Strict liability test for sanctions breaches come into force

Changes to the UK’s financial sanctions regime, introduced by the Economic Crime (Transparency and Enforcement) Act 2022 (the “Act“), came into force today (15 June 2022) and, with them, the power for the Office of Financial Sanctions Implementation (“OFSI“) to impose civil monetary penalties in respect of financial sanctions breaches on a strict liability basis (i.e. irrespective of any knowledge or suspicion). Continue reading