News
Next steps to follow after sanctions exercise
11 November 2025
We have analysed the sanctions data gathered through our latest anti-money laundering data collection exercise. The results have helped us understand how firms are managing their financial sanctions obligations and where further support may be helpful.
As a result, in the coming months we will:
- Send tailored guidance letters to 490 firms where our data suggests sanctions controls could be strengthened, signposting practical steps and good practice. These firms have weaker controls because they confirmed they:
- have not assessed their sanctions risk in writing; and
- do not screen new clients for sanctions.
- Carry out desk-based reviews to understand sanctions risk and exposure with firms who have clients with connections to sanctioned countries and/or offer services that may carry a higher sanctions risk.
- Continue with the sanction control in our AML inspection programme, so firms inspected for AML compliance will also have their sanctions procedures reviewed.
Why we're doing this
Sanctions remain a key regulatory focus. The UK Government's recent introduction of the UK Sanctions List as the single, definitive list of designations, and OFSI's new General Licence (INT/2025/7323088) for legal services, mean firms should be reviewing their internal systems and client-screening arrangements to ensure they are up to date.
What firms should do now
All firms should ensure that their sanctions controls are proportionate and kept under regular review. In particular, firms should:
- assess and document their sanctions risk in writing
- carry out appropriate sanctions screening of new and existing clients; and
- ensure staff understand when and how to report to the Office of Financial Sanctions Implementation (OFSI).
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