OFSI licencing, civil enforcement and breach investigations
The Office of Financial Sanctions Implementation (“OFSI”) is part of HM Treasury and is responsible for helping to ensure that sanctions are properly understood, implemented and enforced in the United Kingdom. As part of achieving those objectives, OFSI provides guidance to help the public comply with financial sanctions and issues licences that allow activities which would otherwise be prohibited under the UK’s sanctions regimes. OFSI also detects and investigates suspected breaches, taking action (including enforcement action) where necessary.
Carter-Ruck is able to advise on all aspects of OFSI’s work, including:
- how to comply with the UK sanctions regimes;
- interpreting OFSI’s guidance;
- applying for specific licences from OFSI and remaining in compliance with those licences once obtained;
- interpreting and complying with OFSI’s General Licenses;
- submitting reports to OFSI, including: frozen asset reporting; fulfilling the reporting obligations under s70A of the Russia (Sanctions) (EU Exit) Regulations 2019; suspected breach reports; and suspected designated person reports;
- considering and responding to information requests from OFSI;
- advising on breach investigations and subsequent enforcement by OFSI; and
- bringing legal proceedings against OFSI where required (for example to press a client’s rights in respect of the grant of a specific licence).
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