Sanctions and Export Control | Regulatory Outlook June 2022

OFSI updates enforcement guidance

The Office of Financial Sanctions Implementation (OFSI) has published an updated version of its enforcement and monetary policy guidance. The updates reflect the measures contained in the Economic Crime (Transparency and Enforcement) Act 2022, the provisions of which were detailed in the March edition of our Regulatory Outlook. 

The changes, which came into effect on 15 June 2022, include (1) the removal of the requirement for OFSI to prove that a person had knowledge or reasonable cause to suspect they were in breach of financial sanctions, (2) a new ability for OFSI to publish details of breaches where monetary penalties have not been imposed, and (3) a more flexible review process relating to monetary penalties. See our Insight for more.