OFSI updates enforcement guidance

OFSI has updated its guidance on Enforcement and Monetary penalties. The main update is to say that OFSI will now always apply the most recent iteration of its guidance to cases it is looking at. It has also taken the opportunity better to explain what “case factors” it uses to assess suspected sanctions breaches, and introduces as specific factors “knowledge, intention and reasonable cause to suspect” and “cooperation” within its wider case factors. It will judge each case on the severity of the breach and the conduct of the relevant person.

Emma Radmore