AML Compliance

Sami Al-Jaburi Added to EU ISIL Al-Qaida Sanctions List

The European Commission published a notice adding Sami Jasim Muhammad Jaata Al-Jaburi to the EU ISIL/Al-Qaida sanctions list via Commission Implementing Regulation (EU) 2026/819. The designation subjects Al-Jaburi to asset freezes and travel bans under Council Regulation (EC) No 881/2002. EU nationals, entities, and financial institutions must freeze any funds or economic resources belonging to, owned, held, or controlled by the designated person.

Al-Khatouni Added to ISIL Al-Qaida Sanctions List Under Regulation 881/2002

The European Commission added Abd El Hamid Salim Ibrahim Brukan al-Khatouni to the ISIL (Da'esh) and Al-Qaida sanctions list via Commission Implementing Regulation (EU) 2026/819. This designation subjects the individual to asset freezes and travel bans under Council Regulation (EC) No 881/2002. EU Member States must implement these restrictive measures immediately.

Director Shares OFSI Ten-Year Anniversary Reflections

OFSI marks its ten-year anniversary with a reflective statement from Director Giles Thomson. Since 2016, OFSI has developed the UK's financial sanctions framework through expanded industry engagement, enhanced general licensing flexibility, and strengthened enforcement capabilities. The office reports £37 billion in frozen assets reported across all regimes in 2024-2025. A new three-year strategy will be published in the coming weeks.

OFSI Updates Licensing Guidance: CDPR Required Above £2M for Law Firms, £1M for Counsel

OFSI has updated its licensing guidance requiring independent Costs Draftsperson's Reports (CDPRs) for legal fees above specified thresholds. Law firms must submit CDPRs when total legal fees exceed £2,000,000 per six-month period per designated person; directly instructed Counsel must submit CDPRs when costs exceed £1,000,000. The thresholds apply cumulatively across all specific licences and applications for each designated person.

OFSI Publishes Seven-Criteria Framework for Prioritising Sanctions Licence Applications

OFSI published its licence prioritisation framework explaining how over 900 annual licensing decisions are categorised as high, medium, or low priority. Applications are assessed against seven criteria including humanitarian purpose, materiality, timing, UK economic impact, administrative burden, reputational/strategic factors, and complexity. The framework aims to provide transparency on how competing demands are managed.

OFSI Analysis: Bank of Scotland £160k Penalty for Russia Sanctions Breach

OFSI published details of a £160,000 monetary penalty imposed on Bank of Scotland Plc (Lloyds Banking Group) for breaching UK Russia financial sanctions. The breach involved a spelling variation of a designated individual's name evading automated screening. OFSI highlighted that weaknesses in screening, escalation procedures and training contributed to the breach, offering lessons for all UK-regulated firms on sanctions compliance controls.

OFSI Call for Evidence on Ownership and Control in Financial Sanctions Regulations

OFSI has launched a call for evidence seeking industry views on how UK financial sanctions ownership and control (O&C) regulations are applied in practice. The evidence call focuses specifically on the 'control' test, where firms report the greatest implementation challenges including legal uncertainty and conflicting interpretations. Responses will inform potential regulatory changes to clarify O&C obligations.

TradeStation Securities Pays $1.1M OFAC Settlement for Sanctions Violations

TradeStation Securities, Inc. agreed to pay $1,110,661 to settle 481 apparent violations of multiple sanctions programs related to Iran, Syria, and Crimea region of Ukraine. The violations occurred during securities transactions between June 2021 and June 2022 due to failures in geo-blocking controls. The settlement reflects non-egregious violations that were voluntarily self-disclosed and significant remedial measures implemented.

U.S. Person Settles Syria Sanctions for $3,777,000

OFAC announced a $3,777,000 settlement with a U.S. person for 20 apparent violations of Syrian Sanctions Regulations between January 2018 and December 2021. The individual provided managerial services to Syrian real estate companies as an executive and board member, including reviewing financial statements, approving expenses, and supervising fee collection. The settlement reflects OFAC's determination that the violations were egregious and not voluntarily self-disclosed.

IMG Academy Settles OFAC Counternarcotics Sanctions Violations for $1.72M

IMG Academy, LLC agreed to pay $1,720,000 to settle potential civil liability for apparent violations of OFAC counternarcotics sanctions. Between 2018 and 2022, IMG Academy entered into annual tuition enrollment agreements with two Specially Designated Nationals sanctioned under the Foreign Narcotics Kingpin Designation Act for ties to a Mexican drug cartel and processed tuition payments for their children. The settlement reflects OFAC's determination that violations were non-egregious, absence of voluntary self-disclosure, but substantial cooperation and remedial measures.