OFSI Encourages Self-Reporting Of Sanctions Breaches

Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made by the heads of OFSI (UK Office of Foreign Sanctions Implementation) and OFAC (US Department of the Treasury's Office of Foreign Assets Control). According to those remarks, companies acting in good faith that self-report minor and unintentional sanctions breaches are unlikely to face enforcement action.

Speaking on 9 October, the heads of OFSI and OFAC effectively incentivised companies to make use of the UK and US self-reporting regimes. Giles Thomson, head of OFSI, said that OFSI is "not going to come after people with a sledgehammer who are seeking to do the right thing", while OFAC Director Brad Smith said that OFAC "probably" would not enforce large penalties against companies that were acting in good faith, unless the