UK – OFSI imposes civil penalty for sanctions breaches

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

UK: OFSI imposes £20.4m civil penalty

Today the UK’s Office of Financial Sanctions Implementation imposed a civil penalty of £20,471,809.83 on Standard Chartered Bank in the latest (and largest) use of its civil enforcement powers. The fine included a 30% reduction to take account of self-reporting and cooperation.

OFSI’s Penalty Report can be found here.

The breaches of the EU’s Russian sanctions regulation 833/2014 arose out of the provision of multiple loans to the non-EU subsidiary of a Russian bank in breach of the restrictions on certain Russian banks accessing the EU’s capital markets. In total 21 loans valued at over £97m were issued during the period after OFSI acquired its civil enforcement powers.

Initially OFSI’s fines were £31.5m, but the fines were reduced after Standard Chartered exercised its right to a ministerial review of the penalties.

 

Latvia – bank fined €1.1m for Russian sanctions compliance failings

The Latvian financial services regulator (the FKTK) has fined SEB Bank €1.8 million, of which €1,121,140 related to shortcomings in the bank’s sanctions compliance.

The inspections leading to the fine had taken place in 2017 and 2018.

The failings are said to have been specific to the EU’s Russian sanctions in regulation 269/2014 (as amended).

The fine was stated to be for not screening for companies and other assets owned by designated persons.

France – Council of State upholds €50m fine for bank’s sanctions compliance failings

The French Council of State has today dismissed the appeal by Banque Postale against the fine of €50m imposed by the regulator, the ACPR.

The fine was imposed for EU sanctions compliance failings which had permitted designated persons subject to asset freezes to still transfer funds through the use of “money orders”.

This is the largest fine imposed by the French authorities.

See our earlier post in relation to the original fine.

Luxembourg – regulator imposes fines for sanctions screening failures

The Luxembourg financial services regulator, the CSSF, has today fined Banque Puilaetco Dewaay Luxembourg SA €15,000 for AML and sanctions compliance failings.

The penalty notice noted that the failing was “a temporary deficiency of the ongoing screening system of the client database against sanction lists”, and noted that the deficiency had since been remediated.

UK – FCA imposes fine of £102m

The UK’s Financial Conduct Authority has issued a Decision Notice against Standard Chartered Bank including a fine of £102,163,200.

The fine related to KYC failings in general, with a focus on failure to conduct customer due diligence even in situations where sanctions red flags were evident. The FCA noted a lack of financial crime risk, and concerns as to the quality of the advice being given.

A particular focus were the UAE branches of the bank, and also export financing in relation to the export of military goods.

© 2009-2025 Duane Morris LLP. Duane Morris is a registered service mark of Duane Morris LLP.

The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

Proudly powered by WordPress