OFSI has published its annual review covering the period from April 2017-March 2018. The review covers:
- that 29 regimes were implemented during the year, with the most active list by far being North Korea (with 96 additions, and other regimes accounting for less than 30, but the lists with the largest number of sanctioned targets remain ISIL (Da’esh), Syria and Iraq);
- the introduction of the “avoidance of delay” provisions that allow the UK to implement UN sanctions immediately on the relevant resolution being adopted, and that the UK used for 18 listings during the year;
- work to improve the searching facility in the Consolidated List;
- details of current UK asset freezes. £12.8 bn frozen funds are currently held by UK businesses – over £12 bn of these funds relating to Libya;
- reports: OFSI received 122 reports of suspected sanctions breaches in the year. It notes that it imposed no monetary penalties for breach during the year but is investigating a number of cases where a penalty may be appropriate. It also notes that it has extended the scope of the criminal offence for not reporting to cover “relevant businesses and professions”; and
- licences: OFSI issued over 50 new licences, most of which were for payment of legal fees.
Finally, OFSI heralds the SAMLA and says it plans to issue more targeted guidance in 2018-19.