Consultation: OFSI's enforcement processes

0%

1. Executive Summary
Page 1 of 8

This digital form is designed to receive responses to the consultation on OFSI's Enforcement Processes which can be found here

 

This consultation invites views and comments on proposed measures to enhance the effectiveness of the enforcement processes undertaken by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury. OFSI is responsible for ensuring that UK financial sanctions are properly understood, implemented, and enforced. OFSI has identified revisions to its enforcement processes that could enable it to resolve cases more efficiently, improving the delivery of public enforcement actions and reducing burdens on OFSI and on subject firms or individuals. They could also improve the transparency of OFSI’s enforcement case assessment process. 

 

In this consultation, OFSI is seeking views on:

  • Changes to OFSI’s public case assessment guidance and penalty discounts for voluntary disclosure and co-operation. 
  • The introduction of a settlement scheme for monetary penalty cases. 
  • The introduction of an Early Account Scheme (EAS) that would in appropriate cases enable subjects of an OFSI enforcement investigation to provide a complete factual account of the matters under investigation to OFSI. 
  • The introduction of a streamlined process with indicative penalties for appropriate cases involving information, reporting, and licensing offences. 
  • Changes to OFSI’s statutory penalty maximums. 

 

The changes proposed in this consultation would apply only to cases where the relevant enforcement powers are OFSI’s civil enforcement powers in connection with breaches of financial sanctions (including Russia-related designated person asset reporting) and the UK Maritime Services Ban and Oil Price Cap exception (Oil Price Cap). This consultation does not propose to make any changes to the criminal enforcement of financial sanctions breaches, or to the civil enforcement of breaches of non-financial sanctions such as trade or transport sanctions, which are the responsibility of other government departments and agencies.

 

OFSI is keen to hear from a wide range of stakeholders in response to the consultation, including businesses, financial institutions, legal and compliance professionals, civil society, and other interested parties.

 

Please note that there is a character limit for responses in this digital form of 20,000 characters per question.

 

Questions or enquiries in relation to this consultation can also be sent to OFSIEnforcementConsultation@hmtreasury.gov.uk.  

 

The consultation will remain open for twelve weeks. The closing date for responses to be submitted is Monday 13 October 2025. 

 

Privacy notice
Click here to download and view the privacy notice for the consultation, which sets out how we will use your personal data and explains your relevant rights under the UK General Data Protection Regulation (UK GDPR).