Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 756 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

7cases from 1 jurisdiction
€15.1mTotal of monetary amounts (6 cases with an amount)
€7.48mLargest single case: Airbus Operations Limited
€932,853Median per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. HM Revenue & Customs (HMRC) / Export Control Joint Unit €8.18m 54 % · 2 cases
  2. HM Treasury, Office of Financial Sanctions Implementation (OFSI) €6.88m 46 % · 4 cases
  3. Leeds Crown Court; Ermittlungen HM Revenue & Customs — 0 % · 1 case

What for?

by topic
  1. Export control and dual-use goods €8.18m 54 % · 3 cases
  2. Breaches of sanctions and embargoes €6.88m 46 % · 4 cases

Who?

by sector

All sectors

  1. Manufacturing and mechanical engineering €7.48m 50 % · 1 case
  2. Financial services and insurance €5.54m 37 % · 1 case
  3. Telecoms, IT and software €1.16m 8 % · 1 case
  4. Defence and security €706,898 5 % · 2 cases
  5. Chemicals and pharmaceuticals €176,590 1 % · 1 case
  6. Transport, logistics and shipping €5,768 0 % · 1 case

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20230—
Q1 20240—
Q2 20240—
Q3 20240—
Q4 20240—
Q1 20250—
Q2 20251€5,768
Q3 20251€176,590
Q4 20251€706,898
Q1 20261—
Q2 20261€1.16m
Q3 20262€13m

7 cases

11 Aug 2026 Citibank, N.A., London BranchOFSI imposes 4.7 million GBP on Citibank London over Russia payments United KingdomBreaches of sanctions and embargoes €5.54m

Mainly between February and November 2022, the London branch processed 970 payments totalling around 19.7 million GBP that breached Russia and anti-corruption sanctions. The causes were overloaded alert handling after the wave of designations, delayed escalation and human error; the bank voluntarily disclosed most of the breaches and received a 20% reduction from HM Treasury's Office of Financial Sanctions Implementation (OFSI).

What organisations can take from it

During waves of designations, alert handling needs additional trained capacity – backlogs and wrong decisions in screening are themselves sanctions breaches.

Relevance to training and awareness

Handling sanctions alerts, escalation and freezing

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Russia (Sanctions) (EU Exit) Regulations 2019; Global Anti-Corruption Sanctions Regulations 2021; s. 146 Policing and Crime Act 2017
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Predominantly voluntary disclosure and cooperation (20% reduction); exceptional burden caused by the 2022 sanctions packages taken into account
Published
2 Sep 2026

Original amount 4,732,830.58 GBP, converted at the ECB reference rate of 11 Aug 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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30 Jul 2026 Airbus Operations LimitedAirbus Operations pays 6.4 million GBP for export control breaches in technology transfer United KingdomExport control and dual-use goods €7.48m

Over an extended period before November 2022, Airbus Operations Ltd breached the Export Control Order 2008: transfers of controlled technology under three open general export licences (OGEL) were not correctly documented, required registers were missing, and one individual licence was not complied with. The case came to light through voluntary disclosure and was concluded by HM Revenue & Customs (HMRC) by way of a compound settlement (date of publication).

What organisations can take from it

Technology transfers by e-mail or data room are also exports – conditions, registers and records of general licences must be put into practice day to day.

Relevance to training and awareness

Licence conditions and record-keeping obligations in technology transfer

Authority / court
HM Revenue & Customs (HMRC) / Export Control Joint Unit
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
Export Control Order 2008, Art. 29(2) und 29(3) (Auflagen und Register bei OGELs) sowie Auflage einer SIEL; Straftaten nach Art. 38(1)(a) und (b); Compound Settlement durch HMRC
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Employees
10,000 or more
Mitigating circumstances
Voluntary disclosure, full cooperation, remedial measures
Published
30 Jul 2026

Original amount 6,409,388 GBP, converted at the ECB reference rate of 30 Jul 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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26 May 2026 Sabre Global Technologies LimitedSabre subsidiary accepted payments from designated Ural Airlines United KingdomBreaches of sanctions and embargoes €1.16m

The provider of a travel booking system continued to provide services to Ural Airlines, designated in May 2022, requested payments of around 906,600 USD and, after the funds were frozen by the bank, looked for alternative payment routes, which HM Treasury's Office of Financial Sanctions Implementation (OFSI) regarded as circumvention. A lack of escalation during a change of roles, vacant leadership positions in legal and compliance, policies focused on US law and screening that did not flag the designation all contributed.

What organisations can take from it

If an existing customer is designated, escalate this immediately; looking for alternative payment routes after the bank has frozen funds is itself a breach.

