UK Sanctions Agency Expecting Penalty Decisions in 'Many' Active Cases Next Year
The U.K.’s lead sanctions agency is expecting penalty decisions in a range of Russia-related enforcement actions next year, it said in its annual report released this week.
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The Office of Financial Sanctions Implementation had 240 active cases under investigation as of April, OFSI said in its report covering 2024-2025. A portion of those cases are linked to potential violations stemming from Russia’s invasion of Ukraine in 2022, and they “may result in public enforcement action,” it said. “Many cases under active investigation are expected to come to decision points in 2025-26.”
OFSI used its annual report to tout its enforcement over the last year, saying it issued 57 monetary penalties, warning letters, disclosures and referrals, mostly targeting companies operating in the financial services and legal sectors. It also created a new “dedicated Compliance Enforcement team” to look for violations of specific and general licenses issued by OFSI.
The agency said it takes breaches of licenses “seriously,” and it’s looking to increase enforcement against those violators. “Investigations of licence reporting breaches or inconsistencies have already led to the identification of other breaches and are a method of detecting circumvention,” OFSI said. “This new function has enabled OFSI to address insufficient reporting more robustly and has significantly reduced response times for licence-related enforcement action.”
The agency said Russia-related sanctions enforcement remains a “priority.” It pointed to its $20,000 fine in September 2024 assessed a property management company (see 2409270048) and its $600,000 fine in March put on a Russian subsidiary of British law firm Herbert Smith Freehills, each for violating Russia-related sanctions (see 2503200018).
OFSI Director Giles Thompson said the agency’s enforcement actions during 2024-2025 totaled about 500,000 pounds (about $670,000) and targeted both small and large firms. “OFSI is sending a clear message: breaches will be identified and addressed proportionately and robustly,” he said.
OFSI also said it’s relying more on its own intelligence gathering as opposed to voluntary disclosures. The agency said it opened 151 cases in 2024-2025 from “non-self-reported sources,” an increase from 108 the previous year.
The agency also noted that about 37 billion pounds' (about $50 billion) worth of assets were reported as frozen to OFSI in 2024-2026, a “significant increase” from the 24.4 billion pounds' (about $32 billion) worth from the previous financial year. It specifically said it saw double the amount of reported Russia-related frozen assets.
In 2024-25, OFSI issued 19 general licenses and processed 904 specific licensing decisions, up from 16 general licenses and down from 1,401 decisions the previous year. But OFSI saw an uptick in its proportion of approved licenses, granting about 52% of licenses in 2024-2025 (471 out of a total of 904) compared with a roughly 25% approval rate the previous year (379 out of 1,401).