Category: OFSI (UK)

  • Office of Financial Sanctions Implementation HM Treasury

    OFSI Webinar: Civil Enforcement Processes – Updated Guidance

    Dear all,

    OFSI is pleased to invite you to our webinar on Tuesday 3 March, 14:00-15:00, covering the recently published consultation response on improving civil enforcement processes for financial sanctions. Feedback from this consultation has informed a strengthened enforcement framework, and OFSI updated its guidance on 9 February 2026 to reflect these enhancements. The guidance can be found here.

    This session will provide an opportunity to walk through the key changes in OFSI’s enforcement and monetary penalties guidance and highlight important points for industry. The webinar is designed to support understanding of the updates and their implementation.

    To register, please click here

    If you have any questions about the webinar or would like to submit a question in advance, please contact the OFSI Enforcement Consultation Team at ofsienforcementconsultation@hmtreasury.gov.uk. Pre‑submitted questions should be sent by close of play 24 February.

    Kind regards,

    OFSI Enforcement Consultation Team

  • Office of Financial Sanctions Implementation HM Treasury

    Call for evidence on ownership and control in financial sanctions regulations

    OFSI has launched a call for evidence to seek industry’s views on how UK financial sanctions regulations on ownership and control are applied in practice, including how firms implement the regulations and where they face challenges.   

    The ownership and control test is designed to stop sanctioned individuals and entities from sidestepping UK sanctions by hiding behind complex company structures, trusts or proxies. However, industry representatives report to OFSI that assessing the ability of a designated person to control an entity – even if they are not actively doing so – can be difficult in practice and may create additional costs and legal risk. 

    We are therefore asking firms, representative bodies and other interested stakeholders to share evidence and practical examples of: 

    • How often ‘hypothetical control’ is present in real financial sanctions cases; 
    • The impact it has on compliance costs, legal risk and business decisions (including derisking); 
    • Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.  

    This information will help us understand whether the current approach is as clear, effective and proportionate as it should be, so that sanctions remain tough on those they target while being workable for legitimate businesses. 

    The Call for Evidence is open until 13th April 2026. 

    The Call for Evidence page:

    Open call for evidence

    Ownership and Control Test in UK Financial Sanctions Regulations

    From: Office of Financial Sanctions Implementation

    Published 16 February 2026

    Summary

    Ownership and Control Test in UK Financial Sanctions Regulations

    This call for evidence is being held on another website.

    This call for evidence closes at

    Call for evidence description

    HMG is launching a call for evidence to seek industry’s views on how UK financial sanctions regulations on ownership and control are applied in practice, including how firms implement the regulations and where they face challenges.   

    We are asking firms, representative bodies and other interested stakeholders to share evidence and practical examples of: 

    • How often ‘hypothetical control’ is present in real financial sanctions cases; 
    • The impact it has on compliance costs, legal risk and business decisions (including de-risking); 
    • Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.  

    This information will help us understand whether the current approach is as clear, effective and proportionate as it should be, so that sanctions remain tough on those they target while being workable for legitimate businesses. 

    How to respond

    OFSI is keen to hear from a wide range of stakeholders in response to the consultation, including businesses, financial institutions, legal and compliance professionals, civil society and other interested parties.  

    This Call for Evidence goes live on Monday 16th February 2026 and will be open for eight weeks. Responses will be accepted until 11:59pm on Monday 13th April 2026. 

    Responses are encouraged via the online form.

    If you cannot respond via the online form, you may send your response by email to oc-callforevidence@hmtreasury.gov.uk 

    Please state whether you are responding as an individual or representing the views of an organisation, business, or representative body.

    Privacy notice

    Click here to view the privacy notice for the call for evidence, which sets out how HM Treasury will use your personal data and explains your rights under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).

    The Call for Evidence PDF:

    There’s an HTML page, too.

    Finally, OFSI wrote a blog post:

    Call for evidence on ownership and control in financial sanctions regulations

    OFSI, 16 February 2026 – OFSI Blog

    OFSI has launched a call for evidence to seek industry’s views on how UK financial sanctions regulations on ownership and control are applied in practice, including how firms implement the regulations and where they face challenges.   

