The UK Office of Financial Sanctions Implementation (OFSI) has published an updated version of its guidance on monetary penalties for breaches of financial sanctions (the “Monetary Penalties Guidance”). The Monetary Penalties Guidance was first issued in April 2017 and sets out guidance on the circumstances in which OFSI may consider it appropriate to impose a monetary penalty, and how it will determine the amount of the penalty. No changes of policy on monetary penalties were made as a result of these updates.

The updated Monetary Penalties Guidance, which replaces the previous version, can be found here. In particular, the Monetary Penalties Guidance has been updated in the following areas:

  • Voluntary disclosure – OFSI has updated the section on voluntary disclosure under the “Case Assessment” chapter of the guidance;
  • Appeal Tribunal process – OFSI has updated the section on right of appeal to reflect the procedure for appealing financial sanctions monetary penalties cases under the Upper Tribunal rules (as amended).