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OFSI's Review describes its progress against three priorities: improving compliance through clear guidance; building capability to deliver its service and functions; and enforcing sanctions proportionately and robustly.
The Annual Review, published on 15 October 2025, is titled "Effective Sanctions" and reports on OFSI's work over the past financial year in the following key areas:
Communications and guidance
OFSI has published a set of 145 FAQs covering a wide range of topics in response to demand from industry and the public. This has reduced routine enquiries and allowed OFSI to focus on more complex issues and enforcement. OFSI has also published guidance and webinars for new sectors subject to reporting requirements and launched the new OFSI / FCDO / OTSI e-alert service which provides sanctions updates to industry.
Designations and reporting
The total number of designations on the Consolidated List reached 4733, including 191 additions for Russia and there were 25 new designations under the cybercrime regime, two under the counter terrorism regime and seven under the Global Human Rights Regime.
The Annual Frozen Asset Review identified a significant increase in frozen assets reporting from £24.4 billion in 2023/2024 to £37 billion in 2024/2025. £22.5 billion of those frozen assets were reported under the Russia regime and £12.95 billion under the Libya regime.
Licensing
OFSI's licensing service has provided greater responsiveness and transparency and a "significant improvement in timeframes", although no further details or metrics are provided on this.
OFSI issued 19 general licences and made 904 specific licensing decisions, down from 1401 in the previous year. OFSI describes this caseload as "at a sustainable level".
Of those 904 licensing decisions:
- 471 were granted (new or amended applications)
- 35 were refused
- 361 were withdrawn
- 4 had insufficient evidence or information.
279 of the 471 licences granted were issued in relation to the Russia regime, followed by 109 in relation to the Libya regime, 19 in relation to Counter Terrorism regime and 43 in relation to the Global Anti-Corruption regime.
International co-operation and intelligence
There has been sustained focus on collaboration with both the EU and the US, including agreeing a memorandum of understanding with the US to enhance information sharing and co-ordinate implementation and enforcement of sanctions.
OFSI has enhanced its strategic intelligence capabilities, provided intelligence to key partners including the FCA and law enforcement and is an active participant in the Joint Money Laundering Intelligence Taskforce (JMLIT) network.
Enforcement
OFSI brought 57 enforcement actions in 2024/2025 which included monetary penalties, warning letters, disclosures and referrals. It also closed 241 cases (not including those relating to the Counter-Terrorism regimes) during 2024/2025 but of these only two resulted in a monetary penalty, 22 in a warning letter and 1 in a warning letter and referral to a regulator. As expected, the highest number of suspected breaches recorded were from the financial sector, followed by the legal sector, and by far the majority related to Russia.
As at April 2025, OFSI had 240 active cases, of which 151 were identified proactively rather than via self-reports. The move towards more proactive enforcement has been bolstered by the establishment of a dedicated Compliance Enforcement team to investigate and enforce breaches of licences.
The Review also highlights amendments to legislation which have improved OFSI's ability to implement and enforce sanctions including new licensing grounds and the introduction of the Regulatory Payments exception. The inclusion of HMT Treasury as a "prescribed person" under the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 offers employment protections to whistleblowers who disclose information about financial sanctions breaches to OFSI and should therefore encourage reporting.
Looking ahead to 2025/2026
OFSI has already undertaken key enforcement action in 2025. In May it imposed the first penalty for an information offence on Svarog Shipping & Trading Company Limited and in July, a £300k penalty against Markom Management Limited in relation to a payment to a Russian designated person.
A new suite of online forms for reporting and licencing applications designed to streamline processes were launched in July 2025. The results of the public consultation on improving the civil enforcement processes for financial sanctions (which closed on 13 October 2025) are expected to feed into OFSI's refreshed strategy for 2025/2026.
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