On 15 October 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) published its 2024-2025 annual review (see here). The report summarises OFSI’s activities for the 2024-2025 financial year and explains that the authority’s work has been centred around three pillars: compliance, capability, and enforcement. We have summarised below some of the key points highlighted in the report.
Investigations and Enforcement
- OFSI continued to record a high volume of cases in 2024-25, recording 394 suspected breach cases and closing 214 cases. This follows a record-high 396 cases being opened in 2023-2024.
- The vast majority of suspected breaches recorded relate to the UK’s sanctions against Russia (329 reports), followed by global anti-corruption (19 reports), and the UK’s sanctions against Libya (18 reports).
- Following the publication in May 2025 of conclusions from a cross-government review of UK sanctions implementation and enforcement, OFSI’s report notes that “the Government is committing to do more to make compliance easier for UK industry, to deter non-compliance and to make sure the right powers and capabilities are in place to enforce sanctions breaches“.
Licensing
- OFSI issued 19 general licences and processed 904 specific licensing decisions during the year. The report highlights improvements that OFSI has made to streamline licensing processes and to improve transparency such as enhanced guidance and updated Frequently Asked Questions. In addition, new online forms and a licensing aftercare service have been introduced to support applicants. The report highlights a “significant improvement” in OFSI’s timeframes for issuing licensing decisions.
Threat Assessment Reports
- The report outlines that OFSI published sector-specific Threat Assessment Reports during the year, including for financial services, legal services, and cryptoassets. These reports are intended to help firms identify red flags and strengthen compliance, and can be found here.
International Collaboration
- Continuing the emphasis on collaboration with the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the report highlights the signing of the OFSI-OFAC Memorandum of Understanding – OFSI’s first such agreement with an international partner.
- More broadly, OFSI participated in over 210 engagements across 44 jurisdictions during the year, reinforcing its cooperation with the EU and other partners.
Legislative Enhancements
- The report highlights the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024, which were introduced in November 2024. These regulations contain a range of measures aimed at improving enforcement powers, licensing efficiency, and reporting requirements. You can read more in our blog post.
Looking Ahead: Strategy Refresh and 10-Year Anniversary
- As OFSI approaches its tenth anniversary in 2026, it plans to refresh its strategy to reflect lessons learned and future challenges. A public consultation on improving civil enforcement processes closed in October 2025, with reforms expected in the coming year.
