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re: experience with frozen accounts in the UK?

Dear list members,

I have heard back from someone who has been dealing with FCO and the Bank of
England for some years on the issue of frozen Iraqi assets in the UK.  He
writes that it is reasonably simple to obtain permission to use the accounts
for visits to the UK provided that a proper application is a minimum 1-2
months in advance.

Other use of the funds, possibly including unfreezing bank accounts
generally, is extremely difficult, in part because of some attempts to skirt
the freeze in the early days.  The difficulty may also reflect very tight UK
national legislation, which was written to include "any Iraqi".  The Bank of
England apparently maintains a deep suspicion of any use of any account,
whether or not it can be established that the Iraqi concerned is an
individual without connections to the regime.

Few banks have a clear idea of the procedure to be followed for application
to use the funds.  Many applications have met failure for this reason. Most,
if not all, high street banks may now have centralised such applications
through their central compliance units. The RBS/Natwest system is now
managed from Edinburgh and seems to work well.

It is not generally possible to speak to the Bank of England directly
without personal connections.  The Bank seems to have received a large
number of applications this year, and insists on processing the applications
in strict order; reminders apparently make them grumpy.  They also insist
that the applications should be pursued through the bank holding the
account, so it is important to make sure that you have direct contact with
the compliance unit in the bank in question. It is also necessary to have
some understanding of what the Bank of England can be expected to permit,
and what they will refuse, since if the applications are made within
reasonable parameters and properly documented, they can be processed more
quickly without repeated referrals or requests for information to and from
from Bank of England to high street bank via the compliance unit.


Colin Rowat

work | Room 406, Department of Economics | The University of Birmingham |
Birmingham, B15 2TT, UK | 0121 414 3754 |

personal | 07768 056 984 (mobile) | (707) 221 3672 (US fax) |

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