Last month, the UK’s Office of Financial Sanctions Implementation’s (“OFSI”) published a Threat Assessment analyzing sanctions compliance involving UK financial services firms since February 2022, when Russia invaded Ukraine.

In the first of our two-part article (available here), we summarized the six key areas of risk that OFSI identified in its Threat Assessment.

In this concluding part, we consider next steps for UK financial services firms, including performing targeted lookbacks and assessing whether existing sanctions compliance programs and controls are properly attuned to the threats and vulnerabilities that OFSI identified, or whether urgent remediation is necessary.…