OFSI has today issued a second penalty for breach of the EU’s Russian sanctions, again using its civil enforcement powers.
The penalty notice is available here.
The penalty, of £36,393.45, was imposed on Clear Junction Limited. The transactions in this case are the same as those relating to TransferGo, although OFSI makes clear that it was Clear Junction which reported the transactions. It is noteworthy that some of the impugned transactions took place after the first report to OFSI.
OFSI’s notice also makes the point that the breach here was of the EU’s Russian sanctions, and that post-Brexit OFSI will continue to investigate breaches of the EU’s regulations that may have taken place before Brexit.