The UK’s Office of Financial Sanctions Implementation will soon issue regulations that could significantly alter the British sanctions enforcement environment, and bring it closer in line with the US’s approach to such violations. On the heels of the newly-enacted Policing and Crime Act 2017, the regulations will introduce civil penalties for the violation of financial sanctions. Previously, the UK sanctions framework imposed only criminal liability. This and other changes, expected in April 2017, will affect the type and magnitude of penalties available to UK regulators. For a detailed analysis of the new regulations, including potential impacts and further comparison to US enforcement, please see our advisory.
