The UK’s Office of Financial Sanctions Implementation (OFSI) has published their February 2025 Financial Services Threat Assessment.

Here are my three key takeaways:

1. Money Laundering & Sanctions Evasion: Traditional money laundering routes are also exploited by Designated Persons to breach sanctions. Addressing money laundering is crucial to tackling sanctions evasion – we should not consider AML and Sanctions Compliance to be separate silos.
2. High-Risk Sectors: Crypto and Non-Bank Payment Services Providers are frequently mentioned as vectors for sanctions evasion. If these sectors aren’t flagged as high-risk in your assessments, it’s time for a review. Urgently.
3. Transparency in High-Risk Jurisdictions: The UK has named the top jurisdictions used for sanctions circumvention in 1Q24, including UAE, Luxembourg, Cayman Islands, and Cyprus. Having worked with regulators in a number of these jurisdictions, the issue often lies in their offshore structures rather than their lack of political will.

You can read the full Threat Assessment here.

If you need assistance with preparing or reviewing risk assessments or training your teams on sanctions compliance, contact Fairgreen Sanctions today.