Who was sanctioned, and for what?

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).

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

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).

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

The company paid HMRC a compound settlement of £569,157.07 for alleged breaches of the Russia sanctions. According to HMRC, while withdrawing from Russia in 2022/2023 it allegedly made sanctioned industrial goods available on two occasions to a person connected with Russia or for use in Russia, and provided related technical assistance. According to HMRC, this is the first time it has publicly named the company behind such a settlement.

Authority / court

HM Revenue & Customs (HMRC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Reg. 46Y(2)(c) und Reg. 46Z(1)(b) Russia (Sanctions) (EU Exit) Regulations 2019

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Voluntary disclosure and full cooperation with HMRC.

Published

29 Jun 2026

Original amount 569,157.07 GBP, converted at the ECB reference rate of 29 Jun 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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. According to the annual accounts filed with the UK companies register for financial year 2024, the company had around 150 employees.

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

Employees

50 to 249

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 28 Sep 2026 · Version 3 · Direct link

On 30 April 2026 OFSI imposed a monetary penalty of GBP 165,000 on the London branch of Deutsche Bank AG by way of settlement. According to OFSI's findings, in June and July 2022 the branch processed two payments totalling GBP 635,618.75 for a customer to a Russian app developer owned by a designated entity. According to OFSI, its screening provider's list did not contain ownership information on the designated entity, so the beneficiary was not identified. The bank had voluntarily disclosed the payments on 20 September 2022. After a notice of intent of 12 September 2025, which OFSI upheld on 2 December 2025, the bank requested a ministerial review on 23 January 2026; the proceedings ended in settlement. The publication does not state the amount originally proposed. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of Monetary Penalty – Deutsche Bank AG London Branch (“DBLB”)", 19 May 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-deutsche-bank-ag-london-branch-dblb. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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; Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

19 May 2026

Original amount 165,000 GBP, converted at the ECB reference rate of 30 Apr 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

On 19 March 2026 OFSI imposed a monetary penalty of GBP 390,000 on Ireland-based Apple Distribution International Limited by way of settlement. According to OFSI's findings, the company, which pays out revenues to software developers on an app marketplace, instructed two payments totalling GBP 635,618.75 in June and July 2022 from a UK bank account to a Russian app developer owned by a designated entity, and did not cancel the instructions. OFSI identified reliance on developers' self-declarations and on third-party data, among other things, as causes. The company had voluntarily disclosed the payments on 4 October 2022. The settlement followed a notice of intent of 11 November 2025 and was reached under the settlement process introduced in February 2026; OFSI made no findings against the parent company. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Apple Distribution International Limited", 30 March 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-apple-distribution-international-limited. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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; Geldbuße nach s. 146 Policing and Crime Act 2017 (Settlement)

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Published

30 Mar 2026

Original amount 390,000 GBP, converted at the ECB reference rate of 19 Mar 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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).

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

On 10 November 2025 OFSI imposed a monetary penalty of GBP 160,000 on Bank of Scotland PLC; without the 50 per cent discount for voluntary disclosure it would have been GBP 320,000, according to OFSI. According to OFSI's findings, between 8 and 24 February 2023 the bank processed 24 payments totalling GBP 77,383.39 through the account of a person designated under Russia sanctions, including credits of GBP 76,000. According to OFSI, screening failed to pick up a variant of the name, and a human error occurred during a PEP review on 20 February 2023. The notice of intent of 28 August 2025 had proposed GBP 175,000. The bank did not request a ministerial review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Bank of Scotland PLC", 26 January 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-bank-of-scotland-plc. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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. 11, 12; Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

26 Jan 2026

Original amount 160,000 GBP, converted at the ECB reference rate of 10 Nov 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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. According to the annual accounts filed with the UK companies register for financial year 2025, the company had around 280 employees.

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

Employees

250 to 999

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 28 Sep 2026 · Version 3 · Direct link

On 8 September 2025 OFSI published a report on sanctions breaches by Vanquis Bank Limited but did not impose a monetary penalty. According to OFSI's findings, the account of a person designated under counter-terrorism sanctions remained fully usable for eight days after the designation; during that time GBP 200 was withdrawn in cash and a purchase of GBP 8.99 was made. OFSI had given the bank advance notice the day before the designation. According to OFSI, the staff responsible had been redeployed to remediation work, so the internal one-day deadline for the freeze was missed. The bank reported the breach itself, but only 13 days after the designation. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Disclosure notice: 08 September 2025", 8 September 2025, https://www.gov.uk/government/publications/disclosure-notice-08-september-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

regulations 11 and 12 of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019; Veröffentlichung nach section 149(3) Policing and Crime Act 2017

Action

Other

Status of proceedings

unknown

Sector

Financial services and insurance

Published

8 Sep 2025

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

A UK exporter not named by HMRC paid a compound settlement of £1,160,725.67 in May 2025 over alleged breaches of the Russia sanctions. According to HMRC, it had made goods available to Russia. According to HMRC, it was at the time of the notice the largest settlement the authority had concluded for a breach of the Russia sanctions; among the lessons, HMRC highlights the risk of supplying Russian companies with operations in third countries.

Authority / court

HM Revenue & Customs (HMRC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Russia (Sanctions) (EU Exit) Regulations 2019

Action

Fine

Status of proceedings

final

Sector

Other

Published

8 Jul 2025

Original amount 1,160,725.67 GBP, converted at the ECB reference rate of 8 Jul 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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.

