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On 14 October 2021, the Office of Financial Sanctions Implementation (“OFSI“) published its Annual Review, providing an overview of OFSI’s activities in the financial year April 2020 to March 2021. A copy of the Annual Review is available here.


In 2020-2021, OFSI considered 132 reports of potential financial sanctions breaches, a slight decrease from 140 in 2019-2020. However, the number of cases considered generally remains on an upwards trajectory from the 99 potential financial sanctions breaches considered in 2018 to 2019. Notably, OFSI did not publish the total value of potential breaches reported during 2020 to 2021.

OFSI has been able to engage with 99 jurisdictions to various degrees, an increase from 83 previously. OFSI has also doubled the number of multilateral events it has participated in over the past 12 months compared to the number recorded in 2019 to 2020.


OFSI has issued 43 new licences, an increase of 7.5% when compared to 2019-2020, and made 75 amendments across 11 regimes. It also issued two authorisations and two general licences.

The majority of new and amended licences issued by OFSI during this review period were issued under the Libya regime. In terms of derogations, the majority of licences were issued under two licensing grounds: 18 for basic needs and 19 for legal fees.

Changes to the Consolidated List

In 2020-2021, OFSI made a total of 1950 changes to the consolidated list of asset freeze targets, including 1,624 amendments and 48 removals. OFSI also added 278 new designated persons to the consolidated list, 159 of which implemented EU and UN legislation, with 119 designations under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA“). As of 25 March 2021, there were 2,213 designated persons including 1,638 individuals and 575 entities across 33 regimes on the consolidated list of asset freeze targets.

As of 25 March 2021, OFSI had made 55 new listings under UK sanctions regulations since the end of the Transition Period at 11pm on 31 December 2020, when EU sanctions were replaced with UK sanctions regulations made under SAMLA.


Sunny Mann is a Partner in Baker McKenzie's London office and co-leads the UK Compliance and Investigations Practice, as well as the UK International Commercial and Trade Practice. Both these practices are ranked Tier 1 by Legal 500 UK. He has also worked in our Firm's Washington DC, New York and Sydney offices. Sunny also advises many clients on risk matters in India. He advises clients (including numerous FTSE 100 and Fortune 100 businesses) on compliance and investigations with respect to export controls, trade sanctions and anti-bribery rules. The Legal 500 ranked Sunny as a “Leading Practitioner", and as "excellent", with a ‘calm’ and "very practical" approach. The India Business Law Journal also noted that Sunny is "excellent and has deep experience in India". He is a Visiting Professor at the College of Europe, the leading institute for post-graduate European studies, where he teaches a course on Corporate Compliance.


Adeel Haque is an associate in Baker McKenzie's London office. He is a member of the International Commercial & Trade and Antitrust & Competition practice groups. Adeel qualified in September 2019 and has spent time working in the Firm's Hong Kong office.

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