Improving civil enforcement processes for financial sanctions

This consultation invites views and comments on proposed measures to enhance  the effectiveness of the enforcement processes undertaken by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury. OFSI is responsible for ensuring that UK financial sanctions are properly understood, implemented, and enforced. OFSI has identified revisions to its enforcement processes that could enable it to resolve cases more efficiently, improving the delivery of public enforcement actions and reducing burdens on OFSI and on subject firms or individuals. They could also improve the transparency of OFSI’s enforcement case assessment process.

In this consultation, OFSI is seeking views on:

• Changes to OFSI’s public case assessment guidance and penalty discounts for voluntary disclosure and co-operation.
• The introduction of a settlement scheme for monetary penalty cases.
• The introduction of an Early Account Scheme (EAS) that would in appropriate cases enable subjects of an OFSI enforcement investigation to provide a complete factual account of the matters under investigation to OFSI.
• The introduction of a streamlined process with indicative penalties for appropriate cases involving information, reporting, and licensing offences.
• Changes to OFSI’s statutory penalty maximums.

The changes proposed in this consultation would apply only to cases where the relevant enforcement powers are OFSI’s civil enforcement powers in connection with breaches of financial sanctions (including Russia-related designated person asset reporting) and the UK Maritime Services Ban and Oil Price Cap exception (Oil Price Cap). This consultation does not propose to make any changes to the criminal enforcement of financial sanctions breaches, or to the civil enforcement of breaches of non-financial sanctions such as trade or transport sanctions, which are the responsibility of other government departments and agencies.

OFSI is keen to hear from a wide range of stakeholders in response to the consultation, including businesses, financial institutions, legal and compliance professionals, civil society, and other interested parties. This consultation closes on 13 October 2025.

The consultation document sets out a number of ways to respond to the consultation. We strongly encourage that responses are made via the online form https://www.smartsurvey.co.uk/s/OFSIEnforcement/

If you cannot respond via the online form, you may send your response by email to OFSIEnforcementConsultation@hmtreasury.gov.uk.

If you are responding via email, please make it clear which question each comment relates to. When responding, please state whether you are responding as an individual or representing the views of an organisation, business, or representative body.

OFSI will be holding a webinar on its recently launched enforcement consultation for interested stakeholders. The event will be an opportunity to discuss the background to the proposals and go into further detail on the proposed changes.

The webinar will take place online on Wednesday 17 September 2025, 14:00- 15:00.

OFSI Enforcement Consultation Webinar Sign up

If you wish to submit a question in advance, please email ofsienforcementconsultation@hmtreasury.gov.uk by 19:00 on 2 September. A detailed agenda will follow in due course.

Questions or enquiries in relation to this consultation can also be sent to  OFSIEnforcementConsultation@hmtreasury.gov.uk.

Whilst it is preferable to send responses electronically, if needed responses can be sent by post to: 

Office of Financial Sanctions Implementation  
HM Treasury 
1 Horse Guards Road 
London 
SW1A 2HQ 
United Kingdom