Today OFSI announced it had imposed a £50,000 financial penalty on TransferGo in the latest example of the use of its civil enforcement powers.
OFSI’s penalty notice is available here.
The fine was imposed in relation to 16 transactions over nearly 2 years valued at just £7,674.77 through which funds were made available Russian National Commercial Bank, which is a designated person under the EU’s Russian sanctions.
TransferGo did not self report but did cooperate with the investigation.
OFSI’s notice makes clear that the RNCB was not the intended beneficiary of the transactions, rather the recipients of the transfers were accounts held by non-designated persons with RNCB. OFSI has made clear that as funds held in bank accounts are legally held by the banks, that these transfers all amounted to making funds available to RNCB