United Kingdom – OFSI reveals 706 Russian sanctions investigations opened since February 2022

As first brought to wider attention by the Global Sanctions site, the UK’s Economic Secretary has provided a written answer on the UK Parliament’s website to the question: “how many investigations by the Office of Financial Sanctions Implementation into breaches of Russian sanctions (a) are open and (b) have been undertaken since February 2022“.

The answer stated that 388 cases have been investigated by OFSI and closed since February 2022, and that 318 investigations are currently open.

This is a total of 706 investigations opened by OFSI into potential or alleged Russian sanctions breaches in the UK since February 2022.

In that time OFSI has imposed two fines (here and here) in relation to Russian sanctions and disclosed one other breach by Wise Payments Limited (here).

This means that 385 of OFSI’s opened Russian investigations since February 2022 were closed without further action.

As of April 2023, OFSI was reporting it had 172 lives cases ongoing, indicating that there has been a significant increase since then.

United Kingdom – HMRC unaware of how many sanctions investigations it is currently conducting

Sky News in the UK has made a Freedom of Information Request to the UK’s primary trade sanctions enforcement body, His Majesty’s Revenue and Customs (HMRC), asking for the “number of cases you are currently investigating”.

See the Sky News piece here (including some comments from Mark Handley of this blog).

HMRC has responded (available here and with thanks to Sky News for providing a copy).

It has said that “the number of current investigations … is not centrally recorded. To determine how many investigations are within scope of your request would require a manual search of a significant number of records, held by different business areas“.

Sky News also asked about the identities of the entities or individuals which have received the six compound penalties for breaches of the UK’s Russian sanctions.

In line with HMRC policy this information was not disclosed because “HMRC do not consider that disclosing the company name would drive compliance, promote voluntary disclosure or be proportionate“.

While this has long been HMRC’s policy, the stance of OFSI and the new Office of Trade Sanctions Implementation is that they will each name the companies subjected to fines.

United Kingdom – National Crime Agency gives update on sanctions enforcement

As first reported by the BBC, the National Crime Agency has written to the Chair of the Treasury Committee of the House of Commons to respond to a series of questions about the NCAs sanctions enforcement efforts to date.

The letter confirms that there have been no convictions obtained under Russian sanctions, or indeed any sanctions regime since the coming into force of the Sanctions and Anti-Money Laundering Act in January 2021.

The NCA also stated that “a very small proportion” of its workload is sanctions-related, but it would not disclose how many cases had been referred to it by OFSI or any other body, or how many active investigations followed from the 5,600 sanctions-related suspicious activity reports it received in the year 2022-2023.

The letter also stated:

the NCA’s Combatting Kleptocracy Cell (CKC) has delivered over 150 disruptions, which include: asset freezes and forfeiture, taking action against key enablers, and supporting international partners” and then gave a number of specific examples including the successful forfeiture of £780,000 obtained in July 2024.

Another example given was “The arrest of enablers in the regulated sector who support the transactions of corrupt elites“, although no further detail was provided.

United Kingdom – three penalties imposed by HMRC for breaches of Russian trade sanctions

On 4 November 2024, HMRC published a Notice to Exporters regarding a compound penalty of £58,426.45 imposed for breaches of Russian trade sanctions.

The Notice included the line:

Since February 2022, HMRC has issued six compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million“.

This struck a chord because, as captured in this blog, only three compound penalties had been publicly imposed by HMRC for breaching Russian sanctions. So a Freedom of Information request was made about the other three.

The response is here.

The response discloses details of three compound penalties (totalling c. £237,000) from August and September 2022 and April 2023. These had each been previously published, but had not previously been described as relating to Russian sanctions.

  • August 2022 – £1,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
  • September 2022 – £19,689.20 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
  • April 2023 – £217,012.50 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.

It is unclear why these penalties were not previously described as relating to breaches of Russian sanctions.

The FOIA request also asked for the names of the individuals or companies which were the subject of the penalties; whether any had self-reported; and what (if any) confiscation of the proceeds of crime was applied. These questions were not answered.

