John Binns, Partner at BCL, has commented on major reforms announced by the Office of Financial Sanctions Implementation (OFSI), including new settlement incentives that could reshape enforcement strategy.
The reforms, announced on 29 January, include proposals to double OFSI’s maximum fine to £2 million (or the whole value of relevant assets) and introduce a time-limited settlement scheme designed to encourage early self-reporting and cooperation. John observed that OFSI is increasingly aligning itself with other UK regulators by placing greater responsibility on companies to identify, disclose and resolve potential wrongdoing. “Ideally, OFSI wants you not only to fashion your own noose, but to build the gallows and hire the hangman as well.”
He added that OFSI is grappling with an “arms race between prohibitions and circumventions,” with sanctions regimes evolving in response to geopolitical developments, while enforcement appetite remains strong.
To read the full article, click here.
More like this
Sanctions compliance – John Binns speaks to The Law Society Gazette
The Russian invasion of Ukraine has thrust sanctions compliance up the agenda for law firms of all sizes. BCL’s John Binns spoke to Katharine Freeland
”UK sanctions—a year in review” John Binns writes for LexisNexis
To say that this has been a game-changing year in UK sanctions would be an understatement. Almost a year since the start of the conflict in Ukraine
Chambers and Partners Sanctions 2024 Guide
The new Chambers and Partners UK Chapter of the Sanctions 2024 Guide, written by Partner John Binns, covers key jurisdictions, providing the latest information on regulatory and legal updates, delisting challenges, trade and export restrictions, litigation and arbitration and designation, compliance and circumvention.
Russia Sanctions and Legal Advice: Some Much-Needed Clarity
The UK Government has introduced key changes to the sanctions provisions regarding legal advisory services in the Russia (Sanctions) (EU Exit) Regulations 2019 (“Russia Regulations”).
The UK has sanctioned 7 Israeli settler outposts and organisations in the West Bank
On 15 October 2024, the Foreign, Commonwealth & Development Office (“FCDO”) sanctioned three settler outposts and four Israeli organisations that it says “have supported and sponsored violence against communities in the West Bank”, under the UK’s global human rights sanctions regime.
Secondary Sanctions, De-Risking, and More: How UK Sanctions Aim for Global Reach
On 26 June 2025, the FCDO published new guidance on UK sanctions compliance for non-UK companies, including businesses in Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Uzbekistan.
UK Sanctions Round-Up: Enforcement Tightens
BCL’s latest sanctions round-up highlights key UK and international developments in sanctions law, enforcement, and policy.
Sanctions Fortnightly Summary: Key UK and Global Developments
This edition of our sanctions round-up covers key UK and international developments.
Fortnightly Sanctions Summary: New Licences, Designations and Enforcement
BCL’s latest sanctions and export controls round-up reviews significant developments in UK and international sanctions law and enforcement over the past fortnight.
Sanctions Round-Up: OFSI Annual Review, Russian Designations, and Policy Shifts
Our latest Sanctions and Export Controls Fortnightly Round-Up reviews key UK and international developments from 6th to 17th October 2025.
Global Sanctions Tighten: New OFSI Licences, EU’s 19th Russia Package, and Lifting of UK Arms Embargo on Armenia and Azerbaijan
This edition covers key UK, US, and EU sanctions and export control developments over the past two weeks.
Fortnightly Sanctions Round-Up: Lukoil Licences, Cyber Designations & Parliamentary Updates
This fortnight’s update highlights significant UK and international developments in sanctions and export controls, including new OFSI General Licences connected to Lukoil, fresh designations under the UK’s Russia and Cyber regimes, and parliamentary scrutiny concerning the use of interest accrued on the frozen proceeds from the sale of Chelsea Football Club.
Sanctions & Export Controls Round-Up: December Update
BCL’s latest sanctions and export controls round-up highlights key UK and international developments in sanctions law and compliance.
BCL Sanctions Round-Up: Key UK and Global Developments
This first 2026 edition considers evolving UK sanctions enforcement practice, government policy responses to sanctions evasion, and Parliamentary scrutiny of the UK’s Magnitsky-style regimes. It also examines developments relating to Venezuela, shadow fleet activity, crypto-assets and humanitarian licensing.
UK and International Sanctions: Key Developments – February 2026