New UK civil sanctions powers in force

On 1 April 2017, Part 8 of the Policing and Crime Act 2017 came into force, which gives HM Treasury in the UK a number of new sanctions enforcement powers.  In particular:

  • HM Treasury is now able to impose civil monetary penalties (fines) for breaches of financial sanctions and for information breaches. The maximum is £1 million or 50% of the estimated value of the funds or economic resources, whichever is greater;
  • New UN financial sanctions listings have direct effect in the UK;
  • The maximum penalty for financial sanctions breaches has been increased from 2 to 7 years;
  • Financial Sanctions have been brought into the scope of Deferred Prosecution Agreements and Serious Crime Prevention Orders.

We previously blogged on the consultation by OFSI (part of HM Treasury) on its draft guidance here.  The draft guidance and consultation document are here.

This entry was posted in United Kingdom by Maya Lester QC. Bookmark the permalink.

About Maya Lester QC

Maya Lester QC has a wide ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. As the most recent (2016) Chambers & Partners directory put it, she "owns the world of sanctions". She spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She represents and advises hundreds of companies and individuals before the European and English courts and has acted in most of the leading cases, including Kadi, Tay Za, Central Bank of Iran, NITC and IRISL.

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