United Kingdom – company convicted of export control violations

His Majesty’s Revenue and Customs (HMRC) has announced the conviction of the company EDM Limited on three counts of exporting controlled military goods without the appropriate licence.

The good in question were military flight simulators valued at £38,967.68.

The company was fined £89,359.80, including costs, but HMRC’s Notice does not mention whether a confiscation order was also made.

EDM Limited had been offered a civil compound penalty to resolve the matter but had not accepted the offer in time and so the case went to trial.

United Kingdom – further charges against individual already facing prosecution for breaching Russian sanctions

As an addition to the existing prosecution it is being reported that the National Crime Agency has added two new charges to those against Alexei Owsjanikow. It is alleged that he paid £41,027.25 on behalf of his brother-in-law, designated person Dmitrii Ovsiannikov, towards private school fees.

The payments are said to have been made in May this year, which would be after Owsjanikow had already been charged with other sanctions offences.

The trial for this prosecution is currently scheduled for March 2025.

United Kingdom – HMRC drops investigation into alleged perfume exports to Russia

Further to our earlier post about an HMRC criminal investigation into the alleged export of luxury perfume to Russia, it is now being reported by the BBC that the investigation has been dropped.

The report does not explain the rationale for discontinuing the investigation, but notes the the primary individual involved, a Mr Crisp, had been recorded on video by a private investigator who asked “How’s your Russian market”, to which the recorded response was “We’re doing really well… we ignore government edicts”.

Another director of the company compiled evidence of the alleged sanction breaches, and provided that to the authorities.

That example of self-reporting and co-operation may well explain why the company was not itself prosecuted. It is unclear why the director Mr Crisp has not been pursued. The investigation first came to light after a civil court ruled there was “strong prima facie evidential basis for the allegations” and ordered the removal of Mr Crisp from his position as director of the company.

United Kingdom – CPS advising on two further criminal prosecutions

Global Investigations Review (behind a paywall) has published the results of a Freedom of Information request to the Crown Prosecution Service which reveals that the CPS has been asked to advise on a total of three cases under Russian sanctions, two of which are not otherwise in the public domain.

One of the newly-revealed relates to financial sanctions, and the other to trade sanctions.

The third is case relates to the ongoing prosecution of three individuals.

The CPS has not yet added this Freedom of Information response to its website.

European sanctions enforcement: the custodial sentences

Although one of the filters on this blog is “custodial sentence”, I thought it might be helpful to collect all the examples in one place.

As such, here is the full list of custodial sentences that have been imposed across Europe for sanctions offences since 2017. Please note this excludes suspended sentences.

2017:

2018:

2019:

2020:

2021:

2022:

2023:

2024:

Overall the figures are dominated by the Netherlands and Germany with approximately 68 of the 80 years of sentences between them. Indeed, as the graph below demonstrates, other than Finland’s 40-day sentence for breaching a travel ban, the Netherlands and Germany are the only European countries to have sent someone to prison for sanctions offences since 2019.

United Kingdom – revised (and increased) figures for the number of OFSI’s oil price cap investigations: 60 to date

As of 27 September 2024, the position as regards OFSI’s investigations into alleged breaches of the UK’s oil price cap was as follows (covering the period from 5 December 2022 to 21 August 2024:

  • total number of investigations commenced: 60
  • total number of investigations commenced where the alleged suspect is a UK person or company: 52
  • total number of investigations which remain open: 42
  • total number of investigations which remain open where the alleged suspect is a UK person or company: 37

These figures revise those we published last month which were based on the BBC’s reporting of the results of a Freedom of Information request it had made to OFSI.

After obtaining a copy of what was released to the BBC by making our own Freedom of Information request we have been able to revise the figures. The BBC did not include in its figures the investigations into non-UK persons potentially breaching the UK’s oil price cap.

What the complete figures reveal is that a further 8 investigations have been commenced into non-UK persons suspected of breaching the oil price cap, of which 5 remain ongoing.

A copy of HM Treasury’s response to our asking for the response provided to the BBC is here.

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

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