The UK Office of Financial Sanctions Implementation (OFSI) has published updated financial sanctions enforcement and monetary penalties guidance following HM Treasury's (HMT) 2025 consultation on proposed reforms to the OFSI's civil enforcement processes. A consultation response was published in January confirming that the reforms would proceed, which we covered previously here.
OFSI has updated the guidance to reflect the enhancements set out in Chapter 4 on the new Early Account Scheme (EAS), Chapter 5 on the revised case assessment framework and Chapter 6 on the updated methodology for the monetary penalty process, including the incorporation of the EAS discount, the new voluntary disclosure and cooperation discount and the settlement scheme. Chapter 7 introduces guidance on financial hardship, explaining how OFSI may take this into account in exceptional circumstances. Chapter 13 is supplementary to Chapters 6 and 7 on monetary penalties and sets out how penalties will be imposed for certain cases dealt with by means of a fixed monetary penalty. Additional amendments have been made throughout to improve procedural clarity. These key changes are effective immediately.
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