Frozen assets reporting for 2025 and 2026

You must report if you hold or control funds or economic resources owned, held or controlled by a designated person.

You don’t need to report accounts blocked only by other national authorities, such as OFAC.

You don’t need to send a nil return if you don’t hold or control any frozen assets.

If you submitted a report for 2025 and no longer hold those assets, you must submit a nil return.

2025 report: 1 January 2025 – 30 September 2025. Value assets as at close of business on Tuesday 30 September 2025. Use the 2025 template. 2025 FSIU Frozen Assets Reporting Template.xlsx

2026 report: 1 October 2025 – 30 September 2026. Value assets as at close of business on Wednesday 30 September 2026. Use the 2026 template. 2026 FSIU Frozen Assets Reporting Template.xlsx

1. all funds or economic resources frozen in Bermuda
2. funds or economic resources overseas that are subject to Bermuda financial sanctions legislation
3. the nature and amount or quantity of each asset
4. the value in US dollars, including for shares, securities, and other debt or payment instruments, and anything in a foreign currency

Funds and economic resources include cryptoassets. For full definitions, see the Annex to the Financial Sanctions Notice.

1. Identify all funds and economic resources you hold or control that are owned, held or controlled by a designated person.
2. Download the template for each reporting period.
3. Complete the templates, giving values as at the dates above.
4. Email them to fsiu@gov.bm by Monday 30 November 2026.

Make one person in your organisation responsible for collating and sending your returns, to avoid duplication.

Don’t wait for the annual deadline. Report newly frozen funds or economic resources to the FSIU immediately, using a Compliance Reporting Form.

Separately from annual reporting, you must:

1. check whether you hold accounts, funds or economic resources for anyone on the UK Sanctions List, or for entities they own or control
2. freeze them
3. not deal with them or make them available to or for the benefit of a designated person, unless a licence has been issued or an exception applies
4. report any findings to the FSIU, including what your knowledge or suspicion is based on
5. provide any information the FSIU requests about frozen funds or economic resources

Failing to comply with financial sanctions legislation, or trying to get around it, is an offence.