A View From The Exchange: OFSI 's evolving sanctions framework

Earlier this month, the UK's Office of Financial Sanctions Implementation (OFSI) published its annual review for 2024-2025. We provide an update on the key takeaways:

Expanding economic reach of UK sanctions

In the twelve months to April 2025, OFSI enhanced both the scale and reach of the UK's sanctions regime:

• across all regimes, £37 billion worth of assets were reported as frozen to OFSI - a 52% increase from the previous financial year

• almost half of the total – £22.5 billion – was attributable to Russia

• designations on OFSI's Consolidated List rose to more than 4,700 individuals, entities and vessels, with almost half linked to Russia.

Proactive, intelligence-led enforcement

There was also an uptick in OFSI's enforcement activity. In 2024-25, the watchdog closed just over 200 investigations and opened almost 400 new ones, similar to the previous year's figures. Significantly, the majority of active cases now stem from OFSI's own intelligence or third-party information, rather than self-disclosures. This marks a shift towards proactive, data-driven detection. A dedicated Compliance Enforcement team was also established to scrutinise licence reporting.

OFSI concluded 57 enforcement actions (including fines, warning letters and public disclosures) during the year, with the financial services and legal sectors most affected. Its largest civil fine in 2024-25 – imposed on a law firm in March 2025 – related to six payments totalling £3.9 million made by the firm during the rapid wind-down of its Russian office. OFSI has highlighted the fine as a cautionary tale for senior individuals failing to follow sanctions screening and due diligence measures.

New guidance

For firms keen to stay on the right side of these rules, OFSI has strengthened its compliance toolkit. A revamped website, a consolidated e-alert service, and the publication of 145 detailed FAQs provide direction on complex issues such as ownership and control, oil price cap obligations, and licensing procedures. Sector-specific threat assessments—starting with financial services and expanding to legal, property, art and crypto—set out red flags and recommended controls. The licensing function itself has become markedly faster and more transparent, with 19 general licences and more than 470 specific licences issued during 2024-25.

Taken together, these developments demonstrate OFSI's evolution ahead of its upcoming 10-year anniversary: the UK sanctions architecture is broader, enforcement is more assertive, and guidance is more practical. Businesses should treat this as a clear signal to refresh screening systems, test control frameworks and ensure suspected violations are escalated to legal and compliance teams.

Other author: Catherine Lillycrop, Associate