Summary
Consultation on changes to the Office of Financial Sanctions
Implementation's civil enforcement processes for financial
sanctions and the oil price cap.
This consultation closes at
11:59pm on 13 October 2025
Consultation description
This consultation invites views and comments on proposed measures
to enhance the effectiveness of the enforcement processes
undertaken by the Office of Financial Sanctions Implementation
(OFSI), part of HM Treasury. OFSI is responsible for ensuring
that UK financial sanctions are properly understood, implemented,
and enforced. OFSI has identified revisions to its enforcement
processes that could enable it to resolve cases more efficiently,
improving the delivery of public enforcement actions and reducing
burdens on OFSI and on subject firms or individuals. They could
also improve the transparency of OFSI's enforcement case
assessment process.
In this consultation, OFSI is seeking views on:
- Changes to OFSI's public case assessment guidance and penalty
discounts for voluntary disclosure and co-operation.
- The introduction of a settlement scheme for monetary penalty
cases.
- The introduction of an Early Account Scheme (EAS) that would
in appropriate cases enable subjects of an OFSI enforcement
investigation to provide a complete factual account of the
matters under investigation to OFSI.
- The introduction of a streamlined process with indicative
penalties for appropriate cases involving information, reporting,
and licensing offences.
- Changes to OFSI's statutory penalty maximums.
The changes proposed in this consultation would apply only to
cases where the relevant enforcement powers are OFSI's civil
enforcement powers in connection with breaches of financial
sanctions (including Russia-related designated person asset
reporting) and the UK Maritime Services Ban and Oil Price Cap
exception (Oil Price Cap). This consultation does not propose to
make any changes to the criminal enforcement of financial
sanctions breaches, or to the civil enforcement of breaches of
non-financial sanctions such as trade or transport sanctions,
which are the responsibility of other government departments and
agencies.
How to respond
OFSI is keen to hear from a wide range of stakeholders in
response to the consultation, including businesses, financial
institutions, legal and compliance professionals, civil society,
and other interested parties. This consultation closes on 13
October 2025.
The consultation document sets out a number of ways to respond to
the consultation. We strongly encourage that responses are made
via the online form https://www.smartsurvey.co.uk/s/OFSIEnforcement/
If you cannot respond via the online form, you may send your
response by email to OFSIEnforcementConsultation@hmtreasury.gov.uk.
If you are responding via email, please make it clear which
question each comment relates to. When responding, please state
whether you are responding as an individual or representing the
views of an organisation, business, or representative body.
Virtual event
While the consultation is open, OFSI will hold a virtual,
working-level event to discuss the consultation with interested
stakeholders. Further details on how to sign up to this event
will follow.
Contact details
Questions or enquiries in relation to this consultation can also
be sent to OFSIEnforcementConsultation@hmtreasury.gov.uk.
Whilst it is preferable to send responses electronically, if
needed responses can be sent by post to:
Office of Financial Sanctions Implementation
HM Treasury
1 Horse Guards Road
London
SW1A 2HQ
United Kingdom
Documents
OFSI's enforcement
processes
Ways to respond
Respond online
or
Email to:
OFSIEnforcementConsultation@hmtreasury.gov.uk
