Syed Rahman outlines the changes in UK sanctions enforcement policy in an article for Law360

With changes having come into effect as from April 1 regarding the UK’s enforcement of sanctions policy, Rahman Ravelli’s Syed Rahman wrote an article detailing what is new.

In his piece, which was published by Law360, Syed explains how the latest guidance from the UK Office of Financial Sanctions Implementation (OFSI) differs from what was issued four years ago. He cites examples in the new guidance of where OFSI appears to be prepared to take a tougher approach to sanctions breaches.

The earlier guidance's reference to not normally imposing a penalty on a person who has already been prosecuted has now gone, along with the circumstances where OFSI reserves the right not to impose a civil monetary penalty. The new guidance emphasises that OFSI can use a variety of types of enforcement action in a single case, which Syed believes means there is now less scope for leniency when it comes to sanctions violations.

Syed makes the point that although most of the changes are not major, they do show that OFSI is putting an emphasis on its enforcement obligations. While the Treasury has said the guidance has been updated to provide clarity, it is a clarification that involves OFSI making very clear its readiness to act on sanctions breaches.

With OFSI now looking to maximise the scope of the existing rules, Syed emphasises the importance of businesses taking all steps necessary to ensure their conduct does nothing that would prompt it to investigate.

Syed's article featured on Law360. (Subscription required)