UK Treasury requires reports on frozen sanctioned assets

LONDON, September 30, 2026 — HM Treasury’s annual review requires holders of frozen assets tied to designated persons to report their value and identifying details to the Office of Financial Sanctions Implementation.

Reports are due Nov. 30 and must reflect assets held at the close of business on Sept. 30. The exercise covers funds and economic resources frozen in the UK, along with overseas assets subject to UK financial sanctions. Accounts blocked solely by another national authority, such as the US Office of Foreign Assets Control, are outside the reporting scope.

The requirement applies to anyone holding or controlling funds or economic resources owned, held or controlled by a designated person. It also extends to entities directly or indirectly owned or controlled by designated persons, even if those entities are not separately named on the UK Sanctions List.

Reportable property can include cash, deposits, securities, debt instruments, real estate, vehicles, precious metals, services and cryptoassets. Shares, securities and foreign-currency debt or payment instruments must also be reported with a value in pounds.

Returns must use the form published on GOV.UK and be sent to OFSI. A nil return is generally unnecessary, but a filer that reported assets last year and no longer holds them should submit one.

This year’s exercise also reflects a change in list maintenance. Since Jan. 28, the UK Sanctions List has been the government’s only updated source for UK designations. New designations since that date receive a UK Sanctions List Unique ID rather than an OFSI Group ID, while older entries retain historic group identifiers. That shift may affect how firms map frozen assets to sanctions records.

The annual deadline does not replace ongoing reporting. Newly frozen funds or economic resources must be reported immediately.