U.K. Office of Financial Sanctions Implementation Issues First Fine
Categories: Banking & Finance, Dispute Resolution
On 21st January 2019, the U.K. Office of Financial Sanctions Implementation (“OFSI”) issued its first ever monetary penalty against Raphaels Bank. While the penalty is small (5,000), there are parallels with the Bribery Act 2010’s early enforcement which suggest this is merely OFSI’s opening salvo. Corporates would be well advised to prepare for more complex investigations and fines of a greater magnitude, and to actively consider cooperation with authorities over even small matters.