UK Overhauls Sanctions Enforcement as OFSI’s New Penalty Regime Takes Effect

Overview

• OFSI’s updated Enforcement and Monetary Penalties guidance took effect on 9 February 2026, introducing a clearer case assessment matrix and revised penalty calculations.
• A Voluntary Disclosure and Cooperation discount of up to 30% now replaces the previous self-disclosure model and applies across penalty cases subject to cooperation quality.
• A time‑limited Settlement Scheme offers a 20% reduction but requires subjects to waive appeal rights, agree not to contest findings, and accept non‑anonymised public notices.
• An Early Account Scheme grants up to a further 20% reduction for providing a comprehensive early account, with cumulative reductions across all mechanisms capped at 70%.
• Fixed penalties of £5,000 or £10,000 will apply to specified information, reporting, and licensing offences, representation periods fall to 15 business days, all penalties will be public, and OFSI will seek legislation to raise the statutory maximum to the higher of £2 million or 100% of breach value.