On 21 March 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) published its 2023-2024 annual review (see here).
The report summarises OFSI’s activities for the 2023-24 financial year in the context of its aim to “Engage, Enhance, Enforce”. This involves industry engagement to improve understanding of UK sanctions, enhancing stakeholder service through increased hiring and investment, and enforcing compliance using a full range of actions and improved processes.
Although OFSI’s report indicates that the authority’s focus has largely been on Russia, the report also emphasises the importance of compliance with sanctions regimes targeting other jurisdictions. We have summarised below some of the key points highlighted in the report.
OFSI Resourcing Statistics
- Increased support from the UK government, including as part of the Economic Deterrence Initiative, has led to OFSI expanding to 135 staff. The report notes that since Russia’s invasion of Ukraine to the end of 2023-24, OFSI has “increased resource in its licensing and enforcement teams by approximately fourfold, and nearly doubled the size of its guidance and engagement function”.
- This expansion was complemented by investments in advanced data analytics, cryptocurrency investigation capabilities, and access to specialist platforms for corporate records and data sets, aimed at enhancing UK sanctions implementation.
Investigations and Enforcement
- Following last year’s report, where OFSI Director Giles Thomson noted the transition to a “proactive” enforcement model, in 2023-24, OFSI opened a record 396 cases and closed 242, up from 74 closed cases the previous year.
- This “proactive” enforcement model is described by OFSI as being “intelligence led”, involving OFSI “leveraging its data, and its partners’ data, to identify breaches of sanctions”.
- The leading number of suspected breaches recorded is in relation to the UK’s sanctions against Russia (with 347 reports), followed by the UK’s sanctions against Libya (21 reports) and Iran (9 reports).
- In August 2024, OFSI issued its first “proactive” monetary penalty to Integral Concierge Services Limited, described in the report as “the first of several cases in [its] pipeline linked to Russia’s invasion of Ukraine” with anticipated further enforcement actions throughout 2025.
Domestic and International Collaboration
- Building on last year’s focus on enhanced partnership with the United States and its Office of Foreign Asset Control (“OFAC”), the 2023-24 report highlights OFSI’s collaboration efforts with authorities in other jurisdictions. The report notes that “[t]he OFSI-OFAC relationship is underpinned by regular engagement throughout the year and at all levels of seniority, reflecting a commitment to strengthening operational collaboration between the organisations”. This includes a secondment programme with OFAC, which “functions as a critical way to share information, expertise, and best practices, and collaborate on projects of common interest, including joint casework”.
- Through the Joint Money Laundering Intelligence Taskforce (JMLIT), which unites law enforcement and the financial sector, OFSI has “issued alerts on sanctions circumvention typologies, red flag behaviours, and suspicious activities”.
- Continuing the emphasis on cooperation with UK partner organisations and OFSI’s intention to “disrupt the evasion of financial sanctions”, the report cites OFSI’s work with agencies such as HMRC, the NCA, FCDO, and FCA.
Licensing
- The report outlines steps taken by OFSI to refine its licensing processes to manage the high demand resulting from sanctions against Russia. In 2023-24, OFSI made 1,401 licensing decisions, up from 503 the previous year.
Engagement with Business
- The report notes OFSI’s efforts to enhance engagement with businesses to provide greater clarity and certainty. This includes launching OFSI’s Frequently Asked Questions and industry guidance on the Oil Price Cap.