    The ownership and control test is designed to stop sanctioned individuals and entities from sidestepping UK sanctions by hiding behind complex company structures, trusts or proxies. However, industry representatives report to OFSI that assessing the ability of a designated person (DP) to control an entity – even if they are not actively doing so – can be difficult in practice and may create additional costs and legal risk. 

    This information will help us understand whether the current approach is as clear, effective and proportionate as it should be, so that sanctions remain tough on those they target while being workable for legitimate businesses. 

    Background  

    The policy intention of the UK government’s approach to ownership and control (O&C) in UK sanctions regulations is to ensure that sanctions cannot be easily circumvented. The two-condition O&C test set out in legislation (e.g. Regulation 7(4) of The Russia (Sanctions) (EU Exit) Regulations 2019) serves as a critical safeguard against sanctions circumvention, by ensuring that entities owned or controlled by a DP are subject to financial sanctions, even if not explicitly named on the UK Sanctions List. In particular, the second condition of that test (also referred to as ‘the control test’) is broadly drafted to capture as much activity as possible. 

     We have repeatedly heard from financial and legal representatives that they face challenges when implementing O&C provisions, with particular emphasis on the degree of uncertainty of the control test and the potential for multiple and sometimes conflicting interpretations. Firms have told OFSI that determining when these situations constitute control for sanctions purposes can be challenging and that it is not always clear what evidence should be reasonably sought to support these assessments. 

    In response to industry feedback, HM Government committed to delivering measures to provide further clarity on ownership and control as part of the Review of Sanctions Implementation and Enforcement, published in May 2025. We are therefore launching a call for evidence on how the UK’s O&C test is applied during financial sanctions compliance. We want to hear from those who apply the test about where it works well, where challenges arise and the practical impacts of these assessments. Formal evidence across these areas, in addition to anecdotal evidence already held by OFSI, will help form a comprehensive picture of how implementation works in practice.  

    The call for evidence focuses on control as a direct response to industry feedback, which has highlighted greater implementation challenges associated with the control element of the O&C test rather than the ownership element. On ownership, HMG continues to actively explore options to respond to calls for greater alignment with international partners, including adopting an aggregation model and amending the 50% ownership rule to “50% or more,” in line with the EU and US sanctions frameworks.   

    Why we are calling for evidence 

    Under UK financial sanctions, a DP is subject to an asset freeze. The regulations also apply to entities that designated persons own or control.  

    An entity is owned or controlled directly or indirectly by another person in any of the following circumstances:  

    • The person holds more than 50% of the shares or voting rights in an entity.  
    • The person has the right to appoint or remove a majority of the board of directors of the entity.  
    • It is reasonable, having regard to all the circumstances, to expect that a DP would (if  they chose to) be able, in most cases or significant respects, by whatever means and whether directly or indirectly, to achieve the result that affairs of an entity are conducted in accordance with that DP’s wishes.   

    Evidence presented that the DP has not exercised control does not mean they do not have the ability to do so and therefore does not necessarily refute a DP’s control over an entity. This may be referred to as a DP’s hypothetical ability to exercise control, or simply ‘hypothetical control.’  If a DP can continue to move money or operate through others, the impact of sanctions is weakened. The O&C test helps ensure that sanctions bite on the real economic interests of DP. 

    At the same time, firms need regulations they can apply in a clear and proportionate way. Uncertainty can mean operational delays while investigations are conducted, higher costs to ensure compliance and de-risking behaviour, where firms may exit contracts or avoid new business relationships to avoid breaching sanctions. 

    This call for evidence will help us understand those pressures by gathering evidence on these issues in a structured way. It will build a picture of how firms and practitioners are currently interpreting and applying the test, which aspects of the ownership and control test cause the most difficulty and the practical impacts – including on costs, timing and business decisions. Our aim is to build a concrete, evidence-based picture of practice, rather than relying on anecdote.  

    Scope of the call for evidence 

    It is important to be clear about scope. The call for evidence does not invite comment on whether ownership and control rules are desirable as a matter of policy. Instead, we are asking for evidence across the following areas: 

    • Chapter 2 examines the prevalence and nature of hypothetical control in financial sanctions, including how frequently this form of control is encountered and in what contexts.  
      We are seeking evidence on its significance in the application of financial sanctions. 
       
    • Chapter 3 explores the practical challenges and ease of implementation associated with the control test.  
      This chapter has a particular focus on the assessment of the hypothetical element of the test and the financial impact of compliance and implementation. 
       
