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UK OFSI consultation proposes tougher sanctions enforcement framework: higher penalties, reduced voluntary disclosure discounts, formal settlement and early account schemes, and simplified fines for minor breaches, aligning with OFAC

Published on: 28 November 2025

Published by a Law360 reporter
Legal News
Article summary

If adopted, these reforms could significantly raise penalties, trim concessions for voluntary self-disclosure, and bring in fresh responses to breaches, including settlement pathways. The proposals would align OFSI more closely with the enforcement model of its US peer, the US Department of the Treasury's Office of Foreign Assets Control (OFAC), a sophisticated, high-powered body with which it has developed an ever broader partnership since 2022, centred on information sharing, joint enforcement and harmonised implementation approaches. OFSI is likewise taking cues from other seasoned UK regulators, such as the Financial Conduct Authority, with which it is working closely. OFSI is progressing, and with that shift come heightened UK sanctions exposures for banks and companies within UK enforcement reach.

OFSI's expanding enforcement activity

Since Russia's invasion of Ukraine in 2022, OFSI has more than doubled its headcount, with a marked emphasis on licensing and enforcement activity. OFSI now has 135 staff and has established a dedicated compliance enforcement team to more effectively detect and actively act against such breaches of licence terms. During 2024-2025, OFSI opened 394 investigations, a material rise on prior years' reported totals...

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