Sanctions in Transition: Insights from OFSI's 2024-25 Review

Eva Koreskova delves into OFSI’s 2024-25 Annual Report and the shift from expanding the UK sanctions regime to focusing on practical enforcement. 

The Thistle Initiatives Financial Crime Team reviewed the latest Annual Report from the Office of Financial Sanctions Implementation (OFSI), which shows a clear shift in focus, from expanding the sanctions regime to improving how it’s enforced.

The OFSI Annual Review 2024-25 marks a new stage in the UK’s sanctions regime. After years of rapid growth, the focus has shifted from expansion to improving how the system operates in practice.

OFSI has now:

• Delivered over 50 specialist training sessions for OFSI staff and more than 30 outreach events for industry, building deeper expertise within the regulator and improving how sanctions are understood and applied in practice. 
• Strengthened cooperation with the Financial Conduct Authority (FCA), National Crime Agency (NCA), and Office of Foreign Assets Control (OFAC), reflecting a shift toward joint intelligence and cross-border enforcement.
• Processed over 900 licensing decisions and handled 3940 suspected breach cases.
• Overseen £22.5 billion in frozen Russian-linked funds and more than 50,000 active asset freezes, demonstrating the scale and maturity of the UK’s sanctions regime. 

Together, these figures suggest a regulator moving beyond reactive case handling. OFSI is now operating with the structure, partnerships, and data capability needed to deliver more strategic, intelligence-led supervision.

OFSI’s central message is simple:

Compliance is measured by performance, not paperwork.

The report highlights three main priorities for the year ahead:

1. Helping firms move from written frameworks to evidence that controls actually work.
2. Embedding sanctions governance in everyday business decisions.

3. Building closer cooperation between regulators and industry to deliver consistent outcomes. 

OFSI has also made transparency a core focus, publishing service-level data and more details on licensing decisions. This shows a regulator holding itself accountable and expecting firms to do the same.

What this means for Firms

The definition of “good compliance” is changing - OFSI now expects firms to prove that their sanctions controls work, are active, risk-based, and in practice.

Firms should:

• Review control effectiveness – test whether ownership checks, screening tools, and escalation processes work as designed.
  
  

• Document decisions – record why specific actions were taken, not just what was done.

• Strengthen governance – ensure accountability for sanctions sits at a senior level with clear oversight routes. 

• Engage early – communicate transparently with OFSI on potential breaches or licensing requests. 

How Thistle Initiatives can help

At Thistle Initiatives, we support firms in strengthening their sanctions compliance frameworks to meet evolving regulatory expectations from OFSI and other global authorities.

Our Financial Crime team helps clients assess and enhance the effectiveness of their sanctions controls, from governance and ownership verification to screening tools, escalation procedures, and audit readiness.

Whether you are reviewing your sanctions framework, preparing for a potential OFSI inquiry, or assessing the effectiveness of evidence control across your operations, we provide practical, proportionate, and tailored guidance.

If you’d like to discuss how we can support your firm in reviewing your sanctions framework or preparing for an OFSI inquiry, get in touch at info@thistleinitiatives.co.uk or call 020 7436 0630 to speak with our team.

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