As part of the just-published UK's Economic Crime Plan 2: outcomes progress report, the UK government has included the following data on the enforcement of financial sanctions:
"396 recorded cases of financial sanctions breaches in the financial year ending 2024, a 16% decrease on the previous year, but there were 242 closed cases – more than tripling the number of closed cases from the previous year".
If the UK had identified 396 actual breaches of sanctions, this would beg the question of why there has been so little enforcement. There is, however, reason to question the data in this announcement.
In OFSI's latest annual report ( see our earlier post) OFSI stated:
"OFSI progressed a substantial number of investigations during 2023-24, recording 396 cases and closing 242, more than tripling the number of closed cases from the previous year".
OFSI's report is the source of the figures of 396 and 242. It would seem, therefore, that the figure of 396 relates not to identified breaches of sanctions, but to the number of financial sanctions investigations OFSI conducted during 2023-24.
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