UK Sanctions Update: Significant New OFSI Enforcement Powers To Be Introduced And Notable Recent Sanctions Cases

UK sanctions regulation remains a highly fluid area of law and enforcement practice. This update provides a summary of some notable recent developments, including significant (and in some cases novel) changes to the civil penalty enforcement landscape following the Office of Financial Sanctions Implementation's ("OFSI") public consultation - which will broadly make it easier for OFSI to punish smaller breaches and increase the amount it may impose for more significant breaches – as well as the implications of OFSI's new (and welcome) consultation on the vexed issue of ownership and control.

We also discuss learnings from the recent enforcement against Bank of Scotland for sanctions breaches and consider the case of Alliance Petrochemical v Mazzagatti & Anor, which provides a clear reaffirmation of the territorial limits of the foreign illegality defence under English law in the context of U.S. sanctions.