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.

Growing power

OFSI, however, appears to be growing in stature as time passes. In its report from the autumn of last year, it states that the Chancellor of the Exchequer, the UK's finance minister, granted it more funds in 2018 that allowed its team to grow by one-fifth. It imposed its first monetary penalties on financial firms for breaking financial sanctions last year. In 2018-19 the UK implemented 32 financial sanction regimes, three more in the previous year, with OFSI playing its part. 2,183 people and entities were subject to asset freezes by 28 regimes as of 28th March 2019 and they all appeared on OFSI's list. It added 162 targets to the list over the financial year of 2018-19, up from 122 in the previous years.

Enforcement actions so far

These are the known enforcement actions in which OFSI imposed a punitive charge. The first and second are financial service firms that dealt with funds belonging to sanctioned people without licences; the third made economic resources available to one. The sanctioned country in question is listed as well.

Raphael & Sons Bank...£5,000 on 21 January 2019...........Egypt.
Travelex UK..................£10,000 on 8 March 2019.............Egypt.
Telia Carrier UK Ltd.....£146,341 on 9th September 2019..Syria.
Total..............................£161,341

The Economic Secretary to the Treasury's anti-terrorist quarterly report (Written Ministerial Statement) for the period of 1 July 2019 to 30 September 2019 reveals that the funds that OFSI freezes are truly tiny. Under the Terrorist Asset-Freezing etc Act 2010 it froze £9,000. Under the EU Regulation (EC) 2580/2001 (aka the CP 931 regime) it froze £18,000. Under the ISIL-AQ regime underpinned by EU Regulation 881/2002 it froze £70,000. OFSI's power, however, appears to be in the ascendant nonetheless.