United Kingdom – European Sanctions Enforcement

June 29, 2026June 29, 2026 by Mark Handley

UK – compound penalty of £569,157 imposed on named energy company

The UK’s HM Revenue and Customs has announced the imposition of a compound penalty of £569,157 on Petrofac Facilities Management Limited.

This is the first time, in a long time, that HMRC has named the recipient of a compound penalty.

The breaches took place in 2022 and 2023 with the company supplying prohibited goods to individuals connected with Russia and also providing technical assistance in relation to those goods.

The company subsequently self-reported and cooperated with the investigation.

The change in naming policy is addressed:

“Naming those involved brings us into line with other enforcement partners whilst sending a clear message on the consequences of breaching sanctions rules.”

The Notice further states that “Where appropriate, HMRC will now include naming as a condition when offering a compound settlement for strategic export and sanctions offences“. It appears that naming will now become more common if not done universally.

The Notice also gives helpful guidance on when HMRC will consider a compound penalty rather than prosecution, noting that a penalty will only be pursued where HMRC considers it has enough evidence to prosecute, and other considerations, including:

the seriousness of the alleged offence;
whether fraudulent intent can be proven;
the extent of the efforts to perpetrate the alleged offence;
the type and value of any goods involved;
the offender’s previous history;
the extent to which the offender has co-operated with any investigation; and
the level of financial penalties known to have been imposed by courts for similar offences.

June 17, 2026June 17, 2026 by Mark Handley

UK – OFSI imposes Russian sanctions fine of £1,000,920.59

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against Sabre Global Technologies Limited (SGTL) imposing a fine of just over £1m against this UK entity.

SGTL continued to provide services to JSC Ural Airlines after that entity was designated in May 2022 and after the fact of the designation was communicated to SGTL by its lawyers on the same day.

Three payments were made to SGTL by JSC Ural Airlines between June and September 2022 totalling $906,576.30. These payments were blocked by SGTL’s bank.

In October 2022 SGTL self-disclosed the breaches to OFSI.

The Penalty Notice identified the following breaches:

by invoicing JSC Ural Airlines SGTL made available a financial benefit (and so “funds”) in the form of the discharge of a debt obligation by the airline;
by continuing to provide the airline with access to a product providing travel content up until 6 December 2022, SGTL was making an “economic resource” available to the airline;
by exploring alternative payment routes to avoid the UK, including the making of a “test” payment of $200 to SGTL’s US bank account, SGTL was circumventing the UK’s sanctions in breach of regulation 19.

These breaches, especially the continued offering of SGTL’s product, were assessed as having a value of £2,634,001.54.

OFSI assessed the breaches as being in the “most serious” category given the value, the duration and the efforts at circumvention. The fine was assessed at the maximum of 50% of the value, and then the company obtained a 20% discount to reflect self-disclosure.

The Penalty Notice makes several other “Notes on Compliance”:

“firms must not test, reroute, restructure, or otherwise manipulate payment pathways in order to avoid, evade, or defeat the effect of UK sanctions. Attempts to engineer alternative channels, including staging of payments through third countries, may constitute circumvention and a breach in and of itself. Such conduct will be treated as aggravating and will significantly increase the seriousness of any case“;
“firms must be vigilant in identifying what may constitute an “economic resource” under UK sanctions regulations. Economic resources are assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but can be used to obtain funds, goods, or services. Services that can be exchanged, directly or indirectly, for funds, goods, or services may constitute an economic resource even if they are intangible or provided digitally. In particular, firms should not assume that software, data services, or digital tools fall outside the scope of financial sanctions. A service that enables a designated person or entity to generate revenue, maintain operations, or otherwise obtain an economic advantage may amount to making an economic resource available“; and
“Although it is reasonable for a firm to take some time to assess the nature and extent of the breach, or seek legal advice, this should not delay an effective response to the breach. In practice, firms should contact OFSI early to inform us of a breach or potential breach. Where full disclosure is not possible, firms should make an early disclosure with partial information on the basis that it is still working out the facts and will make a further and full disclosure as soon as possible“.

June 16, 2026June 16, 2026 by Mark Handley

UK – captain of detained oil tanker charged with sanctions offence

Further to our earlier post on the UK’s seizure of the Smyrtos oil tanker, the UK’s National Crime Agency has announced that Indian national Ajay Pant, has been charged with “directly or indirectly supplying or delivering by ship prohibited oil / oil products from Russia to a third country during the period of June 2026 in contravention of Reg 46Z9B“.

The National Crime Agency’s press release does not state the basis for the UK’s criminal jurisdiction, but the UK’s sanctions regulations apply to actions in the UK’s “territorial sea”, which is elsewhere defined as being the breadth of 12 nautical miles from the UK.

June 15, 2026June 15, 2026 by Mark Handley

UK – seizure of shadow fleet tanker “Smyrtos”

On Sunday British armed forces boarded and detained the “shadow fleet” oil tanker Smyrtos.

While British forces have assisted other nations previously, this is the first time that the UK has detained a shadow fleet vessel.

The vessel was in international waters in the English Channel, and the press release refers to UNCLOS Article 110 as giving a power to exercise “a right of visit” where there are reasonable grounds to suspect the vessel is without nationality”.

The vessel is now anchored off the south coast of England.

BBC reporting notes that the vessel claims a Cameroon flag, and that it has changed its flag multiple times since it was designated by the UK in July 2025. The same reporting has added that a 38-year old Indian national has been arrested on suspicion of offences under the UK’s Russian sanctions.

Lloyd’s List, is reporting that Cameroon had previously expelled the Smyrtos from its registry.

