On 14 December 2023, the Office of Financial Sanctions Implementation (“OFSI”) 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 £145…
On May 2, 2019, the US Office of Foreign Assets Control (“OFAC”) published A Framework for OFAC Compliance Commitments (the “Framework”). This long-awaited document sets out OFAC’s expectations for effective sanctions compliance programs (“SCPs”). 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. Indeed, we are already seeing OFAC settlements conditioned on compliance enhancements reflected in the Framework.