The body behind UK sanctions regulation has updated its guidance on the civil enforcement of sanctions, including some significant new enforcement powers. 

The Office of Financial Sanctions Implementation (OFSI) is overhauling its financial enforcement framework following a consultation. 

The outcome of the consultation on improving civil enforcement processes for financial sanctions was published in January, and was followed shortly afterwards by an update to the OFSI’s guidance on 9 February 2026.  

Key changes include the reduction of the maximum voluntary discount to 30%, the introduction of a formal Early Account Scheme offering up to 20% discount for early detailed admissions, and the creation of a Structure Settlement Scheme offering up to 20% mitigation for uncontested cases.  

The OFSI will also introduce fixed monetary penalties for certain reporting and licensing breaches, and will double the statutory maximum penalty to £2 million or 100% of the breach value – whichever is greater. 

For businesses, this marks a more structured and potentially more punitive enforcement landscape. Lower voluntary disclosure discounts and the higher maximum penalty significantly increase financial exposure and risk. 

The formalisation of the early engagement and settlement mechanisms provides clear incentives to engage with the OFSI to secure mitigation. Fixed penalties also allow the OFSI to address lower-level compliance failures more quickly and predictably.

What steps should you take?

Businesses should review their sanctions compliance frameworks, escalation protocols, and internal investigation capabilities. Systems should enable rapid identification and assessment of potential breaches, with clear pathways for decisions on voluntary disclosure, early account participation, and settlement. 

Record-keeping and investigation capability should be robust to support timely, well-evidenced engagement with the OFSI. Senior management should also be briefed on the heightened enforcement environment and the company’s updated response approach.

Key takeaways

  • Review sanctions compliance and escalation. 
  • Keep accurate records. 
  • Brief senior management on changes.

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Please be advised that this is an update which we think may be of general interest to our wider client base. The insights are not intended to be exhaustive or targeted at specific sectors as such, and whilst we naturally take every care in putting our articles together, they should not be considered a substitute for obtaining proper legal advice on key issues which your business may face.