As discussed in our recent blog post (available here), the UK Office of Financial Sanctions Implementation (“OFSI”) has updated its guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”, available here), to include a number of paragraphs setting out OFSI’s expectations around the nature and type of due diligence that companies should undertake when assessing whether an entity is owned or controlled by one or more designated persons, for sanctions purposes.

Given the significant increase in the volume of sanctioned individuals and entities (in particular under sanctions targeting Russia), and in light of increasingly complex ownership and governance structures that companies can be subject to, OFSI’s guidance provides companies with important direction on how to conduct appropriate, risk-based sanctions due diligence. 
In our latest Sanctions On-Demand Webinar, we discuss:

  • OFSI’s new guidance on ownership and control, including a focus on due diligence assessing (i) formal ownership and control mechanisms, (ii) influence / de facto control, and (iii) ongoing monitoring;
  • the UK’s strict liability enforcement framework for breaches of financial sanctions, and the impact that this has on due diligence considerations;
  • a comparison with EU and US approaches to ownership and control for sanctions purposes; and
  • practical tips for clients around due diligence.

Click HERE to watch this on-demand webinar now.

If you have any follow up questions in respect of the webinar, please click here to reach out to our team.


Julian Godfray is a senior associate in Baker McKenzie's Competition, Trade and Foreign Investment Department in London. Julian works in particular in the Firm's market-leading International Trade and Compliance & Investigations practices. Julian joined the Firm as a trainee in September 2014, and qualified in September 2016. Julian has been seconded to two FTSE 100 clients during his time at the Firm, including in the ethics and compliance team of one client. Julian has also completed secondments to the Firm's European and Competition Law Practice in Brussels in 2016, and more recently to the Firm's Madrid office in 2020, working as part of the Firm's trade compliance practice in Spain.