On 8 September 2025, the UK’s Office of Financial Sanction Implementation (OFSI) published a Disclosure concerning breaches of Regulations 11 and 12 of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 (Regulations) by UK-registered and Financial Conduct Authority-regulated Vanquis Bank Limited (VBL).
This civil enforcement action from OFSI is the fifth of 2025 (and the second Disclosure notice of the year) and is a step up from the single enforcement action OFSI took in 2024. While indicative of action being taken by the enforcement authority, this instance offers another example of OFSI’s emphasis on encouraging organisations to establish effective, robust, and appropriate compliance procedures, systems, and controls to mitigate the risk of violations.