Organisation: Office of Financial Sanctions Implementation (UK)

OFSI, FCA outline new information sharing terms

04 December 2023

OFSI eases concerns around sanctioned officials’ control over companies

Lawyers say that OFSI’s guidance on whether companies are considered controlled by sanctioned Russian officials is reassuring, but uncertainty remains around the sufficient level of due diligence required in individual cases.

24 November 2023

OFSI receives over 100 voluntary disclosures of Russia sanctions breaches

06 November 2023

Theatre trips, private school fees and nannies: inside the UK’s effort to curtail oligarchs’ high-rolling lifestyles

Recently disclosed internal guidance reveals how the UK government seeks to limit the types of payments that sanctioned people can justify as meeting their “basic needs”.

03 November 2023

Sabre Corp reports potential sanctions violations to OFSI

US technology company Sabre Corporation, which provides specialist booking software for airlines, has self-reported potential sanctions breaches to the UK’s civil sanctions enforcer.

02 November 2023

Sanctions Docket: Fridman loses OFSI challenge over payment waivers

In the latest round-up of sanctions developments, oligarch Mikhail Fridman has lost a tussle with OFSI for permission to make further payments towards the upkeep of his house, and a US automotive electronics supplier is still waiting to hear from OFAC almost a decade after a voluntary self-disclosure of potential sanctions breaches.

27 October 2023

UK judge’s broad take on ownership and control unsettles practitioners

“Guidance from the government and OFSI will ease enforcement risk but for overarching comfort, the legislation needs to change,” one lawyer said, following a judge’s recent comments that a designated person can control a company through their political influence.

24 October 2023

OFSI, OFAC leaders: don’t be afraid to self-report

“If people are acting in good faith, unless it involves circumstances of what we would describe as fairly egregious – ie wilful, grossly negligent behaviour – we probably aren’t going to be coming after you looking for a massive, hefty penalty,” OFAC director Brad Smith said.

10 October 2023

The GIR Insight Sanctions Roundtable

Featured in The Guide to Sanctions - Fourth Edition

In March 2023 Global Investigations Review held a discussion between panellists in the United Kingdom and the United States to analyse the latest developments since the third edition of the Guide to Sanctions was published. Chaired by Barbara Linney of BakerHostetler and Rachel Barnes KC of Three Raymond Buildings, the panel also included Britt Mosman of Willkie Farr & Gallagher, Richard Weinert of BDO and James Bowen of Linklaters. Participants not only offered insightful overviews of their respective areas of expertise, but also analysed new screening requirements, and even considered the future of sanctions regimes and how ESG issues are rising up the agenda.

06 October 2023

UK Sanctions Enforcement

Featured in The Guide to Sanctions - Fourth Edition

While the legal tools are largely in place, neither OFSI nor HMRC yet has a significant track record of civil enforcement for breaches of financial or trade sanctions, and recent UK prosecutions for sanctions breaches are notable by their absence.

29 September 2023

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