UK Freeze Assets of High-Profile Individuals in Latest Sanctions Update

On November 21, 2024, the Foreign, Commonwealth and Development Office (FCDO) updated the UK Sanctions List including entities & individuals designated under regulations made under the Sanctions Act.

The UK government sanctions Angolan billionaire Isabel dos Santos and Ukrainian oligarch Dmytro Firtash and seized their UK assets,  as part of a fresh crackdown on “dirty money.”

An updated list assists individuals & businesses to refrain from doing business with these sanctioned parties. The list also provides details about which sanction measure will apply to entities or individuals, providing reasons behind the designation.

The United Kingdom (UK) government has confirmed its commitment to reducing global corruption by updating its sanctions list. This update lies under the purview of Global Anti-Corruption Sanctions Regulations 2021 (S.I. 2021/488).

This Regulation was established under the Sanctions & Anti-Money Laundering Act 2018,  enforcing the UK to impose financial sanctions on entities & individuals involved in corruption.

These sanctions usually take the form of freezing assets & economic resources belonging to designated individuals.

Consolidated List Update

The Consolidated list is updated after including the following entities & individuals:

• Isabel DOS SANTOS (Group ID: 16694)
• Dmitry Vasylovych FIRTASH (Group ID: 16699)
• Lada Pavlovna FIRTASH (Group ID: 16700)
• Denis Vladimirovich GORBUNENKO (Group ID: 16701)
• Liga LEMBERGA (Group ID: 16698)
• Aivars LEMBERGS (Group ID: 16697)
• Paula Cristina Fidalgo Carvalho Das Neves OLIVEIRA (Group ID: 16696)
• Sarju RAIKUNDALIA (Group ID: 16695)

These entities & individuals are now entitled to an “asset freeze” – their assets held in or controlled by the UK.

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Compliance Obligations for Entities and Individuals

The UK government has also issued a warning to financial institutes & entities working within its jurisdiction to take necessary actions to comply with imposed sanctions.

Entities are obligated to take immediate action to comply with the imposed sanctions.

• Businesses should review their record to recognize any funds, accounts, and economic resources controlled or held by designated individuals listed in the Annex to this Notice.
• Any such accounts, economic resources, and funds should be promptly frozen.
• Entities should refrain from dealing with any economic resources & funds, directly or indirectly, to the designated individual until the Office of Financial Sanctions Implementation (OFSI) gives authority under certain conditions.
• Any suspicious finding related to a designated individual, such as funds quantity & nature, should be reported to OFSI.
• OFSI may share received information with a relevant third party, particularly in line with the guidelines outlined in the Information and Records section of the rules.
• Failure to comply with UK financial sanction legislation can result in criminal penalties.

Businesses & entities are urged to stay updated on sanctions developments & implement AML solutions to ensure compliance.