OFSI revises enforcement guidance for breaches of financial sanctions

The Office of Financial Sanctions Implementation has published an updated version of its enforcement and monetary penalty guidance for breaches of financial sanctions which comes into effect from 15 June 2022.     

The updated guidance reflects measures in the Economic Crime (Transparency and Enforcement) Act 2022, these include: 

Most notably for breaches of financial sanctions OFSI will be able to impose civil monetary penalties on a strict civil liability basis. This means that after 15 June the previous requirement for OFSI to prove that a person had knowledge or reasonable cause to suspect that they were in breach of financial sanctions will be removed, but OFSI will still bear the burden of proof to establish that there was a breach of financial sanctions prohibitions.  
OFSI has gained the power to publicise details of financial sanctions breaches committed after 15 June where it has not imposed a monetary penalty.? 
Flexibility in the review process for monetary penalties has been introduced. Reviews requested after 15 June may now be undertaken by someone other than a minister, which will allow HM Treasury to more effectively manage the resourcing implications of this work.? 

Giles Thomson, Director of OFSI, has written a blog about the new powers to accompany the guidance.  

Any queries about the guidance should be directed: ofsi@hmtreasury.gov.uk 

BIBA members’ compliance and regulation queries should be directed to:?compliance@biba.org.uk?quoting their membership number. 

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