Relevance to training and awareness

Responding to new designations of existing customers, prohibition of circumvention

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Russia (Sanctions) (EU Exit) Regulations 2019, regs. 13, 14, 19
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
Voluntary disclosure (31 October 2022) and full cooperation; settlement under the new settlement procedure
Published
17 Jun 2026

Original amount 1,000,920.59 GBP, converted at the ECB reference rate of 26 May 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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6 Feb 2026 Company boss jailed: military thermal imaging rifle scopes to Hong Kong United KingdomExport control and dual-use goods Custodial sentence

A company director from Wakefield attempted to export eight thermal imaging rifle scopes classified as military goods (ML1d) to Hong Kong without a licence, declaring them as cheap cameras; Border Force stopped consignments in 2022 and 2023, and a search, following investigations by HM Revenue & Customs, revealed ten further exports. Leeds Crown Court sentenced him to two years and one month's imprisonment.

What organisations can take from it

False descriptions of military goods lead directly to personal criminal liability of management.

Authority / court
Leeds Crown Court; Ermittlungen HM Revenue & Customs
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
Customs and Excise Management Act 1979, ss. 68, 167; UK Military List ML1d; Waffenembargo China/Hongkong
Action
Custodial sentence
Status of proceedings
unknown
Sector
Defence and security
Culpability
intentional
Liability of senior managers
The director Steven Gates was personally sentenced to 2 years and 1 month's imprisonment.
Published
19 Feb 2026
Sources

Checked against the official source on 25 Sep 2026 · Direct link

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1 Dec 2025 British exporter pays 620,515 GBP for unlicensed exports of military goods United KingdomExport control and dual-use goods €706,898

In September 2025, an unnamed British exporter paid a compound settlement of 620,515.04 GBP to HM Revenue & Customs (HMRC) for unlicensed exports of military goods. HMRC offers such settlements only for unintentional breaches or weaknesses in internal controls and following voluntary disclosure (date = publication).

What organisations can take from it

Weaknesses in internal export control become expensive even without intent – disclosing breaches early can avoid prosecution.

Relevance to training and awareness

Classification of goods and licensing requirements for military goods

Authority / court
HM Revenue & Customs (HMRC) / Export Control Joint Unit
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
Export Control Order 2008
Action
Fine
Status of proceedings
final
Sector
Defence and security
Culpability
negligent
Mitigating circumstances
Voluntary disclosure (prerequisite for the compound settlement)
Published
1 Dec 2025

Original amount 620,515.04 GBP, converted at the ECB reference rate of 1 Dec 2025.

Checked against the official source on 25 Sep 2026 · Direct link

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10 Sep 2025 Colorcon LimitedPharmaceutical supplier Colorcon paid Moscow salaries via sanctioned banks United KingdomBreaches of sanctions and embargoes €176,590

In 2022, the Moscow office of the British subsidiary made payments – mainly salaries – to accounts at Alfa-Bank, Promsvyazbank, Sberbank and VTB; after deduction of payments covered by a general licence, around 128,300 GBP remained in breach. The approval process in the UK checked only the amount and the recipient, not the bank; because of a four-month delay in reporting, HM Treasury's Office of Financial Sanctions Implementation (OFSI) granted only a 35% instead of a 50% reduction.

What organisations can take from it

Anyone approving payments must also screen the recipient's bank against sanctions lists – and report breaches discovered without delay.

Relevance to training and awareness

Payment approval with screening of the recipient bank, prompt reporting

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Russia (Sanctions) (EU Exit) Regulations 2019, reg. 12
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Disclosure and full cooperation, but delayed
Published
30 Sep 2025

Original amount 152,750 GBP, converted at the ECB reference rate of 10 Sep 2025.

Checked against the official source on 25 Sep 2026 · Direct link

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11 Apr 2025 Svarog Shipping & Trading Company LimitedTanker shipping company Svarog left OFSI information request unanswered United KingdomBreaches of sanctions and embargoes €5,768

In the context of investigations into dealings with a Sovcomflot subsidiary, the fuel shipping company registered in the UK and operating from Cyprus did not respond in time to a formal information request from HM Treasury's Office of Financial Sanctions Implementation (OFSI); a response only came after contact via its auditors. No sanctions breach as such was found, but the information offence was.

What organisations can take from it

Information requests from sanctions authorities need a clear intake channel and deadline monitoring – merely missing the deadline is already an offence.

Relevance to training and awareness

Handling requests from authorities and deadlines

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Russia (Sanctions) (EU Exit) Regulations 2019, regs. 72, 74(1)(a)
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Culpability
negligent
Mitigating circumstances
Minor, indirect harm; the response was provided subsequently
Published
8 May 2025

Original amount 5,000 GBP, converted at the ECB reference rate of 11 Apr 2025.

Checked against the official source on 25 Sep 2026 · Direct link

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