Following up on our previous post, yesterday the UK Office of Financial Sanctions Implementation (OFSI) issued regulations formally implementing the civil penalties framework set out in the Policing and Crime Act 2017. OFSI has issued a press release, regulations regarding civil penalties, responses received to OFSI’s request for consultation regarding draft guidance issued in December 2016, and amended guidance regarding financial sanctions generally. The OFSI regulations essentially are consistent with our previous reporting.

We will follow up with a more detailed analysis of the OFSI regulations.