UK OFSI Blog

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.