OFSI updates guidance on enforcement and monetary penalties for financial sanctions breaches and publishes first breach report without imposing a monetary penalty

On 31 August 2023, the Office of Financial Sanctions Implementation (“OFSI“) published several updates to its Enforcement Guidance. These provide some further clarity about OFSI’s assessment of financial sanctions breaches, and approach to its power to publish details of a financial sanctions breach where it has decided not to impose any monetary penalty (a “Disclosure Report“). … Read more

OFSI updates its enforcement guidance regarding ownership and control by sanctioned persons

On 16 March, the UK’s Office of Financial Sanctions Implementation (“OFSI”) updated its guidance on monetary penalties and enforcement (the “Guidance”) to set out its enforcement approach in cases involving ownership and control by designated persons. This is an issue which has assumed increased prominence during the past year with the escalation of sanctions against Russia and … Read more