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On 31 March 2020, the Office of Financial Sanctions Implementation (OFSI) announced the imposition of a monetary penalty of £20.47 million on Standard Chartered Bank (SCB) for breaches of financial sanctions pursuant to part 8 of the Policing and Crime Act 2017.

SCB had referred the penalty (which was imposed after SCB self reported to OFSI) for a Ministerial Review under s.147 of the Act.  The relevant Minister, the Economic Secretary to HM Treasury, who conducted the Review personally in accordance with s 147, upheld the decision to impose a penalty but reduced the overall penalty payable. The decision represents the first substantial penalty imposed by OFSI, as well as the first exercise of the Ministerial Review power, and establishes OFSI as a significant force in sanctions enforcement.  

Javan Herberg QC advised SCB.  

Alan Maclean QC advised HM Treasury.

A report of the decision can be found here.

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