The report aims to provide information on suspected sanctions breaches and assist stakeholders in taking a risk-based approach to compliance.
Key takeaways from the report include:
➡️ It’s likely that some UK financial services firms haven’t disclosed all suspected breaches to OFSI;
➡️ Most instances of non-compliance are due to poor maintenance of frozen assets, breaches of OFSI license conditions, inaccurate ownership assessments, and inaccurate UK nexus assessments;
➡️ Russian designated persons (DPs) are increasingly using enablers to breach UK financial sanctions;
➡️ Most enabler activity relates to maintaining Russian DP lifestyles and assets, with it highly likely that payments are made through non-banking payments service providers (NBPSPs);
➡️ Some enablers claim ownership of frozen assets in an attempt to front for DPs; and
➡️ Enablers use other payment methods such as crypto-assets to breach UK financial sanctions.
✅ Firms should review their sanctions controls and screening systems to ensure they are not facilitating the breach of UK financial sanctions through the circumstances outlined in the report.