News & Analysis as of

Office of Financial Sanctions Implementation (OFSI) HM Treasury

A&O Shearman

Losing control: What the Mints Court of Appeal judgment means for UK sanctions

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On 6 October 2023, the Court of Appeal handed down judgment in the case of Mints & ors v PJSC National Bank Trust & anor [2023] EWCA 1332. The judgment confirmed that the UK’s sanctions do not preclude the English courts...more

Akin Gump Strauss Hauer & Feld LLP

Reflections on Restructurings: UK Sanctions Regulator Clears Path for Future Restructurings

On 28 March 2023, the UK Office of Financial Sanctions Implementation of HM Treasury (“OFSI”) issued the “Bond amendments and restructurings for non-Designated Persons” general licence (General Licence - INT/2023/2824812)...more

A&O Shearman

UK Amends License for 30-Day Wind Down of VTB Bank Positions

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The U.K. Office of Financial Sanctions Implementation has published a revised General License under the Russia (Sanctions) (EU Exit) Regulations 2019. The License was first published on February 25, 2022, and allows...more

K&L Gates LLP

Lessons Learned from the OFSI Annual Review: 2020 - 2021

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The UK Office of Financial Sanctions Implementation (OFSI) of HM Treasury (HMT) published its annual review  for 2020 to 2021 on 14 October 2021. The annual review covers a period in which OFSI moved from implementing an EU...more

Pillsbury Winthrop Shaw Pittman LLP

A UK Version of OFAC?

The Office of Financial Sanctions Implementation ramps up enforcement activities in London - A new UK sanctions enforcement body with added civil enforcement tools is ramping up activities. ...more

A&O Shearman

Key Regulatory Topics: Weekly Update - 4 August - 10 August 2017

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Brexit - Brexit – PRA letter to HoC Treasury Committee on firms' contingency planning - On 9 August, the HoC Treasury Committee published a letter (dated 2 August) from Sam Woods, BoE Deputy Governor, Prudential...more

Sheppard Mullin Richter & Hampton LLP

A New Sleuth in Britain: The UK Quietly Empowers a Sanctions Enforcement Office

On April 3, 2017, the UK Treasury’s Office of Financial Sanctions Implementation (OFSI) announced new penalties for economic sanctions violations of £1 Million or 50% of the value of the transaction, whichever is higher. As a...more

Skadden, Arps, Slate, Meagher & Flom LLP

"UK Tracks OFAC Model in Issuing Guidance on Monetary Penalties for Breaches of Financial Sanctions"

As previously reported, the Policing and Crime Act 2017 (the Act) introduced a series of major changes to the U.K. financial sanctions regime. The changes, which came into force on April 1, 2017, included the creation of new...more

Hogan Lovells

UK: Implementation of UN Financial Sanctions Resolution under the Policing and Crime Act 2017

Hogan Lovells on

The Policing and Crime Act 2017 (the “2017 Act“) has introduced measures to strengthen the effectiveness of the UK’s financial sanctions regime. The delay in the implementation of UN sanctions as a result of EU processes is...more

A&O Shearman

New monetary penalty regime for breach of financial sanctions

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A new regime in the UK for punishing individuals or businesses that breach financial sanctions came into force on 1 April 2017. In March 2016 the Office of Financial Sanctions Implementation (OFSI) was formed, as part of...more

A&O Shearman

New monetary penalty regime for breach of financial sanctions

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A new regime in place in the UK for punishing individuals or businesses that breach financial sanctions comes into force from 1 April. In March 2016 the Office of Financial Sanctions Implementation (OFSI) was formed, as part...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Policing and Crime Act 2017: Changes to the UK Financial Sanctions Regime

The policing and crime bill received royal assent on 31 January 2017. The new Policing and Crime Act 2017 (the Act) introduces changes to a wide cross-section of the criminal justice system, including policing powers and...more

A&O Shearman

UK Government Consults on Imposing Financial Penalties for Breach of Financial Sanctions

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The Office of Financial Sanctions Implementation (OFSI), which is a part of HM Treasury, published the UK Government's proposed approach to imposing financial penalties for breach of financial sanctions. OFSI was established...more

A&O Shearman

UK Enforcement Of Financial Sanctions Likely To Rise

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The new UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury (HMT) opened on 31 March 2016. This may signal a shift towards more aggressive enforcement of the financial sanctions regime in the UK. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

"UK Establishes New HM Treasury Office to Implement Financial Sanctions"

On March 31, 2016, the U.K. launched the new Office of Financial Sanctions Implementation (OFSI) within HM Treasury. OFSI, which assumes the financial sanctions responsibilities previously carried out by HM Treasury’s Asset...more

McGuireWoods LLP

Sharper Teeth For Sanctions Enforcement?

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The current UK sanctions enforcement regime is a complicated web reflecting the requirements of UN Security Council Regulations, EU Regulations, and UK Primary and Secondary Legislation. Penalties for breaches of sanctions...more

Dechert LLP

UK Financial Sanctions Enforcement – New Powers and Tougher Sentences

Dechert LLP on

The UK Government put a package of proposals to Parliament in February to increase both the type and the potential severity of consequences for persons and companies who breach EU financial sanctions. If approved, these...more

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