Following the coming into force of Part 8 of the Policing and Crime Act 2017, which introduces new monetary penalties for breaches of financial sanctions, OFSI has published guidance on the new regime, including:
- Guidance on monetary penalties for breaches of financial sanctions
- A response to OFSI’s consultation on the process for imposing monetary penalties for breaches of financial sanctions
- An updated financial sanctions guidance EU-UK-US: Export Controls and Sanctions Update April 2017
As mentioned in our March 2017 update, for breaches of UK, EU and UN financial sanctions, the maximum penalty is £1 million or 50% of the estimated value of the funds or economic resources, whichever is greater. The Policing and Crime Act 2017 also increases the maximum criminal penalty for breaches of financial sanctions from two to seven years imprisonment. Our recent publication on the Policing and Crime Act 2017 contains an in-depth analysis of the changes to the UK’s financial regime.