Financial institutions face a myriad of sanctions compliance issues arising out of the multiplicity of legal, regulatory and reporting regimes that they are subject to. For Financial institutions in the United Kingdom, the complexity of this sanctions compliance picture has been recently enhanced by two factors: the legal divergence between the UK and the EU since Brexit; and the increasing risk of enforcement since the establishment in 2016 of the Office of Financial Sanctions Implementation (‘OFSI’) within HM Treasury, which signalled a greater focus on financial sanctions compliance.
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