Beyond Sanctions: Key considerations for financial services firms

In line with indications that it will prioritise enforcement in the coming year, the Office of Financial Sanctions Implementation (OFSI) has expanded its enforcement guidance concerning the approach it takes when assessing potential breaches of financial sanctions.

Earlier this month, OFSI amended its “OFSI enforcement and monetary penalties for breaches of financial

In addition to the obligations on regulated firms to comply with applicable sanctions regimes, individuals also need to be aware of their own compliance with sanctions restrictions. From a territorial perspective, individuals must comply with the sanctions regimes in their home jurisdiction wherever in the world they are located — for example, EU, UK and

On 30 August 2022, the Office of Financial Sanctions Implementation (OFSI) published a blog entitled ‘Reporting to the OFSI: what do I need to do?

The blog describes what companies’ reporting obligations are under UK financial sanctions legislation and how they can be met. It also sets out high level examples.

In

On 30 August 2022, the Office of Financial Sanctions Implementation (OFSI) published updated general guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018. Chapter 5 of the general guidance dealing with reporting obligations has been expanded.

On 30 August 2022, the European Commission updated their FAQs on asset freeze and prohibition to make funds and economic resources available.

The FAQs have been updated to include the following question and answer:

Does a listing affect the status of a beneficial owner of a legal person ?

EU sanctions are temporary measures that

On 28 July 2022, the Office of Financial Sanctions Implementation (OFSI) updated its general guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018. The guidance outlines firms’ obligations under financial sanctions, as well as OFSI’s approach to licensing and compliance issues. It takes into account relevant case law and guidance