the forms. **Why you should start using the online forms** * **Faster Responses:** Submissions are delivered directly to the relevant OFSI teams, enabling quicker processing and response times. * **Fewer Follow-Up Questions:****** The online forms include built-in guidance and mandatory fields to help ensure all necessary information is provided in the correct format first time. This reduces the likelihood of incomplete or incorrect submissions and minimises the need for follow-up requests, allowing OFSI to handle cases more quickly. * **Accessibility:** The new forms meet high accessibility standards, ensuring they are usable by everyone. Once your form is submitted, you will receive a confirmation email from OFSI containing the details of your submission. To help you complete your submission smoothly, we recommend reviewing the downloadable versions of our new forms and gathering the necessary information and documents before you begin. We advise stakeholders to complete forms in one session to avoid any loss of information. The forms cannot be saved in progress. However, as long as the browser is not closed, the form will retain details for up to 20 hours. **Where can I get help?** Each online form has guidance on how to fill it in. If you require further assistance, you can contact ofsi@hmtreasury.gov.uk. **Which forms are available?** The following forms are now available online: **Licensing Application** Use this form to make a new application for a licence or amend an application if the activity the licence is needed for is not already covered by any of the General Licences. Information needed: * Detailed information about the transactions. * A detailed explanation of why you think the proposed transaction falls within one or more of the available licencing grounds. * A detailed explanation of the sanctions regime which you are applying under. * For frozen assets, bank details - payment method, account details, payment route details and whether funds are available for payments, and copies of documents to support your application. **Financial sanctions suspected breach reporting form** Use this form to report suspected breaches and compliance issues related to implementation of financial sanctions. Information needed: * Contact details of the person making the report. * Details of the suspected breacher and any involved designated person(s) (DP), including their group ID if they are a DP. * Details of any persons connected with Russia or trust services, if involved. * The sanctions regime under which the suspected breach has occurred and details of any relevant licence numbers that may apply or are suspected to have been breached. * Details of the suspected breach including value, currency, date, details of remitter, intermediary and ultimate beneficiary. * Documentation detailing the events or series of actions that led to the suspected breach taking place (further guidance below). * Details of when and how the suspected breach was discovered, and any other authority the matter has also been or will be reported to. * The types of funds, economic resources or financial services involved. * Any other supporting material. ****Oil Price Cap (OPC) suspected breach reporting form**** Use this form to report suspected breaches and compliance issues related to implementation of the UK’s ban on the maritime transportation of Russian oil and oil products and associated services and the oil price cap. * Contact details of the person making the report. * Details of the suspected breacher and any involved UK persons or entities, including company reference numbers where applicable. * Details of any persons connected to Russia, if involved. * The regulations under which the suspected breach has occurred and the suspected offence that has been triggered. * Details of any suspected breaches of licence conditions or reporting obligations, or the General Licence(s) that the suspected breach relates to, including the licence number. * The tier of service provider of the reporter of the suspected breach. * The tier of service provider of the person(s) suspected of committing the breach. * Details of any suspected breach, including: * Oil transaction details. * Voyage details. * Vessel details. * Any UK nexus and other relevant service providers. * Any sanctions evasion red flags. * Documentation detailing the events or series of actions that led to the suspected breach taking place (further guidance below). * Details of when and how the suspected breach was discovered, and any other authority the matter has also been reported to. * The types of activities, services, and jurisdictions involved. * Any other supporting material, including any relevant attestations. **Licence reporting (except Legal Services General Licence reporting)** Use this form to submit licence reporting. If you need to report under the Legal Services General Licence, use the Legal Services General Licence reporting form instead. **Legal Services General Licence reporting** Use this form to submit licence reporting for activities carried out under the OFSI Legal Services General Licence. Information needed: * Ensure you have all the necessary information and supporting evidence available as per the reporting requirements in the General Licence. **Counter-terrorism suspected breach reporting** Use this form to report all counter-terrorism compliance-related information to OFSI, including information regarding any suspected breaches of financial sanctions. **Designated Persons Reporting** Use this form if you are a DP under the Russia or Belarus (Sanctions) (EU Exit) Regulations 2019 and need to report any funds or economic resources you own, hold or control to OFSI, within 10 weeks of your designation or the relevant legislation coming into force. Please download the Excel template here. This will need to be completed before uploading it to the form. Information needed: * Please provide details of all funds and economic resources owned, held or controlled by you, where the value of those funds or economic resources exceeds £10,000. * Include funds and economic resources held jointly as well as funds and economic resources in your sole name. * If multiple funds or economic resources of the same type taken together exceed £10,000 this must also be reported. * There is space on the Excel to add additional information and notes. **Frozen Asset Reporting** This form should be used by relevant firms to report as soon as practicable the nature and amount or quantity of any funds or economic resources they hold for a customer who is a designated person. Please download the Excel template here. This will need to be completed before uploading it to the form. This form differs from the annual review of frozen assets where, persons that funds or economic resources owned, held or controlled by a designated person as of 30th September in a calendar year will have to provide OFSI with a report stating the nature and amount or quantity of these funds or economic resources by no later than 30th November in that calendar year. For more information on the annual review of frozen assets see our recent annual review. Information needed: * DP information (Group ID & Name). * Details on Frozen Accounts. * Details on Frozen Payments. * Details on Economic Resources. If you have previously reported frozen assets that are no longer held or frozen, you should still use this form to update OFSI. Please clearly indicate the status of those assets in the “additional information” column of the Excel upload. **Immobilised Assets** Use this form for notifying OFSI if your firm knows or suspects it holds funds or economic resources for a person or entity prohibited under regulation 18A(1) of the Russia (Sanctions) (EU Exit) Regulations 2019. This includes the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, the Ministry of Finance of the Russian Federation, or anyone owned, controlled by, or acting on behalf of these entities.  Information needed: * Group ID * Details of the assets – values, country held in, interest accrued. **Compliance reporting** Use these forms to report your compliance with an exception from financial sanctions: Complying with the exception: "Investments in relation to non-government controlled Ukrainian territory" Complying with the exception: "Credits to and transfers out of frozen accounts and relevant accounts" Complying with the exception: "Exception for required payments" Complying with the exception: "Humanitarian Assistance Activity in relation to Syria [Relating to Petroleum Products] " Complying with the exception: "Investments in relation to Russia" Information needed: * Provide details of the transaction (including the date, time, value, relevant parties) and reporter’s contact details.

On 11 April 2025, OFSI imposed a monetary penalty of £5,000 on the UK-registered company Svarog Shipping & Trading Company Limited (“Svarog”). This penalty relates to an information offence and is the first of its kind to be issued by OFSI. Svarog failed to respond within the required timeframe to a statutory Request for Information (RFI) made by OFSI, and failed to provide a reasonable excuse. In those circumstances, OFSI has the power to impose a penalty in respect of the information offence. This case highlights the importance of firms and individuals responding in a timely manner to OFSI RFIs. Below, we have provided an overview of RFIs, a brief summary of the case, and the key compliance lessons that industry can take away. **What do we mean by a “Request for Information?”** OFSI has legal powers to require certain firms and individuals to provide information to it. The reasons OFSI might request this information are outlined in section 5.6 of OFSI’s general guidance, and can include establishing whether financial sanctions may have been breached, or monitoring compliance with certain financial sanctions regulations or licences. When requesting information, OFSI will specify the legislative basis for the request, and the time period within which the information is to be provided. OFSI’s powers to request information are among the most important tools it has for investigating suspected breaches of financial sanctions. If firms or individuals fail to respond to these requests, it can hinder OFSI’s timely access to information, thereby impacting OFSI’s overall effectiveness and efficiency. **What was the information offence committed by Svarog?** OFSI issued an RFI to Svarog on 26 January 2024, as part of a large and complex investigation. Svarog did not respond to the RFI by the deadline. Despite OFSI sending reminders, Svarog’s response was only received after OFSI contacted Svarog’s auditors. Svarog apologised for failing to respond to the RFI, but it did not provide a reasonable excuse for missing the statutory deadline. Given Svarog’s failure to respond to OFSI’s RFI issued on 26 January 2024 and its failure to provide a reasonable excuse, OFSI concluded that Svarog had committed an information offence and that a penalty of £5,000 was the appropriate outcome. OFSI ultimately concluded that Svarog had not breached financial sanctions other than in respect of this information offence. For the full details of the case, please see the penalty notice. **What are the key compliance lessons for industry?** **1. Firms should recognise the seriousness of failing to respond promptly to RFIs.** OFSI takes a dim view of firms who delay or fail to respond to statutory obligations placed upon them. Firms should therefore first note the importance OFSI attaches to its information gathering powers and should be aware of the potential consequences of inaction. Failure to respond to RFIs can significantly impede OFSI’s ability to assess compliance, enforce financial sanctions and maintain compliance with the sanctions regimes. In this instance, Svarog’s failure to respond by the deadline caused delay to the wider investigation the RFI was related to, and wasted OFSI’s resources, including the need for OFSI to contact Svarog’s auditor. Such delays, if repeated across OFSI’s other enquiries, could seriously undermine OFSI’s effectiveness and efficiency, diverting resources away from enforcement action and constituting a poor use of taxpayer money. **2.