OFSI issues new guidance on civil enforcement of financial sanctions

“The UK’s Office of Financial Sanctions Implementation (OFSI) has updated its guidance on the civil enforcement of financial sanctions, introducing several key changes to create a “quicker, easier and more transparent” process. The revisions are aimed at addressing an increase in the volume and complexity of OFSI’s enforcement work and stem from a consultation process that began in May 2025.”

Commenting on the updated OFSI guidance, Roger Gherson, Senior Partner at Gherson Solicitors LLP, shares his views on the expanding enforcement framework and what it means for businesses navigating sanctions risk in this week’s Legal Diary.

Key changes introduced in OFSI’s updated Civil Enforcement Guidance

The most significant updates include the following:

Revised Case Assessment Process: OFSI has implemented an “indicative matrix” to assess the seriousness of sanctions breaches, categorising them into four levels. Higher-level breaches (levels 3 and 4) are more likely to result in substantial monetary penalties.

New Penalty Discounts: Businesses can now qualify for discounts of up to 30% for voluntary disclosure and cooperation, 20% for providing a comprehensive “early account” of the breach and 20% for agreeing to a settlement.

Financial hardship framework: OFSI will only reduce penalties in “exceptional circumstances” where the full penalty would cause severe financial hardship.

Fixed monetary penalties: For certain low-level breaches, OFSI can now issue fixed £5,000 or £10,000 penalties with a short 15-day window to respond.

What the new enforcement approach means for businesses and sanctions compliance

Increased Statutory Maximum: OFSI is also seeking to double the maximum civil penalty from £1 million to either £2 million or the full value of the breach, whichever is higher.

These changes will have a significant impact on how businesses and their legal advisors navigate OFSI’s enforcement regime. Timely cooperation, comprehensive disclosures and a willingness to settle will be key to minimising penalties. Companies must also be vigilant in complying with reporting requirements and licence conditions to avoid the new fixed monetary penalties.

Overall, OFSI’s updated approach aims to make its enforcement process more streamlined and predictable. The updated guidance also emphasises the need for businesses to have robust sanctions compliance programmes in place to mitigate and avoid falling foul of prohibitions imposed via the UK’s sectoral and country-specific sanctions regimes.

How Gherson can assist

The Gherson team have years of experience advising on a wide range of compliance matters, including sanctions. We regularly advise clients on sanctions rules and regulations and can assist companies with developing policies and systems aimed at preventing sanctions risks.

If you would like to speak to us in respect of any of the issues raised in this blog or about your specific circumstances, do not hesitate to contact us for advice, send us an e-mail, or alternatively, follow us on X, Facebook, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice.  Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position.  Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

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