WILL THIS MEAN BETTER GUIDANCE, INCREASED PENALTIES AND MORE ENFORCEMENT?

On 8 July 2015, the UK government published its Summer Budget 2015. Deep in the detail of the supporting policy decisions, at paragraph 2.185, the government announced its plans to establish a new “Office of Financial Sanctions Implementation”.

The new office, which is to be established within HM Treasury during this financial year, will be tasked with ensuring not only that businesses in the private sector are made better aware of the sanctions rules they are being asked to comply with, but also with ensuring that sanctions are “properly enforced”.

The Budget announcement stated that the proposed new office will “work closely with law enforcement” in this endeavour and that the government will also “legislate early in this Parliament to increase the penalties for non-compliance with financial sanctions.”

The Budget announcement may be welcomed by British business for the prospect of greater assistance in understanding sanctions compliance expectations. Yet it may also portent efforts to emulate US-style enforcement; and that could be cause for concern.