Legal background Sanctions Enforcement
UK sanctions are underpinned by regulations made under the Sanctions Act. These regulations outline the obligations and prohibitions of specific sanctions regimes and contain the criminal offences for breaching them. Section 16 of the Sanctions Act makes provision for the sharing of information and the retention of records.
	The power to impose monetary penalties for breaches of financial sanctions is contained in section 146 of the Policing and Crime Act. Monetary penalties for breaches of financial sanctions can be up to 50% of the value of the breach or £1 million, whichever is greater. To impose a penalty, the person suspected of breaching financial sanctions must have "known, or had reasonable cause to suspect" they were in breach of the obligations or prohibitions imposed by financial sanctions legislation. Section 149 of the Policing and Crime Act contains a duty to publicise information about these penalties.
	Once a relevant party has been notified that OFSI intends to issue a monetary penalty, they have a statutory right, as set out in section 147 of the Policing and Crime Act, to request a review of their case by the Minister. The Minister may uphold the decision to impose the penalty and its amount, substitute a different amount, or cancel the decision to impose the penalty altogether. Section 147 of the Policing and Crime Act currently specifies that such monetary penalty reviews must be conducted "personally" by the Minister.
	This Act makes amendments to both the Policing and Crime Act 2017 and the Sanctions and Anti-Money Laundering Act 2018.