Introduction


As part of our ongoing commitment to strengthening the UK’s enforcement regime, on 31 August 2023, OFSI used its new Disclosure enforcement power for the first time. In brief, this power allows OFSI to publish details of financial sanctions breaches - including the person/entity who committed the breaches – where OFSI decides that the breaches are not serious enough to justify a civil monetary penalty. OFSI acquired this power last year via the Economic Crime (Transparency and Enforcement) Act 2022, and it forms an important part of our expanded enforcement toolkit. 

In the US, FinCEN and IRS issued a joint advisory on tax evasion shell companies which outlines various ways in which individuals perpetrate tax and workers compensation insurance fraud, typically involving two schemes and provides red flags for institutions.