Tag: United Kingdom

Posted on by Mark Handley

United Kingdom – prosecution for exports of military goods to Iran, Libya, South Sudan, Sudan and Syria

As first reported by Global Investigations Review (behind a paywall), the UK is prosecuting two individuals for the suspected export of military goods to a range of countries including Iran, Libya, South Sudan, Sudan and Syria.

The defendants David Greenhalgh, 67, and Christos Farmakis, 47, pled not guilty to 17 charges at Southwark Crown Crown on 13 June.

The exports are said to have taken place between 2009 and 2016, with the prosecution underscoring the absence of limitation periods in the UK.

As stated by GIR:

“The defendants allegedly helped ship fighter jets, radar systems, missiles and ammunition to Libya; “battle tanks and associated spare parts”, AK-47 rifles, anti-tank missiles and ammunition to South Sudan; missiles, launchers and rocket-propelled grenades to Syria; and Pechora S-125 surface-to-air missile systems, radar equipment and MiG-29, Su-25 and Su-27 fighter jets to Sudan. …

Farmakis is further accused of being involved in the illicit supply of 5,500 AK-47 rifles and 100,000 tonnes of ammunition to Syria, as well as 25,000 pistols to an unnamed country and unspecified quantities of AK-47 rifles to South Sudan and Iran. 

Greenhalgh is separately accused of helping to export Mi-24V attack helicopters to Sudan”.

Trial has been set for April 2026. 

Posted on by Mark Handley

United Kingdom – conviction for sanctioned person failing to provide financial information

Global Investigations Review (behind a paywall) has reported on the conviction in the UK of Aozma Sultana.

As previously posted, the UK’s Charity Commission has started an investigation into Aozma Sultana in April 2024. She was designated under the UK’s post-Brexit terrorism sanctions.

She answered “do not remember” to most of the questions sent to her upon her designation, and did answer the requisite questions on three other occasions – twice more when OFSI chased for responses, and again after he arrest.

Sentencing is to take place on 6 August.

Posted on by Mark Handley

United Kingdom – law firm fined £600 for breach of Russian sanctions licence conditions

The Solicitors Regulation Authority (the “SRA”) has fined Steptoe International LLP £600 and given the firm a “rebuke” for breaches of the UK’s Russian sanctions.

The breaches are reported to have related to two clients, and involved non-compliance with the conditions of relevant licences granted by OFSI, which is a criminal offence. It is unclear whether this was a general licence or a specific licence.

The firm self-reported the breaches to the SRA, which accepted that the breaches were the result of “inadvertent human error”.

The report makes no mention of any involvement by OFSI.

Posted on by Mark Handley

United Kingdom – OFSI imposes £5,000 fine for refusing to respond to information request

The UK’s OFSI has announced a £5,000 monetary penalty imposed on Svarog Shipping & Trading Company Limited.

The fine was for failing to respond to an information request from OFSI in breach of regulation 74(1)(a) of the UK’s Russian sanctions regulation.

The Penalty Notice states that the request for information was made in the context of a wider “large and complex investigation into suspected breaches” of the UK’s sanctions in relation to Sovcomflot. That investigation is, presumably, ongoing.

Posted on by Mark Handley

United Kingdom – sentencing for first Russian sanctions convictions

Further to last week’s post, sentencing has now been completed against Dmitrii Ovsiannikov and Alexei Owsjanikow, who were both convicted of breaches of the UK’s sanctions regime.

As per a press release from the Crown Prosecution Service, Ovsiannikov was convicted of 8 counts of breaking the asset freeze imposed upon him as a designated person, and has been sentenced to 40 months in prison for each count with each sentence to be served concurrently. He was also convicted of two charges of money laundering.

The charges relate to the purchase of a car, the payment of private school fees, deposits into bank accounts and insurance.

Alexei Owsjanikow was convicted of 2 of the charges against him, relating to the payment of school fees on behalf of his brother-in-law, and was given a suspended 15 month prison sentence and made subject of a curfew order.

Posted on by Mark Handley

United Kingdom – first criminal convictions under the UK’s Russian sanctions

It is being reported that the jury in the criminal prosecution of designated person Dmitrii Ovsiannikov, his wife Ekaterina Ovsiannikova, and his brother in law Alexei Owsjanikow have returned two guilty verdicts and one acquittal.