    • Chapter 4 considers the practical utility of control typologies as a tool to assist with assessing the hypothetical element of the control test for financial sanctions.  
      This includes, in particular, the typology of control set out by Deputy Judge Nicholas Thompsell in his ruling on Kevin Hellard & Ors v OJSC Rossiysky Kredit Bank & Ors. 

    We are particularly interested in concrete examples (anonymised where necessary) that show the realities of sanctions compliance and welcome evidence from any organisation or individual involved in sanctions implementation.  

    How to respond 

    The call for evidence is open until 13th April 2026.  

    Read the full call for evidence and how to respond here: https://www.gov.uk/government/calls-for-evidence/ownership-and-control-test-in-uk-financial-sanctions-regulations  

  • UK Gov logo, 50% resolution.png

    UK Sanctions List Search Tool: User Guide

    We have published a user guide to accompany the UK Sanctions List search tool. It sets out the functions and features of the search tool, how it works and how to use it.

    The user guide helps to explain a number of features to help determine if a person, entity, or ship is included on the UK Sanctions List. These include:

    • Exact matches and partial matches of a search term
    • Fuzzy searching
    • Exact word or phrase
    • Highlighting of search matches
    • Multi-select filters 
    • Search URLs 
    • Results ranking  

    Contents

    1. Overview of search features
    2. How the search works
    3. Widening your search with fuzzy search
    4. Search for exact phrases using quotation marks
    5. Highlighting of search matches
    6. Using filters to narrow your search
    7. Search URLs
    8. How results are ranked
  • UK Gov logo, 50% resolution.png

    Today, Friday 13th February, the UK Government has varied the following designation.

    Individuals Varied:

    Name:Unique ID:
    Saodat NARZIEVARUS1319

    One individual was updated:

    I included the wording from the email for a reason: the Unique ID is a link to a web page with really-nicely formatted sanctions listings. Very user-friendly.

    , ,
  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2025/7895596 extended and 1 FAQ amended

    On 10 February 2026, the General Licence INT/2025/7895596 was amended, the expiry date was extended to 13 August 2026.

    Any persons intending to use General Licence INT/2025/7895596 should consult the copy of the Licence for full details of the permissions and usage requirements.

    On 10 February 2026, FAQ 173 was amended to reflect the amendment of OFSI General Licence INT/2025/7895596.

    From the General Licensing FAQ page:

    General Licence INT/2025/7895596

    173. Can business operations with Lukoil Bulgaria EOOD, Lukoil Neftochim Burgas AD, Lukoil Aviation EOOD, and Lukoil Bunker Bulgaria EOOD, continue as normal with regard to UK financial sanctions?

    On 15 October 2025, the UK designated PJSC Oil Company Lukoil (“Lukoil”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”). Lukoil is consequently subject to financial sanctions, as are entities owned or controlled by Lukoil.

    On 14 November 2025 OFSI issued General Licence INT/2025/7895596. This GL permits the continuation of business with respect to Lukoil Bulgaria EOOD and Lukoil Neftochim Burgas AD which are subsidiaries of PJSC Lukoil. On 20 November OFSI amended General Licence INT/2025/7895596 to include Lukoil Aviation EOOD, and Lukoil Bunker Bulgaria EOOD, which are subsidiaries of PJSC Lukoil.

    OFSI notes the ongoing work within Bulgaria to determine the future status of Lukoil’s Bulgarian operations.

    In line with OFSI licensing practice the expiry date of General Licence INT/2025/7895596 is set out in the amended licence document. The licence is subject to potential renewal based on the factual situation described above.

    Amended on: 10 Feb 2026

    ,
  • Office of Financial Sanctions Implementation HM Treasury

    Financial sanctions enforcement and monetary penalties guidance updated

    Following our recent consultation, we have published updated guidance, reflecting a stronger and more transparent enforcement framework. These updates are designed to support compliance, give firms greater certainty and ensure sanctions are applied in a fair, effective and robust way. This guidance comes into effect from today and as a matter of policy OFSI assess all breaches of financial sanctions in line with the enforcement guidance in effect at the time of making its first formal decision whether to take enforcement action.

    To read the guidance click here.

