Trade Compliance Brief - Export Control and Sanctions Insights

UK Sanctions Strategy 2026-29: The PERC Framework & AI Enforcement | OFSI Deep Dive


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The UK’s Office of Financial Sanctions Implementation (OFSI) has entered its second decade with a high-stakes mandate.

In this episode, we break down the newly released OFSI Strategy 2026-29, a roadmap that shifts the UK from a reactive posture to a proactive, intelligence-led enforcement powerhouse. If your organization operates in or through the UK, the "PERC" framework is your new compliance North Star.

We analyze the strategic shifts every Trade Compliance Officer must know:

  • The PERC Model: A deep dive into Promote, Enable, Respond, and Change—and what "visibly costly" non-compliance actually looks like in 2026.
  • AI-Enabled Enforcement: How OFSI is integrating Artificial Intelligence and data analytics to identify circumvention typologies and "zombie" financial networks.
  • New Performance Targets: Discussion of the aggressive new KPIs, including a commitment to close 50% of licensing cases within 6 months and submit 90% of investigations within 18 months.
  • Intelligence-Led Outcomes: Why the era of relying solely on voluntary self-disclosures is over, as OFSI moves toward proactive case origination.
  • International Cooperation: The "Enhanced Partnership" with OFAC (US) and the EU, aiming to eliminate jurisdictional arbitrage for multinational firms.


OFSI Strategy Report: https://assets.publishing.service.gov.uk/media/69df6b6d53469bbcdf408e9f/OFSI_Strategy_2026-29.pdf

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Trade Compliance Brief - Export Control and Sanctions InsightsBy Pete