Changeflow GovPing Trade & Sanctions OFSI Strategy 2026-2029 Marks Ten-Year Anniversary
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OFSI Strategy 2026-2029 Marks Ten-Year Anniversary

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Summary

OFSI published its 2026-2029 Strategy marking ten years of operation. The strategy introduces the PERC operating model (Promote, Enable, Respond, Change) to guide its work in keeping UK financial sanctions effective. OFSI commits to clearer guidance, reduced licensing friction, proportionate enforcement, and stronger industry engagement through a feedback-loop approach.

What changed

OFSI has published its 2026-2029 Strategy, outlining an ambitious agenda for its second decade. The strategy introduces the PERC model (Promote, Enable, Respond, Change) as its new operating framework, replacing any prior operating model. Key commitments include making sanctions rules clearer so compliance becomes the norm, reducing friction for legitimate activity through practical guidance and digital-first services, using the full enforcement toolkit to deter non-compliance, and embedding lasting improvements through learning from cases and engagement.

Financial institutions and other entities subject to UK financial sanctions should monitor OFSI communications for updated guidance and be prepared to engage with OFSI through industry feedback channels. The strategy signals OFSI's intent to provide more direct compliance support and use a feedback-loop approach where insights from firm queries and breach reporting will inform where OFSI targets guidance. Firms should strengthen controls, reduce repeat issues, and respond quickly to emerging risks based on OFSI's planned timely updates.

What to do next

  1. Monitor OFSI communications for updated guidance
  2. Review internal sanctions compliance processes against OFSI expectations
  3. Engage with OFSI through industry feedback channels

Archived snapshot

Apr 15, 2026

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This year marks ten years since the Office of Financial Sanctions Implementation (OFSI) was established.

Over the last ten years, OFSI has built stronger capability and confidence, enhancing licensing, enforcement and intelligence, deepening international partnerships, and supporting firms to navigate increasingly complex sanctions regimes.

This Strategy marks the start of OFSI’s second decade, setting out an ambitious agenda for 2026–29 to keep UK financial sanctions effective, resilient and impactful.

At its heart is the new, clear operating model: we will Promote, Enable, Respond and Change (PERC).

  • Promote: make sanctions rules and expectations clearer, so compliance is the norm and non-compliance has visible consequences.

  • Enable: reduce friction for legitimate activity through practical guidance, strong licensing service standards and digital-first services.

  • Respond: act quickly and proportionately on breaches, using the full enforcement toolkit to deter and disrupt non-compliance and circumvention.

  • Change: embed lasting improvements by learning from cases and engagement, strengthening sanctions design and driving sustained compliance cultures.
    We will focus our policy and operational decisions—and our resources—on the areas of greatest impact, grounded in high-quality data, evidence and a stronger understanding of threats, risks and context. We will deliver timely and proportionate licensing, proactive and impactful enforcement, robust and targeted counterterrorism designations, and focused compliance support in our highest impact areas.

We will maintain open, regular engagement with industry to understand how sanctions are operating in practice and to make compliance as clear and workable as possible. We will provide more direct support to industry, to support compliance and reduce friction across the system. We will use a feedback-loop approach: insights from firms’ queries, licensing applications, compliance challenges and suspected breach reporting will inform where we target guidance, which scenarios we prioritise for clarification, and how we design and improve our services. In turn, we will feed learning back to industry through timely updates—such as blogs, FAQs, guidance and lessons learned from enforcement—so that firms can strengthen controls, reduce repeat issues and respond quickly to emerging risks.

We will work in close partnership across government, with regulators and law enforcement, and with the private sector and international allies to strengthen the impact of UK financial sanctions and support effective compliance. We will use structured engagement and information-sharing to build a shared understanding of emerging risks and circumvention typologies, align expectations and guidance where possible, and coordinate action to reduce arbitrage and close gaps. Through these partnerships, we will improve the quality of compliance support, target our operational activity more effectively, and amplify the deterrent effect of enforcement.

The Strategy sets out Key Performance Indicators (KPIs) against which we will monitor our progress under the Strategy. We will report against these in our Annual Review starting with the next publication this Autumn.

Tags: Engagement, Strategy

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About OFSI

OFSI helps ensure financial sanctions are properly understood, implemented and enforced in the United Kingdom. This includes the Oil Price Cap on Russian oil.

OFSI is part of HM Treasury.


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Last updated

Classification

Agency
OFSI
Published
April 15th, 2026
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Banks Financial advisers Investors
Industry sector
5221 Commercial Banking
Activity scope
Financial sanctions compliance Sanctions licensing Breach reporting
Geographic scope
United Kingdom GB

Taxonomy

Primary area
Sanctions
Operational domain
Compliance
Compliance frameworks
OFAC Sanctions
Topics
International Trade Financial Services

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