Important AML reminder: OFSI penalty for breach of UK sanctions
13 August 2025
The Office of Financial Sanctions Implementation (OFSI) has issued a penalty of £300,000 against a firm for making a payment directly to a designated person subject to an asset freeze. The OFSI press release can be found here.
OFSI advice – which the IPA would concur with – on sanctions is:
- Take appropriate steps to understand and address your exposure to sanctions risks,
- Have adequate sanctions processes in place and ensure compliance with them,
- Have systems in place to promptly identify and report suspected breaches of financial sanctions to OFSI.
Remember that as an Insolvency Practitioner, you are subject to the requirement to report sanctions issues to OFSI as outlined in our April AML Digest. Insolvency Practitioners need to evidence sanctions checks and risks prior to an appointment and be mindful of sanctions updates and how they might impact your appointment. Particular care should be taken to reassess if dividends are being paid.
