Partner Neil Dooley comments on OFSI’s expanded fining and enforcement powers, in Law360

Partner Neil Dooley comments in Law360 on the Office of Financial Sanctions Implementation’s (OFSI) expanded enforcement and fining powers, and examines their potential limitations stemming from the lack of public awareness.

An extract of Neil’s comments was published in Law360, 9 February 2026.

“This stems primarily from the concern that there is little public awareness of how OFSI conducts investigations and decides on the appropriate penalty, be it a public rebuke or a fine. The aim is to encourage greater and earlier self-reporting and so again it is putting the burden, or carrot, on institutions to come forward as soon as possible.

“Experience shows that OFSI is still taking far too long to deal with licence applications and make decisions on breach reporting and so there also appears to be a desire to streamline the process and to speed it up. Time will tell whether this has any effect, without further resources being deployed on this area by HM Treasury. Frankly, I do not think increasing the fine will have much effect at all.”