OFSI Updates Financial Sanctions Framework

On 9 February 2026 the Office of Financial Sanctions Implementation (OFSI) issued updated guidance on financial sanctions enforcement and monetary penalties. The guidance, which follows a public consultation in 2025, highlights a number of changes in OFSI's approach to enforcement.

Of the various changes outlined in the guidance, the most notable reforms include:

• Introduction of a new Assessment Matrix:  OFSI have sought to clarify how sanctions cases will be assessed. A new four-tier model has been introduced to classify the severity of breaches and the conduct of offending parties. Depending on the tier that a breach falls into, the guidance provides an indication of the likely outcome of the case (which ranges from warning letters to criminal penalties). The guidance suggests that OFSI will take account of factors such as the “strategic priority” of the regime breached, the systems and controls in place to prevent the breach, and whether the breach is an