Revised guidance published Wednesday by the U.K. Office of Financial Sanctions Implementation (OFSI) signals the agency might be strengthening its current enforcement stance as it pertains to breaches of financial sanctions.
The revisions will take effect April 1, at which time OFSI will use the guidance to assess any potential financial sanctions breaches after that date. While the guidance does not contain any material changes, the subtle updates “suggest an intention to make use of monetary penalties in concert with other enforcement tools and the possibility of a broader interpretation of OFSI’s jurisdiction to impose penalties,” wrote Alexandra Melia, a partner with Steptoe Johnson, in a client alert.
