Key Takeaways

• OFSI has published updated enforcement guidance introducing a new case assessment matrix, discount structures, a settlement scheme, and fixed penalties for procedural breaches.
• The new framework allows for cumulative discounts for voluntary disclosure (up to 30%), settlement (20%), and the Early Account Scheme (up to 20%), which can reduce penalties by up to 70%.
• Fixed penalties of £5,000 or £10,000 will apply to information, reporting, and licensing breaches.
• OFSI plans to double maximum penalties to £2 million/100% of breach value.