See our earlier posts on the progress of this case here and here.

These are the first criminal convictions obtained by the UK authorities under the UK’s Russian sanctions regime, and the first criminal conviction under any sanctions regime since 2017. It is also a rare example of the prosecution of a designated person.

Ekaterina Ovsiannikova was acquitted on four counts of circumventing sanctions arising from payments to her husband of £76,000 in 2023.

Alexei Owsjanikow was acquitted of several counts relating to access to a car, arranging car insurance and use of a bank account. He was, however, convicted of two counts of circumventing sanctions relating to the payment of £41,027 in private school fees.

Dmitrii Ovsiannikov was convicted of six of the seven counts he was charged with, all relating to breaches of the asset freeze imposed upon him by reason of his status as a designated person.

Sentencing will take place in due course, and it is to be hoped that the judge’s Sentencing Remarks are made public.

Posted on by Mark Handley

United Kingdom – export control compound penalties issued totalling £3.7m

Yesterday the UK’s HMRC issued a Notice to Exporters publishing three recent compound penalties issued to exporters.

In line with HMRC policy when agreeing to a compound penalty resolution, the information provided on the offending, the offender, and the co-operation provided is limited, although in this instance it is specified that the penalties do not relate to sanctions breaches. The detail available states:

The settlements relate to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979. These do not relate to sanctions offences.

The 3 settlements agreed with UK companies were:

  • January 2025 – £10,900.00 was paid for export license breaches in relation to the export of military goods controlled by The Export Control Order 2008
  • February 2025 – £431,232.20 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
  • February 2025 – £3,231,762.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.

Posted on by Mark Handley

United Kingdom – OFSI fines Moscow subsidiary of UK law firm £465,000

The UK’s OFSI has published a penalty notice imposing a £465,000 fine on Herbert Smith Freehills CIS LLP (“HSF Moscow”) – a UK LLP which operated as the Moscow office of the law firm Herbert Smith Freehills (“HSF”)

The fine was reduced by half due to prompt self reporting by HSF (all the breaches had been reported by 15 July 2022) and further co-operation in the form of the conduct of an internal investigation.

The breaches of the UK’s sanctions were all done by HSF Moscow between 25 and 31 May 2022. The breaches arose from six payments made to designated persons with a total value of £3,932,392.10. The six breaches were:

  1. a payment into a bank account held at Sberbank (a designated bank) to clear an overdraft;
  2. Payment of three invoices valued at £3,903.76 for insurance issued by Sovcombank Life, a wholly-owned subsidiary of Sovcombank (a designated bank);
  3. Payment of £13,216.32 as a redundancy payment to an employee’s bank account held at Sberbank; and
  4. Payment of £3,915,232.31 into an account held by Alfa-Bank (a designated bank), although the transfer was swiftly reversed.

This case emphasizes above all the approach that OFSI takes in relation to accounts held at designated banks. In the view of OFSI payments into such accounts, albeit accounts held by non-designated persons, will amount to making funds available to a designated person.

In relation to the payment to a subsidiary of a designated person, OFSI also emphasizes the importance of appropriate due diligence to understand possible issues of ownership and control.

Posted on by Mark Handley

United Kingdom – enforcement update from the OFSI annual report for 2023/24

OFSI has published its annual report for the year 2023/2024.

The report provides the following data:

2021/22 – 147 investigations opened (and 101 closed);

2022/23 – 473 investigations opened (and 74 closed); and

2023/24 – 396 investigations opened (and 242 closed).

Of the 396 investigations opened in 2023/24, 288 were as a result of self-reporting with 108 opened through pro-active investigation or other means.

Further, OFSI’s report gives a break down of which sanctions regimes the investigations relate to:

  • 347 to Russian sanctions;
  • 21 to Libyan sanctions;
  • 9 to Iran sanctions; and
  • 19 across the other regimes.

The report also gives a break down of the 242 investigations closed during the year of the report:

  • 133 closed with a finding of no breach and sending a “No Further Action” letter;
  • 18 closed with a finding there was a breach and sending a “Warning” letter;
  • 1 closed with a finding of a breach and a referral to a regulator;
  • 1 closed with an OFSI public disclosure;
  • 61 closed without a final determination that there was a breach and sending a “No Further Action” letter; and
  • 28 investigations closed for “Other” reasons.

© 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