Compliance Programs

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 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.
Continue Reading UK OFSI Enforcement Underscores Need for Effective Sanctions Screening and Controls

In late 2024, the United Kingdom’s Financial Conduct Authority (FCA) published a “Dear CEO” letter related to the FCA’s “Custody and Fund Services Supervision Strategy.”

Continue Reading UK FCA Letter Expresses Concerns About Fund Service Providers

On 15 June 2022, the UK Office of Financial Sanctions Implementation (OFSI) implemented important changes to its enforcement powers and updated its “Monetary Penalty” guidance.
Continue Reading New Era in UK Sanctions Enforcement: Introduction of Strict Liability Standard and OFSI Guidance Update