New FAQ added – Asset freeze exception: crediting interest or other earnings on a frozen account

OFSI has published a new FAQ (203) clarifying whether a relevant institution may credit interest or other earnings accruing on one frozen account into a separate frozen account held for the same designated person.

The FAQ explains that regulation 58(3) of the Russia Regulations, and equivalent provisions in other regimes including the counter-terrorism regimes, only permits a relevant institution to credit a frozen account with interest or other earnings due on that account. The exception only applies where the interest or other earnings are credited to the same account on which they accrue.

The FAQ also applies where a separate frozen account has been nominated to receive the interest or earnings. Relevant institutions should consider whether a licence is required before making such payments.

The FAQs respond to stakeholder queries and aims to support a consistent understanding of the regime, helping to reduce the risk of circumvention. We encourage insurers, financial institutions and maritime operators to review the guidance and ensure internal processes reflect these considerations.

and the FAQ:

Asset freeze exception: crediting interest or other earnings on a frozen account 

203. Does regulation 58(3) of The Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”), and its equivalent in other regimes including the counter terrorism regimes permit a relevant institution to credit interest or other earnings accruing on one frozen account into a separate frozen account held for the same designated person?

No. OFSI considers that regulation 58(3) of the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”), and its equivalent in other regimes including the counter terrorism regimes only permits a relevant institution to credit a frozen account with interest or other earnings due on that account. The exception only applies where the interest or other earnings are credited to the same account on which they accrue.

This is the case even where the separate account has been nominated to receive the relevant interest or other earnings or has otherwise been identified as the receiving account of such earnings under the contractual or other arrangements governing the accounts.

Relevant institutions should consider whether a licence is required before making such payments.

Added on: 14 Sep 2026