HMT consults on reforms to OFSI civil enforcement processes

HM Treasury (HMT) has published a consultation paper on proposed reforms to the Office of Financial Sanctions Implementation's (OFSI) civil enforcement processes. The aim is to improve the efficiency, transparency and effectiveness of OFSI's enforcement activities. The reforms would apply solely to OFSI's civil enforcement powers concerning financial sanctions breaches, including Russia-related designated person asset reporting and the UK Maritime Services Ban and Oil Price Cap exception, excluding criminal enforcement or non-financial sanctions.

Key proposals include:

• Updates to OFSI's public case assessment guidance and penalty reductions for voluntary disclosures and cooperation.
• Introducing a settlement scheme for cases involving monetary penalties.
• Introducing an Early Account Scheme, enabling subjects of an OFSI enforcement investigation, where applicable, to provide a full factual account of the matters under investigation.
• Introducing a streamlined enforcement process for indicative penalties in suitable cases involving information, reporting and licensing offences.
• Revisions to statutory penalty maximums.

The deadline for comments on the consultation is 13 October. OFSI will host a virtual working-level event to discuss the consultation, with further details to follow in due course.

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