In brief
- OFSI's Strategy for 2026-29 includes two key KPIs – a pledge that 50% of licensing cases will be completed within 6 months and a commitment to 90% of enforcement investigations being decided within 18 months.
- The Strategy follows the PERC framework – Promote, Enable, Respond and Change – focussing on how the UK will design, implement and enforce financial sanctions over the coming years.
- Ahead of the anticipated increase in regulatory activity, businesses, professionals and individuals should review their sanctions compliance frameworks.
The Office of Financial Sanctions Implementation has published its Strategy for 2026-29, setting out how the UK will design, implement and enforce financial sanctions over the coming years.
This will be important for all those who engage with sanctions regimes - businesses, professionals and individuals – particularly in the Strategy's explanation of how OFSI plans to deliver its stated ambitions in practice.
The Strategy comes at a testing time for OFSI. The Russian invasion of Ukraine in 2022 presented the organisation with its greatest challenge yet – the implementation of the largest ever sanctions regime in the UK, with extensive new delegations and measures.
Moreover, OFSI is having to evolve in response to a more polarised and unpredictable geopolitical landscape, new technologies reshaping sanctions evasion, and the emergence of cryptoassets presenting novel challenges for compliance systems.
At its core, the Strategy presents four strategy pillars – the 'PERC' framework:
- Promote: to continuously make sanctions rules, risks and expectations clearer through targeted sector campaigns, guidance, and collaboration with the private sector such that non-compliance is visibly costly;
- Enable: to ensure firms can comply with sanctions regimes quickly, with a pledge that 50% of licensing cases will be completed within 6 months;
- Respond: to deploy the full 'toolkit' – settlements, monetary penalties, referrals, counter-terrorism designations and preventative action – to protect the sanctions system through timely and visible enforcement, with a commitment to 90% of new enforcement investigations being submitted for decision within 18 months of commencement; and
- Change: to move beyond one-off solutions to sustained compliance cultures in firms and sectors, including the use of AI-enabled workflows and feedback from industry to shape official guidance.
If met, these stated ambitions will have a material impact on businesses, professionals and individuals who engage with sanctions regimes. For example, with a target of 90% of investigations decided within 18 months and a new settlement scheme, the consequences of non-compliance will be felt more quickly and more intensely, and the 6-month KPI for licensing applications will no doubt be welcomed.
The new strategy sees OFSI enter its most ambitious phase yet and ushers in a more proactive, better resourced, and more technologically capable organisation. Ahead of the anticipated increase in regulatory activity, businesses, professionals and individuals should review their sanctions compliance frameworks, ensuring they can provide complete and accurate information and be transparent wherever sanctions risks may arise.