OFSI Publishes First Financial Sanctions Threat Assessment

On February 13, 2025, HM Treasury's Office of Financial Sanctions Implementation ("OFSI") published the Financial Services Threat Assessment(the "Assessment"), the first in a series of sector-specific assessments surveying trends in the UK's financial sanctions landscape and identifying threats to compliance. The Assessment's purpose is to aid businesses in identifying and prioritizing sanctions risks as part of their risk-based sanctions compliance efforts. The Assessment focuses, in particular, on threats to sanctions compliance relating to transactions handled by banks and non-bank payment service providers ("NBPSPs") arising out of the unprecedented expansion of financial sanctions following Russia's invasion of Ukraine in February 2022. However, many of the insights in the Assessment will be of broader relevance to businesses when developing, reviewing, and enhancing their sanctions compliance controls.