** **Engage proactively and candidly with OFSI when it comes to RFIs.** If firms receive an RFI from OFSI but are unsure how to respond, or believe they cannot meet the deadline, they should contact OFSI as soon as possible to seek clarification and/or request an extension. They should not ignore the request. If a firm believes it has missed a statutory deadline, but has a reasonable excuse, it should provide that excuse proactively for OFSI to consider, accompanied by a full explanation of the circumstances. Firms are also encouraged to engage with OFSI’s published guidance and seek professional advice on their sanctions obligations if necessary. **3.** **Have effective communication and monitoring systems in place.** OFSI expects firms to have effective communication and monitoring systems in place, so that firms can promptly identify and respond to any RFI they might receive from OFSI. This includes appointing responsible personnel, monitoring and maintaining up-to-date contact information to ensure compliance with OFSI requests for information. This is especially true for firms operating in sectors with elevated exposure to sanctions. Svarog - operating in the high-risk maritime oil shipment sector - demonstrated some awareness of sanctions risks and its own exposure. These factors ought to have made Svarog more vigilant to the request from OFSI, and should have caused it to have robust processes in place for responding. **4. Consider other compliance and reporting obligations.** Whilst the penalty in this case related to the failure to respond to an RFI without a reasonable excuse, other types of failures to provide information can also constitute breaches leading to penalties. For example: 1. Non-compliance with reporting obligations, including both failure to report and late reporting without reasonable excuse. 2. Incomplete or otherwise non-compliant reporting on specific and general licences, reporting requirements on licences, failures to report frozen assets. You should ensure you are aware of your obligations either as a relevant firm (as defined in the regulations), or as the user or holder of a valid OFSI licence. The requirement to comply with all other obligations applies to both individuals and entities. **Conclusion  ** The information powers contained in the Russia Regulations are designed to ensure OFSI has prompt and full access to the information it needs to implement and enforce financial sanctions. This case signals to industry the importance of responding to RFIs in a timely and comprehensive manner; doing so helps contribute to the effective implementation and robust enforcement of financial sanctions.

On 20 March 2025, OFSI announced a monetary penalty of £465,000 against Herbert Smith Freehills CIS LLP (“HSF Moscow”) for breaches of UK financial sanctions on Russia, linked to its illegal invasion of Ukraine. The penalty relates to six payments made by HSF Moscow, with a collective value of £3,932,392.10, to designated persons subject to an asset freeze. The payments, which took place over a period of seven days as the firm wound down its Russian offices, demonstrated a pattern of failings brought about primarily by inadequate due diligence and sanctions screening, and errors caused by the hasty closure of the HSF Moscow office. HSF London, on behalf of HSF Moscow, voluntarily disclosed the breaches to OFSI, and therefore a 50% reduction has been applied to the final penalty amount. The HSF Moscow penalty carries a number of important compliance messages for industry - not only the legal sector. Below, we have highlighted three key lessons that businesses can draw from this case: 1. **Understand your exposure to sanctions risks** It is essential for firms to understand their exposure to sanctions risks and take appropriate action to address them. Firms operating in higher risk environments, should educate themselves fully on the risks, including by engaging with OFSI’s published guidance, and seeking professional advice on their sanctions obligations where necessary. In particular, parent companies with subsidiaries in areas that pose a heightened sanctions risk (such as offices overseas) should make sure they are providing suitable advice and assurance to their subsidiaries. A prior OFSI penalty against Tracerco in May 2022 also highlighted this risk. 2. **Adhere properly to any sanctions policies and processes in place in your organisation** Firms should follow all relevant sanctions screening and due diligence measures they have in place. This applies to everyone in an organisation, regardless of seniority. Whilst OFSI usually considers the existence of appropriate sanctions policies and procedures as a mitigating factor, failure to comply with them is likely to negate the mitigating factor of having them in place. This is unless there was a good reason for not following said measures, and the decision not to follow them was taken at the appropriate level . Further, the HSF Moscow case demonstrates the significant risks that can emerge when payments are made in haste and procedures are not adequately followed by senior figures. 3. **Fully consider ownership and control** Firms need to carefully consider ownership and control, beyond just whether an entity is directly subject to sanctions. OFSI views failure to properly consider and identify clear ownership more poorly than an incorrect but good faith assessment of control. Firms should therefore take sufficient time and care to properly assess the applicability of sanctions to the specific legal entities they are dealing with. Ownership and control is considered under case factor F within OFSI’s Enforcement and Monetary Penalties guidance, with examples of areas of enquiry OFSI may expect to be undertaken by persons seeking to establish whether an entity is owned or controlled by a designated person. Further information and guidance on UK financial sanctions can be found on OFSI’s website.