The Office of Financial Sanction Implementation is part of HM Treasury and leads the UK’s implementation of financial sanctions and terrorist asset freezing. It has not played a dominant part in the sanctions regime before, but its power is growing slowly.

HM Government set up its Office of Financial Sanctions Implementation in 2016 and the body has talked endlessly to the industry about how best to meet its obligations to enforce United Nations, European Union and British sanctions. However, beyond the larger banks and money transmitters, and particularly amongst lawyers and accountants, understanding and application of these sanctions is uneven. There  are also weaknesses in supervision.

The banking sector is the place where most problems to do with the financing of illicit nuclear weapons are to be found, according to OFSI, and the organisation has been good at spreading tips and awareness about this among them. 'Outreach' is the watchword.

The communication of a 'designation' (the labelling of someone as a sanctioned party) by OFSI occurs within one business day. If a designation occurs on a Friday, Saturday or public holiday it might take four calendar days.

The Policing and Crime Act 2017 increased the maximum custodial sentence for a breach of financial sanctions from two to seven years, in line with a trend that is happening throughout the spectrum of British sentencing. Also, in April 2017, OFSI was given the power to impose a non-criminal monetary penalty for breaches and the UK’s Deferred Prosecution Agreement (DPA) and Serious Crime Prevention Order (SCPO) regimes were extended to cover financial sanctions offences. Until then, the British state could only impose criminal penalties for the breaking of sanctions.

If sanctioned HNW people need to use some of their frozen monies to cover their basic needs, OFSI sometimes obliges. Between January 2015 and November 2017, it issued eight licences under the ISIL (Da’esh) & Al Qaida regime, mostly for that purpose.

When OFSI is aware that certain British financial institutions have had dealings with anyone or anything due to be designated, it talks to them immediately (before updating its consolidated list) to prepare them for the inevitable asset freeze. OFSI provides an email notification service on a website which updates its 21,000 subscribers and informs financial firms about their obligations by answering frequently-asked questions on the gov.uk webpage.

The communication of designations by OFSI is not immediate (although the legal requirement to freeze occurs immediately).

In line with the EU, OFSI defines 'ownership' as 50% or more of the proprietary rights of something or a majority interest in it. Neither the Terrorist Asset-Freezing Act 2010 nor the EU regulations expressly require the freezing of jointly owned assets but OFSI provides non-binding guidance on the subject which says that banks might freeze jointly-held assets if there is a risk that funds or assets will become available to designated persons or entities.