    The guidance published today includes minor updates to a number of chapters, and the significant updates and additions below:

    Early Account Scheme, Settlements & Financial Hardship

    • Chapter 4 – Early Account Scheme (EAS): Introduction of a new EAS (with a penalty discount of up to 20%), enabling subjects to provide an early factual account of a breach in eligible cases. This section sets out clear eligibility criteria, a step-by-step process, and the information OFSI expects to receive.
    • Chapter 6 – Settlement Scheme: Introduction of a new Settlement Scheme (with a penalty discount of 20%). This section sets out how the scheme operates in practice and how it can apply to existing cases.
    • Chapter 7 – Financial Hardship: New policy explaining how OFSI will consider exceptional claims of financial hardship, including the burden on the subject to evidence hardship and OFSI’s ability to consider public interest factors.

    Enforcement Case Assessment & Discounts

    • Chapter 5 – Updated Case Factors: Several case factors have been updated, added, removed or renamed to provide clearer and more consistent assessments.
    • Chapter 5 – Four Level Seriousness Model: Replacement of the previous framework with a new four-tiered seriousness model (Levels 1–4), each with indicative outcomes ranging from warning letters to monetary penalties.
    • Chapter 6 – Voluntary Disclosure & Cooperation Discount: Introduction of a single penalty discount (up to 30%) for complete voluntary disclosure and co-operation, supported by expanded guidance clarifying what OFSI considers complete and timely cooperation.

    Information, Reporting & Licensing Offences

    • Chapter 13 – Fixed Monetary Penalties: New section detailing how £5,000 and £10,000 fixed penalties will be applied for relevant offences, including the assessment process, penalty determination, and examples of applicable conduct. This section also expands on OFSI’s interpretation of information offences.

    OFSI will host an online webinar in March 2026 to explain these changes in more detail. Further details on registration will follow.

    Unlike earlier versions of enforcement guidance, this is not in PDF – it’s a standard HTML web page here:

    Contents

    1. Overview
    2. Introduction
    3. Our enforcement approach
    4. The Early Account Scheme (EAS)
    5. Case assessment
    6. The monetary penalty process: imposing a penalty
    7. Procedure for imposing a monetary penalty
    8. The right of review
    9. Right of appeal
    10. Paying a monetary penalty
    11. Publication of penalties
    12. Publication of breaches where no monetary penalty is imposed
    13. Fixed Monetary Penalties (Information and Licensing)
  • Well, the new format is an improvement… but I’ll still need to implement a way for Gemini to understand that formatting…

    , ,
  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence – INT/2022/1947936 amended and 2 FAQs amended

    On 5 February 2026,  the General Licence INT/2022/1947936 was amended. Annex I was amended to remove Bank FC Otkritie and replace it with BM-Bank, reflecting their merger.

    Any persons intending to use General Licence INT/2022/1947936 should consult the copy of the Licence for full details of the permissions and usage requirements.

    On 5 February 2026, FAQs 147-148 were amended to reflect the amendment of OFSI General Licence – INT/2022/1947936.

    From the FAQ page:

    147. My OFSI licence(s) still mention(s) Bank Otkritie following its merger. What should I do?

    Bank Otkritie, which was Designated under the Russia (Sanctions) (EU Exit) Regulations 2019, ceased to exist as a separate entity when it merged with BM-Bank as of 1 January 2025. BM-Bank remains designated as a result of its ownership and control by the designated entity VTB Bank. OFSI has amended the Humanitarian Activity General Licence INT/2022/1947936 to reflect the merger with BM-Bank and you may continue to rely on this General Licence, provided you otherwise comply with its terms and conditions. Should you hold a live specific licence referencing Bank Otkritie, and you wish to continue relying on this licence, then you should immediately request an amendment to your licence from OFSI as OFSI would consider it a breach of sanctions if entities/individuals continued using their licence without the correct licence permission in place.

    Amended on: 05 Feb 2026

    148. Will OFSI amend General Licences affected by the mergers of Rosbank PJSC and Bank Otkritie with BM-Bank?

    OFSI has amended the affected live General Licences, including those impacted by the merger of Rosbank PJSC and the merger of Bank Otkritie with BM-Bank. Therefore, entities/individuals relying on these General Licences can continue to do so. OFSI will not proactively identify specific licences referring to these entities.

    Amended on: 05 Feb 2026

    , ,