OFSI annual review 2024
Corporate Crime analysis: On 21 March 2025, the Office of Financial Sanctions Implementation (OFSI) published its Annual Review for 2023-2024, titled ‘Engage, Enhance, Enforce’ (the Review). The annual review, now in its eighth edition, is intended to provide an overview of OFSI’s operations in the past financial year. A change in title for this year’s review (the previous two years’ were titled ‘Strengthening our Sanctions’) is illustrative of an evolution in the government’s sanctions strategy, with an increasing emphasis on enforcement to drive sanctions compliance. The growing maturity of the UK’s autonomous sanctions framework, and the increasing allocation of government resources, have facilitated a shift in strategy from a predominant focus on implementation towards the multi-pronged approach embodied in the title of this year’s review. The widespread implementation of sanctions measures since 2022 provided the catalyst for the development of the UK’s autonomous sanctions regime. The content of the annual review is structured into a section for each of the three limbs (engage, enhance and enforce), as summarised in turn below. Written by Alexander Gorst, senior associate, and Mohamed Naleemudeen, associate, at BCL Solicitors LLP.
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