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ARTICLE · 14 JUNE 2022

OFSI Publishes Updated Enforcement And Penalty Guidance

Debevoise & Plimpton
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On 8 June 2022, the United Kingdom's Office of Financial Sanctions Implementation (OFSI) announced that its new strict liability enforcement standard and updated accompanying guidance...

United KingdomFinance and Banking
Satish M. Kini
Satish M. Kini
Karolos Seeger
Karolos Seeger
Jane Shvets
Jane Shvets
Konstantin Bureiko
Konstantin Bureiko
Aisling Cowell
Aisling Cowell

Key takeaways:

  • On 8 June 2022, the United Kingdom's Office of Financial Sanctions Implementation (OFSI) announced that its new strict liability enforcement standard and updated accompanying guidance would take effect on 15 June 2022.
  • The guidance reflects key measures in the Economic Crime (Transparency and Enforcement) Act 2022, including: the new strict liability test for imposing civil monetary penalties; changes to the review of monetary penalties; and a new ability for OFSI to publish details of breaches where it has not imposed a monetary penalty.

On 8 June 2022, the United Kingdom's Office of Financial Sanctions Implementation ("OFSI") announced that its new strict liability enforcement standard and updated accompanying guidance would take effect on 15 June 2022. On 9 June 2022, the corresponding legislation was enacted, confirming that the new strict liability enforcement standard would come into force, and clarifying that it would not apply to

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