Financial sanctions enforcement and monetary penalties guidance updated

Following our recent consultation, we have published updated guidance, reflecting a stronger and more transparent enforcement framework. These updates are designed to support compliance, give firms greater certainty and ensure sanctions are applied in a fair, effective and robust way. This guidance comes into effect from today and as a matter of policy OFSI assess all breaches of financial sanctions in line with the enforcement guidance in effect at the time of making its first formal decision whether to take enforcement action.

To read the guidance click here.

The guidance published today includes minor updates to a number of chapters, and the significant updates and additions below:

Early Account Scheme, Settlements & Financial Hardship

• Chapter 4 – Early Account Scheme (EAS): Introduction of a new EAS (with a penalty discount of up to 20%), enabling subjects to provide an early factual account of a breach in eligible cases. This section sets out clear eligibility criteria, a step-by-step process, and the information OFSI expects to receive.
• Chapter 6 – Settlement Scheme: Introduction of a new Settlement Scheme (with a penalty discount of 20%). This section sets out how the scheme operates in practice and how it can apply to existing cases.
• Chapter 7 – Financial Hardship: New policy explaining how OFSI will consider exceptional claims of financial hardship, including the burden on the subject to evidence hardship and OFSI’s ability to consider public interest factors.

Enforcement Case Assessment & Discounts

• Chapter 5 – Updated Case Factors: Several case factors have been updated, added, removed or renamed to provide clearer and more consistent assessments.
• Chapter 5 – Four Level Seriousness Model: Replacement of the previous framework with a new four-tiered seriousness model (Levels 1–4), each with indicative outcomes ranging from warning letters to monetary penalties.
• Chapter 6 – Voluntary Disclosure & Cooperation Discount: Introduction of a single penalty discount (up to 30%) for complete voluntary disclosure and co-operation, supported by expanded guidance clarifying what OFSI considers complete and timely cooperation.

Information, Reporting & Licensing Offences

• Chapter 13 – Fixed Monetary Penalties: New section detailing how £5,000 and £10,000 fixed penalties will be applied for relevant offences, including the assessment process, penalty determination, and examples of applicable conduct. This section also expands on OFSI’s interpretation of information offences.

OFSI will host an online webinar in March 2026 to explain these changes in more detail. Further details on registration will follow.

Unlike earlier versions of enforcement guidance, this is not in PDF – it’s a standard HTML web page here:

Contents

1. Overview
2. Introduction
3. Our enforcement approach
4. The Early Account Scheme (EAS)
5. Case assessment
6. The monetary penalty process: imposing a penalty
7. Procedure for imposing a monetary penalty
8. The right of review
9. Right of appeal
10. Paying a monetary penalty
11. Publication of penalties
12. Publication of breaches where no monetary penalty is imposed
13. Fixed Monetary Penalties (Information and Licensing)