OFSI updates on the UK’s post-Brexit sanctions regime

With less than three weeks left until the Brexit transition period ends at 11pm on New Year’s Eve, The Office of Financial Sanctions Implementation (OFSI) has highlighted upcoming changes to the UK sanctions framework. 

This OFSI blog explains what firms need to know, what’s has already been implemented, and what actions firms need to take now.

The Sanctions and Anti-Money Laundering Act 2018 provides the legal framework within which the UK can impose, update, and lift sanctions autonomously. This new framework is intended to deliver substantially, if not necessarily exactly, the same policy effects as before. The process of recreating the existing regimes in UK law has required more specific drafting, so it’s important to check the new legislation carefully to make sure your activities remain compliant. 

A list of the UK regimes, legislation and guidance already made in preparation for the end of the transition period is available on the Foreign, Commonwealth and Development Office website. Meanwhile OFSI will continue to maintain consolidated lists of financial sanctions targets on its gov.uk webpages. These will be updated with information from Foreign, Commonwealth & Development Office’s UK Sanctions List at 11pm on 31 December, at which time the FCDO will also update the UK Sanctions List.

From a compliance perspective, firms should continue to use the form on the OFSI website to report any suspected breach of financial sanctions. This again will be updated as the transition period ends, with OFSI accepting submissions as usual. The maximum penalties for breaching the financial sanctions remain unchanged.

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