UK Government Details a Cross-Government Approach to Sanctions Enforcement

Compliance officers should take note – the paper sets out clearly what can protect your firm’s position in the event of a breach.

In March 2026, the UK Government published an important policy paper setting out its cross-government strategic approach to sanctions enforcement. The paper brings together, for the first time in a single document, information on how civil and criminal sanctions enforcement operates across all relevant government departments and agencies – including the Office of Financial Sanctions Implementation (OFSI), the Office of Trade Sanctions Implementation (OTSI), HMRC, the National Crime Agency, and the Department for Transport.

The paper opens with a clear statement of intent: “Robust enforcement of UK sanctions is a priority for this government.” It also explicitly names the Solicitors Regulation Authority as one of the independent regulators responsible for supporting the implementation of the UK’s financial and trade sanctions regimes, reinforcing that sanctions compliance sits firmly within the regulatory expectations placed on law firms.

The strict liability issue

The aspect of the enforcement framework that carries the greatest practical risk for law firms is one that the paper states plainly but which can be easy to underestimate. OFSI, OTSI and the Department for Transport all operate on a strict liability basis for civil enforcement. This means they do not need to prove that a firm knew, or had reasonable cause to suspect, that it was acting in breach of sanctions. A breach alone – however inadvertent – can be sufficient to trigger enforcement action.

This is a materially different standard from the criminal law, and it has significant implications for how firms need to approach their sanctions compliance frameworks. The question is not simply whether your firm intends to comply – it’s whether your systems are robust enough to prevent an inadvertent breach from occurring in the first place. Firms without adequate screening processes, client due diligence procedures, or ongoing monitoring of the UK Sanctions List are exposed in a way that good intentions alone cannot address.

The Law Society’s sanctions guide puts it plainly: if you deal with a designated person’s funds, even without knowing you were doing so, a penalty can be imposed. Regulated professionals are expected by OFSI to meet regulatory and professional standards, and any failure to do so may be treated as an aggravating factor.

What COLPs should focus on

The section of the paper of most immediate practical relevance to law firms is the detailed treatment of civil enforcement mitigating and aggravating factors. Firms can significantly protect their position – and reduce the consequences of a breach – through the following:

Proportionate due diligence. The paper lists robust compliance systems as a mitigating factor, and states explicitly that the government expects proportionate levels of due diligence, including know-your-customer checks, and appropriate systems to ensure compliance with all relevant prohibitions. Inadequate or absent compliance controls are listed as an aggravating factor and may elevate the seriousness of a case, particularly for regulated firms where a higher standard is expected.

Timely voluntary disclosure. The paper strongly encourages prompt self-disclosure of breaches, stating this will be taken into account in enforcement decisions and can lead to a meaningful reduction in any civil monetary penalty. To qualify as a mitigating factor, disclosure must be made as soon as practicable and before the relevant authority becomes aware of the breach. Disclosure made only in response to a request for information will not carry the same weight.

Cooperation. Full, proactive cooperation with an investigation, including timely and complete responses and voluntary provision of relevant documents, is a further mitigating factor. Conversely, poor cooperation, delays or obstruction can increase the severity of any outcome.

It is worth noting that these mitigating factors can apply cumulatively. Voluntary disclosure, cooperation and having robust compliance systems in place together represent the strongest available protection for a firm that finds itself facing a potential enforcement action.

Other mitigating factors include a clean compliance history and swift remedial action taken following a breach. Aggravating factors include deliberate or reckless behaviour, concealment, repeated non-compliance, and significant harm caused to the objectives of the sanctions regime.

Civil monetary penalties and proposed increases

The current statutory maximum civil penalty for financial and trade sanctions breaches is £1 million or 50% of the value of the breach, whichever is greater. The paper notes that OFSI intends to double this to the higher of £2 million or 100% of the breach value, subject to parliamentary time. This proposed increase reflects a broader tightening of the enforcement environment and should be read as a clear signal that the government views sanctions compliance as an area of increasing priority – not one where the risk of meaningful consequences can be discounted.

Criminal enforcement

The paper confirms that a breach of UK sanctions is a criminal offence, carrying a maximum sentence of seven years’ imprisonment for financial and transport sanctions breaches and ten years for trade sanctions breaches. Criminal enforcement is reserved for the most serious and deliberate cases – those involving organised criminal activity, concealment, deception, fraud or repeated non-compliance – but firms should be aware that civil cases can and do get referred for criminal investigation where the conduct warrants it.

The full policy paper is available at GOV.UK and is recommended reading for all compliance officers and MLROs. The Law Society’s sanctions guide is a useful companion resource for firms navigating their day-to-day obligations, and is updated regularly as the sanctions landscape evolves.