TISA supports OFSI enforcement reforms but calls for greater consistency, proportionality and confidentiality incentives
The Investing and Saving Alliance (TISA) has today outlined its support for HM Treasury and OFSI’s proposals to streamline civil enforcement processes for financial sanctions, while recommending further improvements to ensure consistency across regulators, proportionality in penalties, and confidentiality incentives to encourage early settlement.
Sophie Legrand-Green, Head of Policy at TISA, said:
“Financial sanctions enforcement must be robust, but also fair, proportionate and consistent. We welcome OFSI’s efforts to streamline and modernise its approach to this end and would encourage further work to bring enforcement processes in line with the FCA. We would also recommend firms are incentivised to settle cases early through confidentiality protections, and that penalties reflect the real-world impact and intent behind breaches.
A more principles-based, transparent framework will deliver better outcomes for consumers, firms and the wider financial system. TISA stands ready to help the OFSI achieve a better financial crime framework.”
In its response to HM Treasury’s consultation, TISA expressed its support for proposals to introduce both a settlement scheme and an early account process, alongside proposed changes to case assessment guidance and voluntary disclosure discounts. These reforms represent positive steps toward a more efficient and transparent enforcement regime that encourages cooperation and early resolution.
To strengthen the proposals, TISA recommends that OFSI align its enforcement approach more closely with the FCA, ensuring firms receive consistent treatment regardless of which authority leads a case. It also suggests introducing time limits on settlement discussions to improve procedural efficiency and offering confidentiality protections as part of settlement agreements to incentivise early engagement.
TISA further calls for a principles-based framework for determining penalties – one that considers the intent behind breaches, their severity, and the financial impact involved. Maximum penalties should also be tailored to the type of breach, ensuring that enforcement outcomes are proportionate and targeted at the most serious infractions.
ENDS
Notes to Editors:
- TISA’s full response to HM Treasury’s consultation Improving civil enforcement processes for financial sanctions is available on request.
- HM Treasury’s consultation Improving civil enforcement processes for financial sanctions can be found here.
- TISA is a not-for-profit membership organisation committed to improving the financial wellbeing of all UK consumers by working collectively with the financial services industry to deliver solutions and champion innovation, for the benefit of people, our industry, and the nation.
- TISA has approximately 270 member firms involved in the supply and distribution of savings and investment products and associated services. Members include the UK’s major investment managers, retail banks, online platforms, insurance companies, pension providers, distributors, building societies, wealth managers, third party administrators, FinTechs, financial consultants, financial advisers, industry infrastructure providers and stockbrokers.