Sanctions update – creation of Office of Financial Sanctions Implementation and changes to UK financial sanctions regime

The Summer Budget 2015 contained a commitment to significantly revamp the UK's approach to the implementation and to the enforcement of financial sanctions, at both the administrative and legislative level.  These changes have now begun to be introduced, through the creation of the Office of Financial Sanctions Implementation ("OFSI") within Her Majesty's Treasury ("HMT") and the proposed introduction of new financial sanctions legislation contained in the draft Policing and Crime Bill (the "Bill").  The Bill provides for an increase in the minimum criminal penalties applicable to breaches of financial sanctions, and introduces a new power for HMT to impose civil monetary penalties in certain circumstances.  The Bill also provides for swifter implementation of UN financial sanctions in the UK.

Our briefing provides an overview of OFSI's role, summarises the proposed changes to the UK financial sanctions regime and additional powers to be granted to OFSI under the Bill, and highlights key points in the updated financial sanctions guidance recently published by OFSI.