The 2018/2019 Annual Report of the Office of Financial Sanctions Implementation (OFSI) revealed that the value of sanctions breaches self-reported to the agency fell by more than a billion pounds in the last financial year.  Partner Anna Bradshaw said that the parallel decline in the number of reports submitted could be the start of a trend, and that companies may have been turned off self-reporting after OFSI imposed an inaugural civil monetary penalty on Raphael’s Bank in February for a breach in connection with a £200 transaction.  “The size of the OFSI’s first civil fine is not what companies are worried about”, she said.  “It’s the fact they went after a company that had self-reported,” she added.  Read more