On 2 May 2024, HM Treasury updated its guidance on financial sanctions enforcement and monetary penalties.

The Office of Financial Sanctions Implementation (OFSI) will now always apply the most recent iteration of its enforcement guidance to cases. Chapter 3 of the guidance, which covers case assessment, gives details on the change. Other updates

On 1 May 2024, the Office of Financial Sanctions Implementation (OFSI) published Frequently Asked Questions. The FAQs constitute a new form of additional guidance aimed at providing technical support to industry partners and the public. They are designed to offer easily accessible responses to commonplace compliance questions. This may be through navigating

In March 2022, a year after Russia’s invasion of Ukraine, the Treasury Committee published a report regarding the development, implementation and impact of economic sanctions on Russia (the 2022 Report).  In brief, the 2022 Report found that:

  • Despite its own production of
  • On 21 December 2023, the European Banking Authority (EBA) issued a public consultation on two sets of guidelines on internal policies, procedures and controls to ensure the implementation of EU and national restrictive measures.

    One set of draft guidelines is addressed to financial institutions and prudential supervisors and sets common, regulatory expectations regarding

    On 2 December 2022, HM Treasury published updated statutory guidance to assist in the implementation of, and compliance with the Russia (Sanctions) (EU Exit) Regulations 2019. The guidance has been updated to clarify the application of the prohibition on provision of technical assistance, financial services or funds related to G7 dependency and further goods.

    On 4 May 2022, the UK Government announced a ban on services exports to Russia, and as of 21 July 2022 that ban is now in force by virtue of regulation 54C of The Russia (Sanctions) (EU Exit) Regulations 2019 (as amended by The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022) (the Regulations

    The Economic Crime (Transparency and Enforcement) Act 2022 (the Act), which came into force in March 2022, aimed amongst other things, to give UK sanctions authorities greater power to take enforcement action and impose penalties on persons that breach sanctions restrictions, through the introduction of a “strict liability” test. These new powers of the UK’s

    On 12 July 2022, there was published the ‘Financial Sanctions Evasion Typologies: Russian Elites and Enablers’ by the National Economic Crime Centre, a multi-agency unit in the National Crime Agency, and HM Treasury’s Office of Financial Sanctions Implementation, working in conjunction with law enforcement and financial sector partners as part of the Joint

    On 11 July 2022, there was published a letter by the Financial Conduct Authority (FCA) to the House of Commons’ Treasury Committee regarding the regulator’s financial sanctions responsibilities.

    In the letter, the FCA addresses its responsibilities for financial sanctions and covers the following topics:

    • The current level of awareness and compliance at authorised firms of