United Kingdom – European Sanctions Enforcement

September 9, 2026September 9, 2026 by Mark Handley

UK – HMRC issues £7.4m penalty for supply of goods to Russia

The UK’s HM Revenue and Customs has issued its largest sanctions-related Compound Penalty to date.

The company, Illumina Cambridge Limited, was fined £7,438,840.13 for breaches of the UK’s Russian sanctions.

The published Notice gives limited information on the breaches:

“Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations“.

Regulation 25(1) prohibits the direct or indirect making available of “restricted goods” or “restricted technology” either for use in Russia, or to a person connected with Russia.

Illumina Cambridge Limited voluntarily disclosed the conduct to HNRC and cooperated with the investigation.

As noted by HMRC “sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK“.

This is the third large fine/forfeiture handed out by UK authorities in the last few weeks following the £4.7m fine from OFSI (2 September) and the $5.2m forfeiture from the National Crime Agency (27 August).

September 2, 2026September 2, 2026 by Mark Handley

UK – OFSI imposes fine of £4.73m on investment bank

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Citibank NA in the amount of £4,732,830.58.

This is OFSI’s second largest fine since it was launched.

The fine relates to 970 payments in breach of the UK’s Russian sanctions with a total value of £19,720,127.32 with most of the payments taking place in the months after February 2022.

OFSI have Citibank a 20% voluntary self-disclosure and cooperation credit (and not the permissible 30%). The bank had voluntarily self-reported many of the breaches and payments, but was unaware of £6.9m of the payments being breaches until OFSI started to raise questions.

OFSI also provided Citibank with a 20% discount based on agreeing a settlement, under OFSI’s fairly new settlement methodology.

These discounts, against a starting point where the maximum fine is 50% of the value of the breaches, resulted in the penalty amount. It is worth noting that the new Chancellor has announced plans to increase the maximum fine to 100% of the value of the transfer.

The breaches all related to failings and delay in screening customers, recipients and correspondent banks. While OFSI’s Notice expresses sympathy with the high volume of designations that took place in 2022, it was critical of Citibank’s level of preparedness in the run up to February 2022 and of the high volume of errors including changes in policy that made the prevention of payments more difficult. OFSI also was critical of the time taken for the bank to report that it was holding frozen assets.

August 27, 2026August 27, 2026 by Mark Handley

UK – National Crime Agency agrees forfeiture of $5.2m to resolve sanctions and AML investigation

The UK’s National Crime Agency has issued a press release stating that it has entered into a settlement agreement with ENEX Premium Trading Limited, owned by Nadir Valiyev and registered in St Kitts and Nevis.

The press release states that the settlement involves no admission of criminality by either ENEX of Mr Valiyev.

The allegation that was investigated from 2024 onwards was that ENEX was involved in the shipment of stolen Ukrainian grain. The NCA obtained an Account Freezing Order in November 2024 over sums received from China between July and September 2024. It is those funds which have now been forfeited.

August 27, 2026August 27, 2026 by Mark Handley

UK – Russian-flagged vessel issued with movement direction to leave UK waters

The UK’s Department of Transport has today published information on events that took place on 27-28 January 2026.

On 27 January, the Russian-flagged, registered and operated vessel the Sinegorsk contacted HM Coastguard stating an intention to enter UK waters to undertake repairs to its hull.

The Centre for Transport Sanctions within the Department of Transport conducted an investigation into the sanctions status of the vessel.

After determining that the vessel was within the scope of the discretionary powers to issue a “movement direction”, the Secretary of State decided to issue such a direction. On 28 January HM Coastguard issued the notice to the Sinegorsk which proceeded to comply with the direction and leave UK waters.

August 24, 2026August 24, 2026 by Mark Handley

UK and Ireland – TikTok self reports possible sanctions breaches

It has been reported, here (behind a paywall), that TikTok Information Technologies UK Limited, has self-reported potential breaches of sanctions both to the UK’s Office of Financial Sanctions Implementation, and to Ireland’s Central Bank of Ireland, as well as to other unnamed regulators.

