Irene Polieri Authors Law360 Article on Office of Financial Sanctions Implementation’s Reform Plans

Article  |  December 8, 2025

Law360

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In an Expert Analysis feature for Law360, associate Irene Polieri looked in-depth at some of the key proposals of the Office of Financial Sanctions Implementation (OFSI) to reform its financial sanctions enforcement practices, and their potential impact on businesses.

Irene wrote that, if implemented, the changes could materially increase penalties, reduce discounts for voluntary disclosure, and introduce new ways of responding to breaches, such as settlement options. The reforms would bring OFSI’s enforcement framework closer to that of its U.S. counterpart, the U.S. Department of the Treasury’s Office of Foreign Assets Control.