Partner Anna Bradshaw comments in the Global Investigations Review (GIR) on the civil monetary penalties imposed on Standard Chartered Bank by the UK Office of Financial Sanctions Implementation (OFSI), noting that the substantial reduction in the penalty amounts at the ministerial review stage are comparable to those seen in previous enforcement action and querying what this says about the fairness with which enforcement powers are exercised. “The degree of variance between OFSI and the reviewing Minister on both occasions when the process has been invoked suggests something more problematic may be at play”, she says. Read more