On 15 June 2022, the UK Office of Financial Sanctions Implementation (OFSI) implemented important changes to its enforcement powers and updated its “Monetary Penalty” guidance. In summary, OFSI has introduced three key changes: 1) new strict liability standard; 2) publication powers; and 3) flexibility in the review process.
New Era in UK Sanctions Enforcement: Introduction of Strict Liability Standard and OFSI Guidance Update