The information on the self-reporting comes from the most-recently filed company accounts, available from Companies House in England:

No other information is available on the sanctions regime, or regimes, involved, the nature of the potential breaches, or the progress in any regulatory investigations since April.

August 3, 2026August 3, 2026 by Mark Handley

United Kingdom – two fines for military export control breaches

On 27 July, the UK’s HM Revenue and Customs issued a “Notice to Exporters” relating to two companies fined £216,530.30 and £20,889.15 respectively.

The companies were not named.

The conduct was not described in any detail and only said to “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”.

The details of why and how these companies were able to secure a resolution via a compound penalty were also not provided, although the Notice says in general terms:

“Compound settlements may be offered where an exporter has:

voluntarily told HMRC about sanctions or export control breaches, and
committed a breach that was inadvertent or due to weaknesses in internal controls”.

July 30, 2026July 30, 2026 by Mark Handley

United Kingdom – £6.4m fine for strategic export control failures

Further to our earlier post reporting on the UK’s investigation into Airbus, HMRC has today issued a Notice to Exporters that Airbus Operations Limited (AOL) has entered into a compound settlement with HMRC under which it will pay a fine of £6,409,388 for offences under The Export Control Order 2008.

This is the largest fine imposed by HMRC under the compound settlement regime, and is another example of the new practice of sometimes naming companies that enter into such settlements.

The offences do not relate to sanctions but to the UK’s strategic export controls regime.

The breaches took place “over a sustained period” before November 2022 and were self-reported by AOL which cooperated with the investigation and has implemented remediation.

The breaches are described in only general terms as follows:

Article 29(2)(a-g) on multiple occasions for failing to keep accurate records of transfers of controlled technology as per the conditions of three of their Open General Export Licences (OGELs)
Article 29(3) on multiple occasions for failing to keep registers in relation to their OGELs
Article 29(2)(i) on multiple occasions for failing to keep accurate records contrary to the conditions of one of their OGELs
a Standard Individual Export Licence (SIEL) on one occasion, relating to a failure of licence conditions

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – sanctions enforcement statistics for HMRC in 2025/26

The UK’s HMRC has released enforcement statistics for 2025 and the first part of 2026 in a “Technical Note”:

22 criminal investigations with three charges and two (at the time of the release of the Note) pending trial;
58 seizures of sanctioned goods
1 compound penalty of £1,160,725.67 (see our previous post);
29 self-disclosures, with these being resolved as follows:
- 18 warning letters;
- 7 no further action letters;
- 1 compound penalty;
- 3 cases remain unresolved.

By way of cooperation with the Office of Trade Sanctions Implementation, there were 44 referrals to HMRC in 2025/2026, with 10 resulting in no further action, 13 relating to already-ongoing investigations; and 21 still under review.

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – charges dismissed against art gallery and transporter

Further to our earlier post, on 9 July, the charges against the art gallery Hauser & Wirth, and art logistics company Artay Rauchweger were dismissed on the basis of a pre-trial application. The dismissal was first reported by GIR behind a paywall.

The charges related to an allegation that the gallery sold a painting to a “person connected with Russia”. The relevant statutory definition (in regulation 19A(2)(a) of the UK’s Russian sanctions regulations), is that the person must be either “ordinarily resident in Russia” or “located in Russia”. The focus for the court was the first test.

The judge held that a properly directed jury would be unable to find that there was sufficient evidence that the buyer of the artwork was “ordinarily resident” in Russia at the time of the sale in July and August 2022.

The prosecution produced evidence of a continuing connection to Russia, but the judge is reported to have held that “the statutory test is not one of continuing connection, nationality or association, but ordinary residence”.

July 20, 2026July 20, 2026 by Mark Handley

United Kingdom – bail denied and trial date set for prosecution of captain of the tanker Smyrtos

Further to our earlier post, it is being reported that a hearing took place in London on Thursday of last week relating to the prosecution of Ajay Pant, the Indian national who was captain of the oil tanker the MV Smyrtos.

As part of the hearing Pant’s application to be released on bail was refused and a four week trial was listed to start on 15 December.

In addition, the court has scheduled a hearing on 12 November to hear an application by the defendant to have the charges dismissed. The reporting does not mention the basis for that application.