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Did Herbert Smith expect lesser OFSI fine?

+ How to nail a LinkedIn post

Author

Paul Huston
May 12, 2025

FCC Insights

Hi ,

I previously spoke about struggling with the ephemeral nature of LinkedIn posts regarding Enforcement Actions.

Don’t get me wrong, I think there’s a a place for great, original responses on a LinkedIn feed (see below Emil Dall’s brilliant post last week about the OFSI Svarog fine).

But I also feel AML Leaders require a place where they can return to find insights and trends around those insights.

So three updates today on that note:

  1. The recent Herbert Smith Freehills OFSI action is live

  2. All Enforcement Action deep-dives get links to regulations breached

  3. All deep-dives get links to the underlying Enforcement Action doc

  1. The Hebert Smith Freehills action is live

    I previously wrote 4 bullets on this on LinkedIn in March. But now you get key figures and snippets you can include in your comms, a Timeline, deeper case analysis and Enforcement Action & regs links (see below).

    In terms of insights, I found the timeline (below) pretty interesting:

    • Herbert Smith Freehills self-reported the violation the day after the last breach was found;

    • But also requested a ministerial review of the penalty

    • Maybe they thought they were being too harshly punished for prompt self-disclosure?

    I think these kinds of details can get missed in the original Enforcement Action when it’s a wall of text.

  1. All Enforcement Action deep-dives pages now identify the specific regulations breached & associated designated people/entities

  • You get a link to the overarching regulations named and breached - ie Russia (Sanctions) (EU Exit) Regulations 2019

  • You get a specific link to the actual regulation breached - ie Regulation 12 in this case

  • You get links to designated people/entities mentioned (if applicable)

  1. I’ve also added links to the original Enforcement Action doc

  • I often go back to Enforcement Actions multiple times to glean different pieces of data. However I go through a convoluted search process each time. This way I hope it makes things easier for you

Conclusion

I want this to be your one-stop shop for enforcement actions & insights around them so let me know if you would want anything else.

Cheers,

Paul