Financial sanctions & insolvency
Designations, ownership and control, reporting, asset freezes and licences.
Financial sanctions can affect dealings with assets, creditors, buyers and other parties in an insolvency. An office-holder must identify the applicable restrictions before moving money or property. Appointment to office does not itself release an asset freeze or supply a licence.
Screen and understand control
Use the current UK Sanctions List and the relevant regime’s legislation. The OFSI Consolidated List closed on 28 January 2026; it is no longer the current source of UK designations.
A name search alone is insufficient. Consider aliases, identifying information and ownership or control by a designated person. A party that does not appear by name may still be affected by restrictions. Reassess when parties, ownership or designations change.
Understand the restriction
An asset freeze limits dealings and the making available of funds or economic resources. It does not mean that ownership passes to the government or to the office-holder. Identify which assets, activities and persons are covered before selecting a course of action.
Exceptions and licensing grounds are specific. An application, or the fact that a payment concerns insolvency expenses, is not permission to pay. Check the terms and scope of any licence and retain evidence of compliance.
Report and record appropriately
OFSI’s guidance explains the reporting obligations of relevant firms, including insolvency practitioners. Apply the statutory knowledge or reasonable-cause tests and any required reporting timescale. Reports about frozen assets and breaches have different purposes.
A sanctions report and an NCA suspicious activity report address different regimes. Record the legal basis for each decision, any restriction on the proposed act and the action taken. Use current official sources rather than a saved list from the appointment date.
Technical detail
Sanctions law can also impose restrictions beyond financial asset freezes. The guide is an overview of financial sanctions; the relevant regime and activity may require other official guidance.
England and Wales: source route
The AML framework is UK-wide. In England and Wales, identify the insolvency procedure and the office-holder’s powers under the Insolvency Act 1986 and applicable Rules when investigating transactions or handling assets. Those powers do not remove separate AML obligations.
Sources & review
Read the source in its own context. Legislation may contain commencement provisions and changes not yet applied to the displayed text. Professional guidance is identified separately from law.
Initial source-based editorial review: 26 Oct 2026. Next scheduled review: 26 Nov 2026. Substantive changes are reviewed before publication.
Added in the practice and regulation expansion requested on 26 October 2026. Primary-source editorial check; this is not independent professional approval. Future measures are distinguished from provisions in force.
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