The Office of Financial Sanctions Implementation (OFSI) updated its Enforcement and Monetary Penalties Guidance.

Amendments have been made to the following areas:

  • Case assessment: OFSI will always apply the most reiteration of its Enforcement guidance to cases, with guidance on assessments provided in Chapter 3;
  • Case factors: Information is provided on how OFSI applies and splits the case factors used by the authority to assess suspected breaches of financial sanctions, including the new distinction of “Knowledge, intention and reasonable cause to suspect” and “Cooperation”; and
  • Ministerial reviews: Minor edits have been made to information on the delegation of ministerial reviews of money penalties in Chapter 6.

Firms should review the latest Guidance to ensure continued financial sanctions compliance.

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