
In February 2025, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a report outlining its assessment of the sanctions-related threats posed to the UK by firms operating in the UK’s financial services sector. As to be expected, the report focuses on the risks associated with transactions since February 24, 2022, when Russia invaded Ukraine and countries around the world, including the UK, responded with an unprecedented expansion of financial sanctions. However, while OFSI acknowledges that compliance with Russia sanctions must remain a priority for UK financial services firms, it simultaneously makes sure to remind firms that they must strictly comply with all UK sanctions, and many of the insights in the OFSI report are of broader relevance to sanctions compliance.
In our two-part article, we first outline the key threats that OFSI identified in its report, and then we set forth the steps that financial services firms can and should take to address those threats when developing or enhancing their sanctions compliance programs.