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- My first Insights page! UK Export Settlements cont'd
FCC Deeper Insights
Hi ,
On Wednesday I spoke about the importance of UK approach to export breaches as the potential flag-carrier of Sanctions measures and enforcement going forward.
I also promised a full page that you can use to share insights internally or externally - see gif below with link.
Not the world’s most exciting gif, but useful hopefully
Link to the page above: https://reg52.com/hmrc-export-breaches-2020-to-2025/
Feel free to just go to the page and browse yourself.
Two aspects I would draw your attention to when speaking with ExCo or clients:
Blind spots which HMRC has been penalising firms for
If you’re dealing across UK & US - what’s the difference in enforcement approach to date?
The Dual-use Goods Blind spots
Half-way down the page you’ll come across these blind-spots. The vast majority of HMRC settlements relate to dual-use goods, here’s reasons for the breaches:
If you’re dealing across the UK & US
Here’s a quick way to think about the differentiation (also on the Insights page).
Dimension | HMRC (Trade) | OFSI (Financial) | OFAC (US) |
Domain | Goods, brokering, technical assistance | Funds, economic resources | Both goods & funds |
Core Penalty Tool | Compound settlements (if inadvertent) | Monetary penalty | Civil penalty + criminal referral |
Public Detail Level | Limited (amount only) | Public Notice | 5-ish pages |
Key Trigger for Leniency | Self-disclosure & remediation | Voluntary disclosure & cooperation | "Voluntary Self-Disclosure" + non-egregious |
At the bottom of the Insights page I also included the most relevant Settlement/Enforcement Action links if you want to call out specific cases to mgmt.
I’ll be back on Wednesday, have a good long weekend!
Paul
If you found today’s email this helpful, please share with one fellow AML Leader, thanks.
They can sign up at the top of the page here: https://reg52.com/hmrc-export-breaches-2020-to-2025/