Frozen Asset Reporting (2025 and 2026)
Read the full frozen asset reporting notice
2026 Financial Sanctions Notice - Frozen Asset Reporting.pdf
Frozen assets reporting for 2025 and 2026
If you hold or control funds or economic resources owned, held or controlled by a designated person, the Governor requests a report for each period below. Use the matching template and email it to the FSIU.
SUBMISSION DEADLINE:
Email your completed templates to fsiu@gov.bm by Monday 30 November 2026.
What do they do?
Financial sanctions apply to every person and legal entity operating in Bermuda, and to territory persons wherever they are.
PATI statements
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Check the sanctions lists
Search current UK and Bermuda designations before you transact.
Freeze and report a match
Do not deal with the assets. Report suspected matches to the FSIU straight away.
Apply for a licence
Find the forms and guidance for activities involving frozen assets.
Submit your annual frozen asset report
Send your 2025 and 2026 returns using the templates. The deadline is Monday 30 November 2026.
Designated persons and delisting
Find out who is designated and how a designated person can ask to be removed from a list.
Subscribe to alerts
Get notified when sanctions measures change.
What the rules mean for you
Financial sanctions are used to support international peace and security. They can restrict access to funds, economic resources, financial markets and services.
Always check current legislation.
Guidance explains the FSIU’s approach but does not replace legal advice. Sanctions measures can change.
Who must comply?
All individuals and legal entities within or undertaking activities in Bermuda, plus territory persons and Bermuda ships.
Who is designated?
Since 28 January 2026, the UK Sanctions List is the only UK list. Entities owned or controlled by a designated person are covered too.
If you identify a match
Freeze funds and economic resources immediately, don’t make them available, and report to the FSIU.
Exceptions and licences
Some activities are exempt. Others may proceed only when the FSIU has issued a licence under the applicable regime.
From the FSIU FAQs
Common questions
These summaries help you find the right topic. Read the full guidance and applicable legislation before making a decision.
I have a designated person as a customer – what should I do?
You must freeze (i.e. refrain from dealing with) their assets and report details of the assets to the FSIU using the Compliance Reporting Form.
We are a firm of lawyers acting for a designated person. Do we need a licence?
The provision of legal services does not require a licence. However, the payment of legal fees using frozen funds held on behalf of a designated person does require a licence because this involves dealing with funds that are required to be treated as frozen.
What is the position if a policy holder names a designated person as a beneficiary?
Sanctions prohibit the payment of funds to, or for the benefit of, designated persons. This would, without a licence, prevent the payment of benefits due under a policy to a beneficiary who is a designated person.
Can I make payments to a designated person?
It may be possible to make payments due under contracts, agreements or obligations, which were concluded or arose prior to the date the person was designated. All such payments must be made into a frozen account. This can take place without the requirement of a licence by the FSIU because this is automatically acceptable under the legislation.
Before making such payments you should take steps to establish the facts, and in particular that the account is frozen as required by the sanctions legislation. Primarily you must seek confirmation from the account-holding institution that the account is indeed frozen. All other payments to a designated person require a licence from the FSIU.