UK OFSI Strategy 2026-2029 Based on PERC Framework
Summary
The UK Office of Financial Sanctions Implementation (OFSI) has published its strategy for 2026-2029, structured around the PERC framework: Promote, Enable, Respond, and Change. The strategy outlines targeted engagement campaigns for priority sectors, aims to close 50% of licensing cases within six months, and commits to submitting 90% of new enforcement investigations for decision within 18 months. OFSI also targets quarterly joint output with international partners and enhanced digital services including AI-enabled workflows.
What changed
The UK OFSI published its 2026-2029 strategy document, replacing or superseding any prior strategic framework. The strategy is organized around four pillars: Promote (shaping expectations through targeted sector campaigns and international partnerships, targeting quarterly co-branded outputs), Enable (streamlining licensing with a six-month closure target for 50% of cases, modernizing digital services including AI-enabled workflows), Respond (prioritizing evidence-led enforcement with 90% of investigations submitted for decision within 18 months, targeting intelligence-originated case outcomes), and Change (embedding lasting behaviour change through feedback loops and practical implementation support).
Financial institutions subject to UK financial sanctions must anticipate increased engagement from OFSI under the Promote pillar, faster licensing decisions under the Enable pillar, and more proactive enforcement timelines under the Respond pillar. Firms should review their sanctions compliance programmes against OFSI's stated priorities and consider early engagement with OFSI on complex scenarios, as the strategy explicitly encourages and rewards such proactive outreach. The digital transformation commitments may also affect how firms interact with OFSI for reporting and licensing.
Archived snapshot
Apr 20, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 20, 2026
UK OFSI strategy for 2026–2029
The UK Office of Financial Sanctions Implementation (OFSI) has published its strategy for 2026–2029. The strategy is based around the "Promote, Enable, Respond and Change" (PERC) framework:
- Promote: To shape expectations and set the standard, OFSI will run targeted campaigns for priority sectors; publish clear guidance products and assessments showing what non-compliance is and how to avoid it; and work with domestic and international regulators to promote consistency. "Promote" key performance indicators (KPIs) include sector-specific engagement campaigns and delivering joint or co-branded public output (such as joint guidance, public statements, case studies or advisories) with international partners on a quarterly basis.
- Enable: OFSI will remove friction for legitimate activity and support sanctions compliance behaviour that is fast, predictable and scalable by encouraging early engagement from firms to address risks or uncertainties, providing direct, practical compliance advice on complex scenarios, and maintaining an effective and regularly updated licensing offer with high, publicised service standards. Engagement will be modern and digital by default, including online services, reporting and forms, supported by enhanced data use, data sharing and AI enabled workflows. The "enable" KPI is to close 50% of licensing cases within six months.
- Respond: OFSI will protect the system through visible, timely and proportionate enforcement by prioritising evidence led cases that target the highest risks. It will use analytics to identify networks, typologies and repeat behaviours, deploy its full toolkit across financial sanctions, and ensure public enforcement outcomes are fast and as impactful as possible. OFSI will also robustly defend litigation, strengthen the legislative framework, apply best practice case management, and work closely with UK regulators and enforcement partners to ensure complementary action. "Respond" KPIs include submitting 90% of new enforcement investigations for decision within 18 months of commencement of investigation, and increasing intelligence-originated case outcomes in financial year 2027/28 and 2028/29.
- Change: To embed lasting behaviour changes across the financial sanctions' system and all of its actors, OFSI will use feedback loops (including guidance and lessons learned, and learning from industry and government partners), ensure all new and updated sanctions enable practical implementation, both domestically and internationally, and use AI-enabled workflows to enhance its services. "Change" KPIs include submitting 90% of new enforcement investigations for decision within 18 months of commencement and increasing intelligence led case outcomes in financial year 2027/28 and 2028/29. [View source.]
;) ;) Report
Latest Posts
- UK FCA consults on cryptoasset perimeter guidance
- UK OFSI strategy for 2026–2029
- Eurosystem's response to EC consultation on the competitiveness of the EU banking sector
- EC adopts Delegated Regulation setting RTS on order execution policy
- Disputes 101 – Parent company liability in its various forms See more »
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
Attorney Advertising.
©
A&O Shearman
2026
Written by:
A&O Shearman Contact + Follow
PUBLISH YOUR CONTENT ON JD SUPRA
- ✔ Increased readership
- ✔ Actionable analytics
- ✔ Ongoing writing guidance Join more than 70,000 authors publishing their insights on JD Supra
Published In:
Artificial Intelligence + Follow Economic Sanctions + Follow Enforcement Actions + Follow Office of Financial Sanctions Implementation (OFSI) + Follow Regulatory Oversight + Follow UK + Follow Finance & Banking + Follow International Trade + Follow
A&O Shearman on:
Solve with 2Captcha
Solve with 2Captcha
Named provisions
Related changes
Get daily alerts for JD Supra Finance & Banking
Daily digest delivered to your inbox.
Free. Unsubscribe anytime.
Source
About this page
Every important government, regulator, and court update from around the world. One place. Real-time. Free. Our mission
Source document text, dates, docket IDs, and authority are extracted directly from A&O Shearman.
The summary, classification, recommended actions, deadlines, and penalty information are AI-generated from the original text and may contain errors. Always verify against the source document.
Classification
Who this affects
Taxonomy
Browse Categories
Get alerts for this source
We'll email you when JD Supra Finance & Banking publishes new changes.
Subscribed!
Optional. Filters your digest to exactly the updates that matter to you.