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Financial crime

OFSI (Office of Financial Sanctions Implementation)

The Office of Financial Sanctions Implementation (OFSI) is the part of HM Treasury responsible for implementing and enforcing UK financial sanctions. It maintains the UK consolidated list of sanctioned persons and entities, issues guidance and licences, and investigates and enforces breaches of the sanctions regime.

The Office of Financial Sanctions Implementation (OFSI) is the part of HM Treasury responsible for implementing and enforcing UK financial sanctions. OFSI maintains the UK consolidated list of sanctioned persons and entities, provides guidance to regulated firms on their obligations, considers licence applications for exceptions, and investigates and enforces breaches. Every regulated firm with exposure to cross-border transactions must ensure it screens against the OFSI consolidated list and other applicable UK sanctions regimes.

Why OFSI matters

Breaching UK financial sanctions is a criminal and civil offence. The regime can apply on a strict-liability basis, meaning the firm may be in breach even without intent. OFSI has the power to impose significant civil monetary penalties. The Russia-related sanctions designations since 2022 have dramatically expanded the scope of practical sanctions compliance for UK firms.

Who it applies to

All UK regulated firms, with the most acute obligations on those with international operations, cross-border payments or relationships with non-UK entities.

PEP, EDD and beneficial ownership.

Frequently asked questions

What is OFSI?
OFSI, the Office of Financial Sanctions Implementation, is part of HM Treasury and is responsible for implementing and enforcing UK financial sanctions. It maintains the UK consolidated list of sanctioned persons and entities, provides guidance to firms, considers licence applications, and investigates and penalises breaches of the financial sanctions regime.
What happens if a firm breaches UK financial sanctions?
Breaching UK financial sanctions is a criminal and civil offence, and the regime can apply on a strict-liability basis, meaning a firm may be in breach even without intent. OFSI can impose significant civil monetary penalties and refer cases for criminal prosecution, so firms must screen against the OFSI consolidated list.

Reviewed by Margaret Hassett

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