Frozen asset reporting: New requirement
The UK Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024 amended the sanctions regimes to introduce a new reporting obligation on all persons that hold funds or economic resources owned, held, or controlled by a Sanctioned Person.
On 6 November 2025, the FRA published a notice in relation to frozen asset reporting clarifying the extension of this frozen asset reporting requirement to the Cayman Islands. The notice is available here.
What does your entity need to do under the existing sanctions regimes?
All Cayman Islands entities should:
- consider whether such entities hold or control any funds or economic resources owned, held, or controlled by a person listed as asset freeze targets on the UK Sanctions List, or any entity owned or controlled by such a person (Sanctioned Person);
- freeze such funds or economic resources, including any accounts;
- refrain from "dealing" (as broadly defined) with the funds or economic resources or making them available directly or indirectly to, or for the benefit of, sanctioned persons or entities they own or control, unless licensed by the Governor or an exception applies;
- report any findings to the FRA at financialsanctions@gov.ky, together with any additional information or other matter on which the knowledge or suspicion that the funds or economic resources are owned, held or controlled by a Sanctioned Person is based, by completing and submitting a Compliance Reporting Form; and
- provide any information concerning the frozen funds or economic resources of sanctioned persons that the FRA may request.
What does your entity need to do under the new frozen asset reporting requirement?
If a Cayman Islands entity holds or controls any funds or economic resources owned, held, or controlled by a Sanctioned Person, it must now provide an annual frozen assets report to the FRA with details of these assets in addition to the existing requirements outlined above. If your entity has, or should have, reported frozen assets to the FRA in a Compliance Reporting From, it will likely also now have to file annual reports.
However, there is no need for an entity which does not hold or control funds or economic resources, owned, held, or controlled by a Sanctioned Person to provide a nil return to the FRA. This may be applicable if you have filed a Compliance Reporting Form in relation to sanctioned persons but were not holding or controlling the frozen assets in question.
The annual report needs to include details of all funds or economic resources frozen under the UK sanctions regimes, regardless of whether the Cayman Islands entity holds or controls them in the Cayman Islands or overseas. Assets frozen solely in response to the financial sanctions regimes of other jurisdictions do not need to be reported to the FRA.
What is the timing?
If required, your entity must file a report to the FRA no later than Sunday 30 November 2025.
Your entity should report the nature and amount or quantity of the frozen assets as of Tuesday 30 September 2025. If it is holding shares, securities, or other debt or payment instruments as frozen assets, it will need to provide the USD value at 30 September 2025.
What should entities do next?
Identify all the frozen assets the entity currently holds or controls and complete the template form.
The template form is available here and we have included the required datapoints below.
Datapoints to be reported:
- Reporting Entity
- Submitted on behalf of
- Cayman Fund / Entity
- A/C Name
- Type of Asset
- Asset Freeze Target
- OFSI Group ID
- UK Sanctions List Unique ID
- Regime
- Country fund are held in
- A/C Holding Institution / Firm
- A/C or Card Number
- Sortcode
- Additional Institutions
- Currency
- Currency Rate
- Credit Balance/Asset Value in original currency
- Debit Balance / Asset Value in original currency
- Notes
- Date A/C opened
If you have any questions, Walkers has a global team of dedicated regulatory lawyers who can advise your entities on the new reporting requirements. We have long experience of advising on financial sanctions compliance.
