On 14 December 2023, the Office of Financial Sanctions Implementation (āOFSIā) published its 2022-2023 annual review (see here). The review summarises OFSI’s activities over the 2022-2023 financial year and looks ahead at trends and OFSI’s priorities for the next year. Russia Sanctions The report has a particular focus on the UK’s expanded Russia sanctions regime, stating that by 31 March 2023, “130 oligarchs and family members” who had a combined net worth of around Ā£145…
On May 2, 2019, the US Office of Foreign Assets Control (“OFAC”) published A Framework for OFAC Compliance Commitments (the “Framework”).Ā This long-awaited document sets out OFAC’s expectations for effective sanctions compliance programs (“SCPs”). Ā While the broad elements of the Framework should be familiar to seasoned compliance practitioners, the details highlight the specific significance that OFAC attaches to SCPs in resolving enforcement actions. Ā Indeed, we are already seeing OFAC settlements conditioned on compliance enhancements reflected in the Framework.