The Financial Reporting Authority (FRA) has introduced a new annual reporting requirement for anyone holding frozen assets linked to designated people under UK sanctions regimes.
The requirement, announced in a financial sanctions notice on 6 November, stems from United Kingdom regulations amended in 2024.
They extend new reporting obligations to the Cayman Islands for funds or economic resources owned, held or controlled by sanctioned individuals or entities.
Financial institutions, law firms and others holding client assets must report the value of all frozen assets as of 30 September to the FRA using a standardised template.
“The requirement is to provide an annual frozen assets report to the governor with details of these assets,” the FRA stated in the notice, adding that first reports are due by 30 November.
The reporting obligation covers all funds and economic resources frozen under UK sanctions regimes extended to Cayman through Orders in Council, including both assets held locally and overseas where subject to the modified sanctions regulations.
Assets blocked solely by other national authorities, such as the US Office of Foreign Assets Control, do not require reporting to the FRA.
Economic resources requiring reporting include tangible and intangible assets such as precious metals, vehicles, property, crypto assets and services that could be used to obtain funds, goods or services.
Unlike many regulatory reporting requirements, entities that do not hold any frozen assets are not required to submit nil returns.
The FRA said organisations should designate one person to collate and submit returns to avoid duplication, with reports to be submitted electronically to financialsanctions@gov.ky
Beyond the annual reporting requirement, entities must continue to immediately report any newly frozen funds or economic resources as they arise.
The notice reminded firms of their existing obligations to check clients against HM Treasury’s Consolidated List of asset freeze targets, freeze relevant accounts, refrain from dealing with frozen assets unless licensed by the governor, and report findings immediately.
The reporting template and guidance are available on the FRA’s website, with the authority providing support for queries through its financial sanctions email address.
