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UK Issues Sanctions Guidance on Changes Made in 2022 Economic Crime Act

The U.K.'s Office of Financial Sanctions Implementation issued guidance on the enforcement and monetary penalties for violations of financial sanctions to reflect changes made by the Economic Crime (Transparency and Enforcement) Act of 2022. The new measures and guidance come into effect June 15.

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After this date, OFSI will impose civil monetary penalties on a strict liability basis for sanctions violations and it will continue to impose the penalties when it is “appropriate, proportionate and in the public interest to do so." The agency emphasized the need for self-disclosure as a mitigating factor to these penalties. OFSI has gained the power to publish details of sanctions violations committed after June 15 where a penalty has not been imposed, the guidance said. Senior officials, and not just ministers, can undertake reviews of monetary penalties requested after June 15.