UK Considering Revising Financial Sanctions Enforcement, Including Max Penalties

July 23, 2025 |Sanctions

The U.K. is accepting public comments on how the Office of Financial Sanctions Implementation can improve its civil enforcement of financial sanctions and whether it should adopt several proposed changes to its current practices. Those include:

revisions to OFSI's maximum penalty amounts
changes to OFSI’s "public case assessment guidance" and penalty discounts for voluntary disclosures and cooperation
a new settlement scheme for monetary penalties
a new "Early Account Scheme" that would allow the subject of an OFSI investigation to "provide a complete factual account of the matters under investigation to OFSI"
a streamlined process with "indicative penalties for appropriate cases" involving information, reporting and licensing violations.

The U.K. stressed that these proposed changes wouldn't apply to criminal cases or to civil cases involving non-financial sanctions, such as trade- or transport-related violations. Comments are due Oct. 13. OFSI also plans to soon host a virtual event to discuss these changes with "interested stakeholders."