THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 76, February 2019

OFSI gears up to use its civil enforcement powers

The Office of Financial Sanctions Implementation is the UK’s new(-ish) financial sanctions authority. Eighteen months old, it’s yet to use its civil enforcement powers. Rachel Barnes, Patrick..

The Office of Financial Sanctions Implementation is the UK’s new(-ish) financial sanctions authority. Eighteen months old, it’s yet to use its civil enforcement powers. Rachel Barnes, Patrick Hill and Genevieve Woods consider why and what the future may hold.   The UK’s Office of Financial Sanctions Implementation (‘OFSI’) is the UK’s competent authority for implementing and enforcing financial sanctions. It has enjoyed powers to impose civil monetary penalties for serious breaches of financial sanctions since April 2017, yet in 18 months it has never exercised those powers. This article examines why that may be the case, why OFSI’s approach may...

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