Improving civil enforcement of financial sanctions under SAMLA 2018
Corporate Crime analysis: Christopher Gribbin, managing associate, and Molly Vann from the White Collar Crime & Investigations team at Mishcon de Reya examine the latest consultation by the Office of Financial Sanctions Implementation (OFSI), launched on 22 July 2025, which seeks to reform the civil enforcement process for financial sanctions in the UK. The proposed changes aim to make the Office of Financial Sanctions Implementation’s (OFSI) processes clearer, more transparent, and efficient. Key reforms include updated case assessment guidance, a new settlement scheme, and the introduction of an Early Account Scheme to encourage prompt and comprehensive disclosure. OFSI also proposes streamlined penalties for reporting and licensing breaches, and a significant increase in statutory penalty maximums. While these measures are designed to expedite investigations and foster industry engagement, they are balanced by the prospect of tougher penalties. The consultation closes on 13 October 2025.