The Office of Financial Sanctions Implementation (“OFSI“) published an update to the monetary penalties for breaches of financial sanctions guidance on 28 January 2022 (see here). The guidance sets out how OFSI will decide when to use its civil enforcement powers to impose monetary penalties for breaches of financial sanctions, and how such penalties will be calculated.

In the recent update, changes were made to the guidance on when OFSI will consider investigation and enforcement to be in the public interest. These updates emphasise the level of discretion that OFSI may have to determine whether to take action and whether to utilise civil enforcement powers. Further, the changes remove previous commentary and examples of considerations that would factor into OFSI’s assessment of whether it is in the public interest to take such steps.


Ross Evans is a Senior Associate in the EU, Competition and Trade team in London, who specializes in advising companies in the technology, telecoms, engineering, and fintech sectors on how to manage a rapidly changing landscape of competition/antitrust, trade law, and national security and investment regimes. He regularly advises clients in relation to UK public interest intervention rules and national security and investment issues, and on global foreign investment review strategy, leveraging his expertise in trade and export control laws and competition merger control regimes, and an in-depth understanding of emerging technologies.