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On 6 September 2021, the Office of Financial Sanctions Implementation (“OFSI“) published its 2021 frozen asset reporting notice (see here). The notice is a reminder that all persons that hold or control funds or economic resources belonging to, owned, held, or controlled by a designated person must provide a report to OFSI with the details of these assets by Friday 15 October 2021. This is part of HM Treasury’s annual review of frozen assets to update its records and to capture any changes during the reporting period.

Any report must include the value of all such assets as at close of business on Thursday 30 September 2021. All returns need to be made in the form of a completed template from the GOV.UK website to

There is no need to provide a nil return to OFSI if you do not hold or control funds or economic resources belonging to, owned, held or controlled by a designated person. However, if you submitted a report last year (other than a nil return) and no longer hold those assets, you should submit a nil return.


Sunny Mann is a Partner in Baker McKenzie's London office and co-leads the UK Compliance and Investigations Practice, as well as the UK International Commercial and Trade Practice. Both these practices are ranked Tier 1 by Legal 500 UK. He has also worked in our Firm's Washington DC, New York and Sydney offices. Sunny also advises many clients on risk matters in India. He advises clients (including numerous FTSE 100 and Fortune 100 businesses) on compliance and investigations with respect to export controls, trade sanctions and anti-bribery rules. The Legal 500 ranked Sunny as a “Leading Practitioner", and as "excellent", with a ‘calm’ and "very practical" approach. The India Business Law Journal also noted that Sunny is "excellent and has deep experience in India". He is a Visiting Professor at the College of Europe, the leading institute for post-graduate European studies, where he teaches a course on Corporate Compliance.


Adeel Haque is an associate in Baker McKenzie's London office. He is a member of the International Commercial & Trade and Antitrust & Competition practice groups. Adeel qualified in September 2019 and has spent time working in the Firm's Hong Kong office.

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