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

A UK company not named by HMRC paid a compound settlement of £3,231,762.40 in February 2025 in lieu of prosecution over the alleged export of military goods without the licence required under the Export Control Order 2008. HMRC set out the facts in these terms. It was the largest of three settlements totalling close to £3.7 million that HMRC concluded between January and March 2025; no sanctions offences were involved.

Authority / court

HM Revenue & Customs (HMRC)

Area of law

Sanctions and export control · Export control and dual-use goods

Legal basis

Export Control Order 2008; Customs and Excise Management Act 1979

Action

Fine

Status of proceedings

final

Sector

Defence and security

Published

9 Apr 2025

Original amount 3,231,762.4 GBP, converted at the ECB reference rate of 9 Apr 2025.

Checked against the official source on 3 Oct 2026 · Direct link

On 14 March 2025 OFSI published a report on breaches by three UK charities – Sahara Hands, Peculiar Peoples' Palace Ministries and Impact Planet – of information requirements under counter-terrorism sanctions law; OFSI did not impose a monetary penalty. According to OFSI's findings, the organisations had failed without reasonable excuse to provide information in response to a formal request, despite three letters. OFSI made clear that this concerns an information offence only and that it holds no information indicating any further breach of the sanctions regulations. OFSI considers it possible that out-of-date contact details on the Charity Commission register played a role, but did not treat this as mitigating. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Disclosure notice: 14 March 2025", 14 March 2025, https://www.gov.uk/government/publications/disclosure-notice-14-march-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019, reg. 36(6); Veröffentlichung nach s. 149(3) Policing and Crime Act 2017

Action

Other

Status of proceedings

unknown

Sector

Other

Published

14 Mar 2025

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

On 10 January 2025 OFSI imposed a monetary penalty of GBP 300,000 on the UK company Markom Management Limited, which in 2018 provided fiduciary, administration and bookkeeping services to companies. According to OFSI's findings, on 20 February 2018 the company instructed the return of an overpayment of around GBP 416,590 to a person designated under EU law, thereby making funds directly available to that person. OFSI attributed this to a lack of processes, poor knowledge of sanctions and a wish to make the payment quickly. The company reported the breach in October 2018; OFSI did not grant a disclosure discount. The notice of intent of 1 August 2024 had proposed GBP 400,000; after representations from the company OFSI reduced the amount. A ministerial review upheld the penalty on 4 June 2025. The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Markom Management Limited", 31 July 2025, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-markom-management-limited. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 (Umsetzung der Verordnung (EU) Nr. 269/2014); Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Published

31 Jul 2025

Original amount 300,000 GBP, converted at the ECB reference rate of 10 Jan 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

On 11 November 2024 OFSI imposed a monetary penalty of GBP 465,000 on Herbert Smith Freehills CIS LLP, the Moscow office of an international law firm; without the 50 per cent discount for voluntary disclosure it would have been GBP 930,000, according to OFSI. According to OFSI's findings, between 25 and 31 May 2022 the entity made six payments totalling GBP 3,932,392.10 to three designated Russian banks, partly in the course of closing the office. OFSI identified insufficient checks and a lack of sanctions screening of the payments, as well as haste in winding down, as causes. OFSI made no findings against the London parent. A ministerial review upheld the penalty on 14 February 2025, and on 14 March 2025 the London parent agreed to pay the penalty in full on the entity's behalf. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Herbert Smith Freehills CIS LLP Moscow", 20 March 2025, https://www.gov.uk/government/publications/penalty-notice-20-march-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019; Geldbuße nach section 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Other

Published

20 Mar 2025

Original amount 465,000 GBP, converted at the ECB reference rate of 11 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

On 29 August 2024 OFSI imposed a monetary penalty of GBP 15,000 on a UK concierge and property services company. According to OFSI's findings, the small property management company made or received 26 payments totalling GBP 15,487.30 in 2022 and 2023 in connection with a property owned by a designated person, thereby dealing with frozen funds or making funds available for that person's benefit. Other payments were covered by a general licence, but the company failed to make the reports the licence required; OFSI treated this as a further breach and as an aggravating factor but did not impose a separate penalty for it. The company had not disclosed the breaches voluntarily. It made no representations and did not request a ministerial review. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

regulations 11(1) and 13(1) of the Russia (Sanctions) (EU Exit) Regulations 2019; Geldbuße nach section 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Construction and real estate

Published

26 Sep 2024

Original amount 15,000 GBP, converted at the ECB reference rate of 29 Aug 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 29 Aug 2026 · Direct link

HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a report on 31 August 2023 on a sanctions breach by a UK payments firm but did not impose a monetary penalty. According to OFSI's findings, on 30 June 2022, one day after the designation, GBP 250 in cash was withdrawn using a debit card on a business account, although the account belonged to a company owned or controlled by a designated person. The account itself had been restricted after a screening match, but the card had not; according to OFSI, the internal policy did not provide for cards to be frozen in such cases, and no specialist team was available at the weekend, so the card was only frozen on 4 July 2022. OFSI treated this as making funds available to a company owned or controlled by a designated person. The company had reported the incident itself and changed its processes; OFSI considered publication rather than a penalty to be appropriate. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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; Veröffentlichung nach s. 149(3) Policing and Crime Act 2017

Action

Other

Status of proceedings

unknown

Sector

Financial services and insurance

Published

31 Aug 2023

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 31 Aug 2025 · Direct link