The OFSI has published its first sanctions Threat Assessment Report, published as the first in a series of sector-specific assessments addressing threats and vulnerabilities relating to UK financial sanctions. This follows OFSI’s commitment under the Economic Crime Plan 2 to publish sectoral sanctions threat assessments, intended to assist stakeholders in key UK sectors as part of a broader risk-based approach to sanctions compliance.
This first sector-specific report related to the financial services sector. Since Russian invaded Ukraine in February 2022, the UK sanctions landscape has changed significantly as a result of the subsequent implementation of unprecedented financial sanctions on Russia by the UK Government and international partners.
- This report outlines OFSI’s assessment of threats to sanctions compliance involving UK financial services firms since February 2022
- UK financial sanctions legislation applies to all persons in the UK and UK persons wherever they are in the world. Relevant Firms, as defined in legislation, comprise most of the UK financial services sector (further information on relevant firms can be found here). ‘Relevant Firms’ includes all firms which hold FCA Permissions.
- Of all the suspected sanctions breaches reported to OFSI since February 2022, UK financial services firms have reported over 65%.
- Of those financial services-related reports, over 80% were from Banks or non-Bank payment services providers (NBPSPs), with only 4% coming from the insurance sector.
- The report sets out some key observations, and covers a number of topics with case studies.