On 15 April 2026, the Office of Financial Sanctions Implementation (OFSI) published its strategy for 2026 – 2029 to ensure UK financial sanctions remain effective, resilient and impactful.
The aim of the strategy is to deliver three key outcomes: an enhanced understanding of threats grounded in data; high quality licensing, enforcement and compliance
In parallel with shifting foreign policy objectives and geopolitical change, we are seeing a wave of regulatory action concerning sanctions across the United States, Canada, the European Union and the United Kingdom. Our international trade and sanctions team outlines some of the key developments below, including enforcement and key jurisdictions targeted by authorities.
United States
On 16 October 2025, the European Securities and Markets Authority (ESMA) issued its second consolidated report on sanctions.
In 2024, more than 970 administrative sanctions and measures were imposed across Member States in financial sectors under ESMA’s remit. The number of administrative sanctions and measures remained stable compared to 2023. Overall, the
On 2 September 2025, the Home Office published its outcomes progress report on the Economic Crime Plan 2 (ECP2), which was published in March 2023 and set out how public and private sectors would cut economic crime, protect national security and support the UK’s economic growth. The report provides a summary of key
On 21 July 2025, HM Treasury published a report which outlines the Office of Financial Sanctions Implementation’s (OFSI) assessment of threats to sanctions compliance involving UK cryptoasset firms since January 2022. Among other things the report notes that it is almost certain that UK cryptoasset firms have under-reported suspected breaches of financial sanctions
On 14 November 2024, the European Banking Authority (EBA) issued two sets of final guidelines that, for the first time, set common EU standards on the governance arrangements and the policies, procedures and controls financial institutions should have in place to be able to comply with the EU and national restrictive measures.
First
On 10 May 2024, the UK government hosted a senior US government delegation for the second United States-UK Strategic Sanctions Dialogue. A press release was issued, including a joint statement which outlined how the talks delivered on the commitment under the 2023 Atlantic Declaration for a Twenty First Century US-UK Economic Partnership to strengthen coordination
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