I’m Head of Enforcement and Engagement for the Office of Financial Sanctions Implementation.
This may sound like a contradiction, but actually I think enforcement and engagement are natural fits. Breaching financial sanctions is a criminal offence, punishable by up to seven years in prison, or a civil monetary penalty. But as a compliance professional I think that the best enforcement is 100% compliance – that is, everyone has properly assessed their risks, taken sensible steps to manage them and, consequently, doesn’t break the law.
That can only happen if people understand how financial sanctions work – what your risk is and how the law applies to you. That’s why, when the former Chancellor announced OFSI’s creation, he gave us three roles – to help ensure that financial sanctions are properly understood, implemented and enforced in the UK.
The ‘understanding’ element of that is at least as important as the other two, and is arguably the most important. Financial sanctions are restrictions on economic activity imposed by governments, either individually or acting together through the UK, EU or UN.
It’s important that OFSI is an engaged organisation, giving those affected by sanctions the right information to comply with those restrictions, using the most effective tools and channels to do so. We seek to be a centre of excellence for financial sanctions, promoting understanding and enabling people to make the right decisions about their business and personal transactions. We want to make it as easy as possible to do the right thing.
It’s one of the areas we focused on most in our first year of operation, and we’ve continued this year.
- produce the Consolidated List of Financial Sanctions Targets and provide e-alerts on list changes and other news to our 23,500 subscribers
- publish guidance on gov.uk, including detailed FAQs and guidance on how we use our penalty powers
- regularly communicate and work with trade and regulatory bodies (over 50 last year) to promote financial sanctions to existing and new audiences through their channels (for example, working with The Charity Commission on our bespoke FAQs for charities).
- speak at financial crime, financial services, foreign policy and other industry events and meetings (over 100 last year), and
- generally, do everything we can to get the word out about financial sanctions (including this blog).
We attend a lot of conferences and public events, particularly with the compliance community. It’s a great way to get our messages out and an important opportunity to listen to the concerns of the people most directly involved in implementing financial sanctions.
Financial sanctions by their nature are international. OFSI works as part of the sanctions community in the UK and worldwide to ensure that sanctions have their intended impact.
Most recently, we’ve spoken at financial crime and sanctions conferences in New York, Washington DC and London — helping financial sector professionals understand who we are, what we do, and how to comply with their international sanctions obligations.
We often speak alongside representatives from agencies like OFSI from other countries. Sanctions work best when they are supported and implemented in the same way by many countries whose understanding is clear and consistent. We are proud to collaborate, where we can, with our international counterparts.
I’ll be blogging on this page about future events, new guidance and key issues in compliance and enforcement. If you’d like someone from OFSI to speak at your event, read this page. We can’t guarantee we can attend (we get asked a lot) but we will certainly consider it. Speaking at an event does not imply that OFSI or individual speakers endorse the event organisation or any products or services.