UK SANCTIONS – NEW OFSI ENFORCEMENT POWERS AND REVISED GUIDANCE

A post from the Office for Financial Sanctions Implementation on 8 June explains how OFSI has recently updated its Monetary Penalty guidance, as well as outlining its ongoing enforcement approach, in light of changes to its enforcement powers introduced by the Economic Crime (Transparency and Enforcement) Act 2022.  For breaches of financial sanctions that are committed after 15 June, OFSI will be able to impose civil monetary penalties on a strict civil liability basis – and won’t have to prove that a person had knowledge or reasonable cause to suspect that they were in breach of financial sanctions.  However, OFSI continues to emphasise the importance of self-disclosure as a potential mitigating factor. OFSI has also gained the power to publicise details of financial sanctions breaches committed after 15 June where a monetary penalty has not been imposed.  It has also introduced flexibility in the review process for monetary penalties, so that reviews requested after 15 June may now be undertaken by someone other than a minister.

https://ofsi.blog.gov.uk/2022/06/08/new-enforcement-powers-a-message-from-giles-thomson-director-of-ofsi/

New guidance from OFSI on enforcement and monetary penalties comes into effect from 15 June

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1081195/OFSI_Enforcement_guidance_June_2022.pdf

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https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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