Key takeaways

• On 1 December 2016, the Office of Financial Sanctions Implementation (“OFSI”) issued a consultation paper on its proposed guidelines for imposing civil penalties for breaches of financial sanctions.
• The consultation paper provides valuable insight as to when OFSI will impose civil fines, how their value will be calculated and the types of mitigating and aggravating factors that OFSI will consider (with particular emphasis on self-disclosure and cooperation).
• The proposed guidelines and the Policing and Crime Bill herald a stricter sanctions enforcement regime in the UK.