Restrictions in financial services have become a pillar of Western countries’ response to Russia’s recent invasion on Ukraine. In the UK, the Financial Conduct Authority (FCA) tries to shorten the stretch to compliance starting from a one-webpage overview.

A “list of asset freeze targets for financial sanctions obligations”, from a specific Office of Financial Sanctions Implementation (OFSI), is one of the main rulers against which British financial companies should measure the stuff they work with. There is also a UK Sanctions LIst. These links can both be found on the FCA’s new overview page on the topic.

Jonathan Herbst, head of financial services at global law firm Norton Rose Fulbright, has in turn summed up what he sees as the main takeaways.


“The key message from the FCA is that it expects firms to have established systems and controls to counter the risk that they might be used to further financial crime and this includes compliance with financial sanctions obligations,” he writes.

In a five-minute video he adds some comment (about the regulatory aspects, not on the sanctions content as such): “It’s ultimately about common sense and being ready for all scenarios. What regulators have in mind, if you think about it, is something similar to the financial crisis or Brexit. Are you as a firm prepared for any shock that might or might not come along?”