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 billion at the time of Russia’s invasion of Ukraine have been sanctioned. OFSI also declares that as of October 2023, £22.7 billion of Russian assets were reported frozen since February 2022.

Enforcement and Implementation

OFSI director Giles Thomson notes in the foreword that OFSI is “transitioning to a proactive enforcement model”. The report further states that “OFSI is undertaking a large number of complex investigations into Russia related breaches, which it anticipates will lead to public enforcement action”.

The report details that OFSI recorded 473 suspected breaches of financial sanctions (excluding oil price cap and counter-terrorism breaches) over the financial year, of which:

  • 7 warning letters were issued in response to confirmed breaches that OFSI did not consider warranted public enforcement action;
  • 2 monetary penalties were issued; and
  • 51 cases were closed with no further action, 44 of which related to Russia-related sanctions breach reports.

Licensing decisions were taken on 503 cases by OFSI’s Licensing Unit over the financial year. In 283 cases a licence was granted and in 9 cases the application was rejected. The remaining decisions are categorised as ‘applications withdrawn’, ‘licence not required’, ‘insufficient evidence/information’ or ‘other’.

This volume of activity has led OFSI to significantly expand. In the 2022-2023 financial year, OFSI increased resource in its enforcement team by 175%, licensing team by 160% and guidance and engagement team by 120%.

Looking Ahead

The report states that over the next 12 months, OFSI will move to an increasingly proactive enforcement model and develop its information monitoring and intelligence capabilities, working with strategic partners, law enforcement and industry regulators for high risk and under-reporting sectors. Furthermore, OFSI aims to expand its international engagement by working more closely with OFAC to deliver joint webinars and private sector engagements.  

OFSI also indicates that it intends continue to grow its industry engagement by focusing on a set of priority industries, including “financial services, fintech/crypto, legal, accountancy, property, high-value dealers and NGOs”.

Further details on OFSI’s current activities and recent guidance can be found on its website (available here).



Adeel Haque is an Associate in Baker McKenzie's London office. He is a member of the International Commercial & Trade and Antitrust & Competition practice groups. Adeel qualified in September 2019 and has spent time working in the Firm's Hong Kong office.