On 15 April 2026, the UK Office of Financial Sanctions Implementation (“OFSI”) published a strategy document setting out its intentions for 2026-29, and marking its 10 year anniversary.
The strategy document establishes a framework built around the following pillars:
- Promote – making sanctions rules and expectations clearer to encourage compliance, including through clear guidance, co-operation with other regulators and enforcement agencies in the UK and overseas, and conducting sector-specific engagement;
- Enable – removing friction for legitimate activity, including encouraging engagement and providing compliance advice, as well as enhancing OFSI’s licensing offering;
- Respond – enhancing enforcement, including through better case prioritisation, fast enforcement, and using the entire enforcement toolkit available. This builds upon recent changes to OFSI’s enforcement approach (see our blog post here), and a recent cross-Government policy paper on sanctions enforcement (see our blog post here); and
- Change – embedding lasting behavioural change, including by shaping guidance based upon real-world experience.
In particular, OFSI has set itself a number of KPIs that signal its direction of travel. In particular, these include the following:
- Licensing – OFSI intends to close a minimum of 50% of licensing cases within 6 months of submission.
- Enforcement outcomes – OFSI intends to submit at least 90% of new enforcement cases for decision within 18 months of commencing an investigation.
- Investigation sourcing – OFSI intends to “increasingly pursue intelligence originated case outcomes” in 2027/28 and 2028/29. This builds on OFSI’s existing information streams, including mandatory breach reporting by financial institutions and other businesses.
- Outreach – OFSI intends to conduct sector-specific engagement campaigns, and deliver quarterly joint or cobranded public output with international parties such as guidance, advisories, case studies and public statements. It also intends to measure outcomes through annual surveys.
OFSI has committed to monitor its progress against the KPIs, and to update where there is “meaningful reason to do so”.
The full strategy document has been published here.
