The Office of Financial Sanctions Implementation (OFSI) updated its financial sanctions enforcement and monetary penalties guidance.
OFSI confirmed significant changes to its civil enforcement processes, aimed at increasing transparency, efficiency and deterrence in financial sanctions cases.
Key updates include:
Statutory Maximum Penalties: Raised the maximum penalties to increase deterrence and support enforcement;
➡️ Revised Case Assessment Framework: Introduction of a clearer four-level seriousness case assessment matrix;
➡️ Early Account Scheme (EAS): A new mechanism allowing subjects to provide an early factual account of breaches in exchange for a potential penalty reduction;
➡️ New Discount Structure: Formal incorporation of the Voluntary Disclosure and Co-operation discount (up to 30%), the Settlement Scheme discount (20%), and the newly introduced EAS discount (up to 20%);
➡️ Settlement Scheme: Introduction of a structured settlement process with defined procedural steps and available discount;
✅ Firms should reassess their sanctions breach reporting, internal investigation, and wider sanctions control frameworks, and respond appropriately to the regulator’s evolving approach to enforcement.