OFSI updates guidance on monetary penalties for financial sanctions breaches

The Office of Financial Sanctions Implementation of HM Treasury (OFSI) has amended its guidance on monetary penalties for financial sanctions breaches.  The new guidance, applicable to the government’s treatment of breaches discovered after January 28, 2022, outlines the government’s power to impose financial sanctions, how OFSI will exercise this power, and the rights of persons against whom monetary penalties have been assessed.

The January 2022 amendments focus on assessment of the public interest - in particular, on the way in which OFSI will weigh factors such as a consistent application of the law, and the interest in seeing that justice be done whilst ensuring that public resources are wisely spent.  In line with these principles, OFSI may elect not to take enforcement action if it concludes that it would not be in the public interest; at the same time, OFSI may decide to take more serious action than the relevant conduct appears to warrant.

OFSI Guidance (January 2022)

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