News & Analysis as of

Civil Monetary Penalty United Kingdom

Womble Bond Dickinson

The ICO’s Penalty Against 23andMe Brings New Emphasis on Cybersecurity Risks - Key Takeaways for U.S. Companies

Womble Bond Dickinson on

The dramatic increase in global reach that the internet provides U.S.-based companies comes as a double edge sword. While it significantly increases a company’s potential customer pool, it also subjects companies to...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

Ropes & Gray LLP

OFSI Annual Review 2023-2024: A Shift Towards Proactive Sanctions Enforcement and Enhanced Industry Engagement

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On 21 March 2025, the Office of Financial Sanctions Implementation (OFSI) published its annual review for 2023-2024 period. The report highlights a number of key developments in the agency’s work. Importantly, the data...more

K&L Gates LLP

UK Office of Trade Sanctions Implementation New Enforcement Powers and Increased Reporting Obligations

K&L Gates LLP on

On 12 September 2024, the UK government released the new Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the Regulations), which will come into force on 10 October 2024. The Regulations grant the...more

The Volkov Law Group

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

The Volkov Law Group on

In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property...more

Latham & Watkins LLP

New Civil Monetary Penalty Regime for UK Trade Sanctions

Latham & Watkins LLP on

The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 empower OTSI to enforce UK trade sanctions through civil monetary penalties, building on the role of OFSI, which has enforced UK financial...more

Mayer Brown

UK Government Launches Office of Trade Sanctions Implementation to Enforce UK Trade Sanctions

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On 12 September 2024, the UK Government published the regulatory framework providing the scope and powers of the Office of Trade Sanctions Implementation (OTSI), the authority responsible for the implementation and...more

A&O Shearman

UK Russia sanctions: back in the spotlight

A&O Shearman on

Sanctions and the systems and controls companies have in place to comply with them seem to be back in the spotlight. In addition to guidance recently published by the UK Financial Conduct Authority, a number of recent...more

WilmerHale

The Gambling Commission reaffirms its status as one of the UK’s most active AML enforcement authorities.

WilmerHale on

On 28 March 2023, the UK Gambling Commission (the Commission) announced that three gambling businesses owned by William Hill Group would pay a total financial penalty of £19.2 million for social responsibility and anti-money...more

White & Case LLP

Crackdown on procedural infringements

White & Case LLP on

European Union - In May 2022, the GC upheld the EC's €28 million fine imposed on Canon for gun jumping in the context of a so-called warehousing structure. Interestingly, the GC ruled that the standstill obligation does...more

ArentFox Schiff

CFTC’s Historic Enforcement Action Impacting the Oil Industry & Related Derivatives

ArentFox Schiff on

The Commodity Futures Trading Commission, under a reconstituted Commission, is signaling a new era of aggressive enforcement of the Commodity Exchange Act. Significant Violations and Penalties - United States- On...more

Cohen & Gresser LLP

Sanctions Enforcement in England & Wales

Cohen & Gresser LLP on

On 8 June 2022, and to coincide with the introduction of amendments to the Economic Crime (Transparency and Enforcement) Act 2022 (“the Economic Crime Act”), the UK’s Office of Financial Sanctions Implementation (“OFSI”)...more

BCLP

Potential reforms to the UK’s model for criminal liability: should we be concerned?

BCLP on

On 10 June 2022, the Law Commission published its long awaited paper setting out ten options that are available to the Government for reform of the common law principles governing corporate criminal liability in the UK. In...more

Morrison & Foerster LLP

OFSI Fines UK Firm Located Overseas for UK Financial Sanctions Breach

The Office of Financial Sanctions Implementation (OFSI) imposed a £15,000 penalty on UAE-based and UK-registered entity, Tracerco Limited (Tracerco), for breaching UK sanctions when it purchased flights for an employee from...more

BCLP

Banking Bites - June 2022

BCLP on

New High Court case considers nature and scope of the Quincecare duty - In June, the Court of Appeal expanded the scope of a bank’s duty of care to protect its customers from fraud to encompass instructions by those other...more

A&O Shearman

UK sanctions enforcement changes come into force today

A&O Shearman on

The UK sanctions enforcement regime becomes tougher today due to changes made by the Economic Crime (Transparency and Enforcement) Act 2022 coming into force....more

Cadwalader, Wickersham & Taft LLP

Sanctions Watch: UK Authority Outlines Powers to Impose Strict Liability Civil Penalties

Summary - From 15 June 2022, the Office of Financial Sanctions Implementation (“OFSI”) has the power to issue monetary penalties for breaches of financial sanctions on a strict liability basis. The newly-published...more

WilmerHale

Online Safety Bill Update: civil sanctions prioritized over criminal

WilmerHale on

The U.K. Government recently introduced an updated draft of the Online Safety Bill (the “OSB”) to Parliament. The OSB is the U.K.’s first significant piece of legislation regulating online behavior. ...more

Morrison & Foerster LLP

Seven Takeaway Points from OFSI’s Annual Review 2020-2021

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On 14 October 2021, the Office of Financial Sanctions Implementation (“OFSI”) published its annual review for the financial year 2020-2021 (the “Annual Review”). Under the leadership of its new Director, Giles Thomson,...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For March 2021

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Morrison & Foerster LLP

UK Quarterly Review: Business Crime, Investigations, And Regulatory Enforcement

In our Quarterly Review, we bring you important UK developments relating to business crime, investigations, and regulatory enforcement from the last three months. As the UK gets used to life outside the EU and implements...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - October 2020

Recent and significant regulatory and legislative events in the digital asset space demonstrate the evolving and expanding approach by U.S. and international regulators to the burgeoning digital asset markets. These...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

UK Government Proposes Tighter Reporting Requirements Under Modern Slavery Act, but No Action on Enforcement Measures

Following a review of the Modern Slavery Act 2015 (MSA) and the Home Office ‘Transparency in Supply Chains Consultation’ that closed in September 2019, the UK government is proposing a tightening of the reporting requirements...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For July 2020

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

BCLP

Enforcement Undertakings: The Shifting Landscape of Environmental Criminal Liability

BCLP on

In recent years, there has been a fundamental change in the way that breaches of environmental law in England and Wales are dealt with – the number of prosecutions is decreasing, the quantum of fines is increasing and the use...more

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