- continued reform of corporate criminal
Beyond Sanctions: Key considerations for financial services firms
FCA speech – How to change in response to changing threats

- If you work on the first line of defence, how
Are your due diligence measures fit for purpose? OFSI provides further clarity on its assessment of breaches of financial sanctions


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…
Financial crime investigations in the UK: looking ahead to 2023
- a renewed focus on fraud, including further
Individual accountability for directors of non-UK entities under the UK’s Russian sanctions regime
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…
New FCA webpage on side pockets

On 8 September 2022, the FCA published a new webpage on side pockets. The new webpage follows the FCA’s July 2022 Policy Statement on side pockets and discusses at a high level how they work and what investors can expect.
Reporting to OFSI: what do I need to do ?
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 …
OFSI updated guidance on the general principles for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018
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.
European Commission updates FAQs on asset freeze and prohibition to make funds and economic resources available

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…
OFSI updates licensing timeframes in its general guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018
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…