UK review of Sanctions Enforcement is done

Hi ,

Sometimes with government reviews it’s tempting to try find the angle of what they’re doing wrong, what more could be done.

But overall, I would say the UK cross-government review of sanctions implementation and enforcement released yesterday has been fairly speedy and addresses things that to date have been lacking.

I would give them a good grade, maybe an A- (it would have been good to see more detail in the doc above).

Here’s the three areas I think we’ll see change most over the next few months and what it means for Reg52 and the goal of helping AML leaders benefit from enforcement actions learnings:

1. Fast-track penalties and early settlements are coming

The UK is introducing:

• A new early settlement scheme for civil financial sanctions breaches (similar to OFAC’s approach), and

• Fast-track penalties for lower-level breaches like late reporting or licence non-compliance.

Why it matters: Enforcement actions will happen faster, and cooperation will become a commercial decision. Firms slow to respond risk higher penalties and reputation damage.

What this means for Reg52: I was speaking about this a few weeks ago, I think there’s going to be a lot more enforcement coming in Europe & UK. This point was made in the House of Commons speech to go with the report (see below)

2. Public enforcement actions & expectations will be more detailed

The government will:

• Start publishing sanctions enforcement actions regularly, and

• Launch a cross-government sanctions enforcement strategy, making expectations and penalties clearer.

Why it matters: UK Government feels it can do a better job at driving deterrence and shaping industry behaviour.

What this means for Reg52: This is brilliant! Currently OFSI enforcement actions are 5-7 pages and don’t reveal much detail (vs 50+ pages from FCA or 7+ pages of rich detail from OFAC).

3. Civil and criminal enforcement powers are expanding across government

New powers allow:

• The Office of Trade Sanctions Implementation (OTSI) and Department for Transport to issue civil fines,

• HMRC and NCA to continue leading criminal prosecutions—like the first-ever UK Russia sanctions conviction in April 2025.

Why it matters: As I highlighted with the HMRC compound settlements, enforcement isn’t just OFSI’s remit. A single breach can now involve multiple regulators depending on the type—financial, trade, or transport.

What this means for Reg52: As you’ve seen I’m starting with OFSI & FCA but it pretty much means I’ll have to cover more and more actions which I think will build a better knowledge base for you.

On the topic of UK Sanctions enforcement, if you’re interested in OFSI’s largest ever fine of £20.47m for Standard Chartered in 2020, here’s the deep-dive I published this week: https://reg52.com/enforcement/ofsi/standard-chartered-ofsi-fine-2020/

Cheers,

Paul

By the way, please do share with any other AML leaders you think might find this interesting!