UK financial sanctions apply to any individual or entity within the UK’s territory or that carries out activities within the UK’s territory.  UK nationals and legal entities established under UK law, including their overseas branches, must additionally comply with UK sanctions regardless of where they are located or where their activities take place. OFSI will only seek to enforce breaches of financial sanctions where there is a “UK nexus”.  OFSI advises that this can be established by “a UK company working overseas, transactions using clearing services in the UK, actions by a local subsidiary of a UK company (depending on the governance), action taking place overseas but directed from within the UK, or financial products or insurance bought on UK markets but held or used overseas”. ¹

¹ OFSI Monetary Penalties Guidance, March 2023, section 3.9.