Introduction
On 22 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”), which is responsible for the enforcement of financial sanctions in the UK, opened a public consultation on proposed amendments to its civil monetary penalty procedures.
The consultation (available here) seeks input on five key categories of amendments to OFSI’s current civil enforcement processes as follows:
- amending OFSI’s public case assessment guidance, and aligning its penalty discounts for voluntary disclosure and cooperation to a maximum of 30% (the current maximum varying between 30% or 50% depending on the severity of the offence, and available only for full disclosure). These proposals are intended to improve transparency;
- to introduce a settlement scheme for monetary penalty cases, with the intention of resolving cases more quickly. Settled cases would be subject to a default 20% discount of the penalty amount, but the subject would also waive their rights of appeal;
- to introduce an Early Account Scheme (“EAS”), based on a similar scheme introduced by the Prudential Regulatory Authority in 2024, again with the intention of resolving cases more quickly. The EAS would, in certain cases, allow potential investigation subjects to provide a full factual account of the matters under investigation at an early stage of the process, in exchange for an increased settlement discount;
- to introduce changes to the enforcement of information, reporting and licensing offences process, potentially to involve fixed or indicative penalties; and
- to increase OFSI’s maximum civil monetary penalties from their current maximum of the greater of £1 million or 50% of the value of the breach, to the greater of £2 million or 100% of the value of the breach. OFSI has also invited views on other options for evaluating penalties, including turnover-based penalties, and the assessment of penalties on a “per breach” rather than “per case” basis.
Responding to the consultation
The deadline to provide responses to the consultation is 23:59 London time on 13 October 2025.
OFSI has invited responses to be provided through its online form (available here) or, failing that, by email to OFSIEnforcementConsultation@hmtreasury.gov.uk, or by post to Office of Financial Sanctions Implementation, HM Treasury, 1 Horse Guards Road, London, SW1A 2HQ, United Kingdom.
OFSI has also scheduled a webinar in relation to the consultation at 14:00-15:00 London time on 17 September 2025. A link to attend the webinar is available here.
