Category: Compliance & AML · Reviewed by Jake Leat, Associate Director · Last reviewed June 2026
The HM Treasury body responsible for the implementation and enforcement of financial sanctions in the UK — including maintaining the UK Sanctions List, issuing licences for prohibited transactions, and pursuing breach enforcement.
The Office of Financial Sanctions Implementation (OFSI) is part of HM Treasury. It is the UK’s competent authority for financial sanctions. It maintains the Consolidated List of Financial Sanctions Targets, issues general and specific licences permitting otherwise-prohibited transactions, receives reports of suspected breaches, and enforces financial sanctions breaches civilly under monetary penalty powers (and supports criminal prosecution where appropriate).
OFSI was established in 2016 as a function of HM Treasury. Its powers derive from the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), the Policing and Crime Act 2017 (civil monetary penalty powers), and the various country-specific and thematic UK sanctions regulations made under SAMLA.
Firms must screen customers, beneficial owners, payees and counterparties against the UK Sanctions List on onboarding and on each transaction. Where a match arises, the firm must freeze the funds (where applicable), report to OFSI without delay and apply for a licence if a transaction is needed. Breaches are reportable and subject to civil monetary penalty under the Policing and Crime Act 2017 / SAMLA regime — the most serious penalties have run into millions of pounds. The penalty is strict liability for the act, with proportionality and seriousness assessed in calibration.
For insurance, OFSI guidance (the Financial Sanctions and Insurance Guidance) covers risk-transfer, claims payments and renewals. Strict-liability civil enforcement was introduced by the Economic Crime (Transparency and Enforcement) Act 2022, expanding OFSI’s enforcement reach.
Apex’s onboarding process screens names against the UK Sanctions List. A confirmed match would freeze any inception or claim payment, generate a report to OFSI within the prescribed timeline, and engage the firm’s MLRO for related SAR considerations under POCA. Subsequent action would depend on OFSI’s licence position.
Office of Financial Sanctions Implementation guidance. Sanctions and Anti-Money Laundering Act 2018. Policing and Crime Act 2017, Part 8. Economic Crime (Transparency and Enforcement) Act 2022.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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