On 2 May 2024, HM Treasury updated its guidance on financial sanctions enforcement and monetary penalties.

The Office of Financial Sanctions Implementation (OFSI) will now always apply the most recent iteration of its enforcement guidance to cases. Chapter 3 of the guidance, which covers case assessment, gives details on the change. Other updates are primarily to Chapter 3. The guidance now better explains how OFSI applies and splits the ‘case factors’ that it uses to assess suspected breaches of financial sanctions. It introduces two new distinct case factors, “Knowledge, intention and reasonable cause to suspect” and “Cooperation” that were previously included more generally in the guidance. Chapter 6 also includes a small edit to the delegation of ministerial reviews of monetary penalties.