OFSI’s Enforcement Overhaul – What the July 2025 Consultation Means for UK Sanctions Compliance
By: Michael Ruck, Rosie Naylor, Petr Bartoš, and Laura Scott
On 22 July 2025, the UK Office of Financial Sanctions Implementation (OFSI) launched a significant consultation on proposed reforms to its civil enforcement framework (the Consultation). These reforms – currently open for consultation until 13 October 2025 – could reshape how sanctions breaches are investigated, penalised and resolved. This marks a decisive shift away from OFSI’s traditionally cautious approach, and signals that the UK is moving toward a more assertive, US-style sanctions enforcement model.
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