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UK Issues Guidance About Using Suspense Accounts for Sanctioned Assets

The U.K. said it generally won’t penalize an organization for using a “suspense account” to temporarily record sanctioned assets, the country’s Office of Financial Sanctions Implementation said in new frequently asked question 145 published this week.

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The agency said it “does not consider it to be in the public interest to take enforcement action in relation to the creation and use of suspense accounts for the express purpose of” following U.K. requirements to freeze funds belonging to a sanctioned person, as long as the organization only uses that account at the point when it “first becomes aware” of those U.K. requirements. The organization also should notify OFSI in a frozen asset report that they’re using suspense accounts, OFSI said, which are used by companies to record entries on its books that need clarification before they’re assigned to their proper accounts.

“Relevant Institutions may wish to make specific reference to this FAQ within any such frozen asset report,” OFSI said.