OFSI Compliance for Financial Institutions: Obligations, Reporting and Licensing

Introduction

The Office of Financial Sanctions Implementation (OFSI) sitswithin HM Treasury and is responsible for implementing and enforcing the UK'sfinancial sanctions regime. For banks, insurers, payment service providers, andother financial institutions, OFSI compliance involves a distinct and demandingset of obligations: mandatory reporting of suspected breaches, asset freezing,licensing for otherwise prohibited activities, and participation in OFSI'sregular guidance and consultation processes. This course provides a detailedand practical guide to OFSI compliance as it applies to the financial sector.

Who ThisCourse Is For

This course is designed for sanctions compliance officers,financial crime teams, relationship managers, and legal counsel at UK financialinstitutions and regulated firms. It is suitable for professionals who arefamiliar with UK sanctions basics and want to focus on the specific obligationsthat apply to the financial sector.

WhatYou'll Learn

•      OFSI's role, powers, and approach to financialinstitutions

•      Mandatory reporting obligations under the UK sanctionsregulations

•      Asset freeze implementation: identifying, freezing, andmanaging frozen assets

•      OFSI's licensing regime: grounds, applicationprocedure, and timelines

•      OFSI's enforcement powers: civil monetary penalties andthe aggravated offence

•      How OFSI assesses compliance and what it looks for ininspections

•      Engaging with OFSI: voluntary disclosure, guidancerequests, and stakeholder consultation

CourseStructure

Format: Live onlinesession with Q&A, also available as on-demand recording

Duration: 2 hours

Level: Intermediate

Assessment: Noformal assessment — attendance certificate issued on completion

Technical Requirements

This course is compatible with most operating systems andmodern web browsers. Live sessions are delivered via video conferencing.On-demand recordings are accessible via the course platform. A stable internetconnection is recommended. If you experience access issues, please contact yourorganisation's IT department or the course provider.

‍CourseContent

1. OFSI and the UK FinancialSanctions Regime

•      OFSI's mandate and its relationship with the FCDO andNCA

•      How OFSI differs from OFAC: UK-specific features andapproaches

•      OFSI's compliance and implementation approach

•      OFSI guidance: financial sanctions guidance andsector-specific guidance

2. Mandatory ReportingObligations

•      Who must report to OFSI and when

•      The 'knowledge or reasonable cause to suspect'threshold

•      What to include in a report: content and formatrequirements

•      Managing the relationship between OFSI reporting andSAR obligations

3. Asset Freeze Implementation

•      Identifying designated persons: screening and alertmanagement

•      Immediate freeze obligations: steps and timelines

•      Freezing complex assets: securities, insurancepolicies, and real estate

•      Annual reporting on frozen assets to OFSI

4. Licensing

•      General licences issued by OFSI: scope and conditions

•      Applying for a specific licence: preparation andprocess

•      Grounds for licensing: basic needs, legal fees, andextraordinary situations

•      OFSI's decision-making timelines and the practicalmanagement of licence applications

5. Enforcement

•      OFSI's civil monetary penalty regime

•      The aggravated criminal offence: knowingly orrecklessly breaching sanctions

•      OFSI's enforcement case register: key lessons frompublished cases

•      Voluntary disclosure to OFSI: procedure and mitigatingimpact

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