The Office of Financial Sanctions Implementation (“OFSI“) published an update to the monetary penalties for breaches of financial sanctions guidance (“Guidance”) on 2 May 2024 (see here). The Guidance explains when and how OFSI will use its civil enforcement powers to impose monetary penalties for breaches of financial sanctions, including guidance on how such penalties will be calculated. The most recent changes primarily focus on Chapter 3 (Case assessment) of the Guidance. Following the recent update, OFSI…