Financial Services – Page 2 – European Sanctions Enforcement

August 4, 2025August 4, 2025 by Mark Handley

United Kingdom – OFSI imposes a fine of £300,000 for breach of EU Russian sanctions

OFSI has published a Penalty Notice fining a UK company Markom Management Limited (“MML”) £300,000 for breaches of The Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014.

The fine was for issuing a payment instruction to return an overpayment of £416,590.92 to a Russian bank account belonging to a designated person.

The fine was initially set at £400,000, but was reduced through the ministerial review process.

This penalty is noteworthy for a number of reasons:

This enforcement action dates from events in 2018. While underscoring the slowness of OFSI’s enforcement steps it also reinforces the lack of a limitation period for the UK’s sanctions, and the fact that the UK continues to enforce the EU sanctions that were in place before Brexit.
The self-reporting by MML was considered insufficient to trigger a discount to the imposed penalty.
The conduct that warranted the penalty was a person in the UK sending a payment instruction to a bank in Russia to transfer funds to another bank in Russia. This is a reminder of the broad reach of the UK’s criminal jurisdiction when it comes to communications sent in or out of the jurisdiction. This penalty notice sits uneasily alongside the recent civil decision in Celestial Aviation Trading Ireland Ltd & Ors v Volga-Dnper Logistics BV [2025] EWHC 1156 (Comm).

July 1, 2025July 1, 2025 by Mark Handley

France – financial services regulator fines bank €600,000 for sanctions compliance failings

France’s ACPR has issued a press release making public a fine of €600,000 imposed on Banque Delubac.

The detailed Décision, make clear that the compliance failings predominantly relate to AML and CTF failings, but Complaint 9 relates to sanctions compliance. The ACPR noted a failure by the bank to collect data on directors and beneficial owners for more than a quarter of its business customers. Further, the bank applied no screening at all on transactions valued at below €1,000 between 2020 and 2022/203.

The size of the fine is said to reflect the €3m spent on improving the bank’s compliance, and the bank’s loss for the financial year 2024.

June 11, 2025June 11, 2025 by Mark Handley

Netherlands – DNB issues instruction to trust office regarding sanctions compliance

The Nederlandsche Bank (DNB) has issued a press release relating to Erez Corporate Service B.V.

Erez was issued an “instruction” in June 2021 by the DNB in relation to the remediation of various compliance failings, including compliance with EU sanctions.

Erez has sought to challenge, and then appeal, this instruction, but those efforts have not been successful which is why the DNB are now publishing the details of the instruction.

April 14, 2025 by Mark Handley

Norway – investigation into shadow fleet “insurance” provider

It has been reported that police in Oslo are investigating a company called Romarine AS, as well as four individuals (two Norwegians, a Russian and a Bulgarian) relating to the insurance services provided to Russian shadow fleet vessels, and vessels sanctioned by the EU.

The allegations include the provision of faked insurance documentation purporting to show that the vessels had valid insurance, and the provision of unauthorised insurance services.

The Oslo Police were referred the case by the Norwegian Financial Supervisory Authority which has issued an order for Romarine to cease operations.

April 11, 2025November 28, 2025 by Mark Handley

Finland – regulator’s audit findings on S-Bank’s sanctions compliance

Finland’s Financial Supervisory Authority has published the results of an “audit” on S-Bank PLC’s compliance with the EU’s Russian sanctions.

The audit revealed a “very significant lack” of effective controls in terms of the deposit limits imposed by the EU’s sanctions. Also highlighted was a lack of training and a lack of “sufficiently effective procedures” for sanctions compliance.

The audit also noted that there was a lack of independent supervision of business units with risk control sitting within each unit and being involved in the initial business decisions and so were unable to provide an independent check on those decisions.

Overall the audit findings were described as being of “high significance”, but it is unclear what further regulatory action might be taken.

April 8, 2025April 8, 2025 by Mark Handley

Luxembourg – CSSF issues fine for AML and sanctions compliance failings

A fine imposed by Luxembourg’s financial services regulator on the Luxembourg subsidiary of the Allianz Group has become public after a court dismissed an appeal.

The fine of €283,000 was first imposed on 25 March 2022, but only published on 4 April 2025 after the conclusion of the court challenge.

One of the compliance issues identified included failures to “provide evidence of complete initial and ongoing name screening against … sanctions lists”.

January 2, 2025January 2, 2025 by Mark Handley

Bermuda – trust company fined $600,000 for sanctions and AML compliance failings

On 30 December the Bermuda Monetary Authority announced the imposition of a fine of $600,000 on Meritus Trust Company Limited for a series of AML and sanctions compliance failings.

In terms of sanctions compliance the failing was specified as “An overreliance on manual processes to implement international sanctions policies and procedures and sanctions screening“.

The BMA’s on-site investigation was commenced in June 2022 and the company was then given a deadline of July 2023 to complete the necessary remediation. The BMA was satisfied with the company’s efforts and noted a number of mitigating factors such as a low risk of loss to clients, co-operation, the remediation efforts, and the company’s overall culture of compliance.

This is a rare example of a sanctions enforcement fine being imposed in one of the UK’s overseas territories or crown dependencies. The only other example known (to this blog) are the fines and other punishments imposed in Guernsey in 2015/2016.

October 21, 2024October 21, 2024 by Mark Handley

Netherlands – sanctions compliance fine on trust services provider upheld

The Rotterdam District Court has largely upheld a fine of €95,000 imposed on a trust services provider by the Dutch National Bank.

The DNB’s investigation started in 2019, and the fine was originally imposed on 2022.

The fine related to compliance failings including both money laundering and sanctions failures. The firm’s policies and procedures were insufficient and there was a lack of proper identification of the UBO and of ongoing diligence.

On appeal the fine was reduced to €90,250 due to an argument that the investigation process had been unduly lengthy,

October 2, 2024October 2, 2024 by Mark Handley

UK – FCA fines bank £29m for sanctions compliance failings

The UK’s Financial Conduct Authority has today fined Starling Bank £28,959,426 for sanctions compliance failings.

The Final Notice states that the bank became aware in January 2023 that its screening was being done against a small sub-set of the Consolidated List of sanctions targets.

The FCA described the compliance program at Starling as “shockingly lax”.

The FCA also noted that the fine would have been £40,959,426 without Starling’s agreement to resolve the matter.

September 27, 2024September 27, 2024 by Mark Handley

UK – OFSI imposes £15,000 civil penalty

The UK’s Office of Financial Sanctions Implementation has today issued notice of a civil monetary penalty it has imposed on a company called Integral Concierge Services Limited (“ICSL”).

The penalty was for £15,000.

The fine related to 26 payments made to, or received from, a designated person under the UK’s Russian sanctions. The payments related to property management including collecting rent, paying for maintenance, and ICSL taking its own management fees. The designated person was not named.

The company did not initially self-disclose, but did then cooperate including by disclosing breaches that had not yet been identified by OFSI.

The company also breaches the reporting requirements under several general licences, but OFSO chose to not fine in relation to those breaches but rather to treat those failures as aggravating factors.