Our European Vessel Seizure Tracker has been updated.

June 12, 2026June 12, 2026 by Mark Handley

UK – two convicted for tens of millions in prohibited arms sales

HM Revenue and Customs has issued a press release relating to yesterday’s conviction of David Greenhalgh and Christos Farmakis on multiple counts (nine and ten respectively) of unlawful exports of military hardware in breach of UK sanctions and arms embargos under the Export Control Order 2008.

Mr Farmakis was tried in absentia with HMRC stating that he is thought to currently be in Greece and that HMRC is “working with international partners to bring him to the UK to face justice”.

Sentencing is due to take place in July, with the judge reported as saying that Mr Greenhalgh should expect a lengthy custodial sentence.

The unlicensed sales and exports were to Sudan, South Sudan and Libya between 2009 and 2016 and were largely of ex-Soviet equipment including “ex-Soviet jets, surface-to-air missile systems, anti-tank missiles, thousands of assault rifles and other controlled goods”.

The transactions were conducted through Mr Greenhalgh’s companies and involved circuitous transport routes as well as faked end-user certificates.

May 19, 2026May 19, 2026 by Mark Handley

UK – OFSI fines bank £165,000 for processing transfers to an entity wholly-owned by designated person

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice against the London branch of Deutsche Bank AG fining it £165,000.

The fine related to two payments made in June 2022 and July 2022 that had been voluntarily reported to OFSI in September 2022. The “pace” of resolving this matter is in keeping with previous cases from OFSI.

The first payment leading to the fine was of £356,429.27 processed on 29 June 2022 in favour of a company called Okko LLC. Earlier that same day the UK had designated the 100% shareholder of Okko, JSC New Opportunities.

The second payment of £279,189.48 was made a month later.

OFSO took the view (particularly in light of the second payment) that even though there had been a limited window to stop the first payment, nonetheless there was such a window. The screening methods used by Deutsche Bank failed to identify that a newly-designated entity wholly-owned the intended transferee. This failing continued for the next month and was not purely a function of the short window for the first payment.

OFSI also took the view that the breaches could only be seen as such after the UK adopted a strict liability rule for the civil enforcement of sanctions breaches on 15 June 2022. An additional payment made before this date, was not considered a “breach” for this reason.

The notice was resolved under OFSI’s new settlement regime, and involved a 45% discount on what would otherwise have been a £300,000 fine based on the self-disclosure and Deutsche Bank agreeing to settle.

April 20, 2026April 20, 2026 by Mark Handley

United Kingdom – former designated person charged with breaching his asset freeze under Russian sanctions

The UK’s National Crime Agency has published a press release confirming that it has charged John Michael Ormerod with two counts of breaches the UK’s Russian sanctions as well as a money laundering offence.

Ormerod was designated by the UK on 20 May 2025, and the charges relate to his efforts to transfer £200,000 on the same day in breach of the asset freeze imposed upon him.

Ormerod’s UK listing had been lifted on 2 March 2026.

April 1, 2026April 1, 2026 by Mark Handley

United Kingdom – Irish subsidiary of Apple fined £390,000 by OFSI

The UK’s Office of Financial Sanctions Implementation has issued a Penalty Notice fining the Irish-incorporated company Apple Distribution International Limited (“ADIL”), £390,000 for breaches of the UK’s Russian sanctions.

ADIL was fined for issuing payment instructions to a UK bank, and for failing to cancel those payment instructions. The two payments in June and July 2022 for a total of £635,618.75 were to Okko LLC, a company wholly owned by the designated person JSC New Opportunities.

OFSI took the view that the instructions issued to a UK bank, and the failure to cancel those instructions, amounted to conduct within the UK for the purposes of the jurisdictional reach of the UK’s sanctions. This is in line with older case law that had established that sending instructions into the UK could amount to an offence within the UK.

ADIL self-disclosed the conduct in October 2022. The Penalty Notice was also arrived at by way of an agreed settlement pursuant to OFSI’s new enforcement procedures.

The penalty is also noteworthy because JSC New Opportunities was designated by the UK at 11am on 29 June 2022. The first payment instruction had been made on 6 June but with a value date of 30 June. The second payment instruction was issued on 30 June with a value date of 28 July 2022.

OFSI took the view that there was a “narrow window” in which the first payment could have been stopped, and that it was an aggravating factor justifying enforcement action that a second payment had been ordered. The Penalty Notice also expressly states that OFSI was relying on the “strict liability” enforcement rules that come into effect in 15 June 2022. Earlier payments made to Okko LLC, while it had been owned by a different designated person were also made in breach of the UK’s sanctions, but were not the subject of OFSI’s enforcement action as they took place before the coming into force of the “strict liability” rules.

OFSI also stated that despite the failings of the external screening provider used by ADLI, it was ultimately ADLI’s responsibility as the payment issuer, to ensure compliance with the UK’s sanctions.

March 20, 2026March 20, 2026 by Mark Handley

United Kingdom – corporate registry moves to dissolve entities sanctioned by the U.S. as related to the IRGC

The OCCRP has reported on actions taken by England’s Companies House to dissolve the company, and crypto exchange, Zedxion Exchange Ltd.

Zedxion is an SDN under U.S. sanctions for its links to Babak Zanjani (another SDN) and the IRGC.

Companies House has posted a notice on the pages for Zedxion stating:

“The registrar is intending to take, or has taken, steps to strike off this company under section 1002A of the Companies Act 2006. This relates to information or a statement in an application for incorporation that is misleading, false or deceptive.“

As per the OCCRP the false, misleading or deceptive information appears to relate to the identification information provided as to the shareholder, and person of significant control, of Zedxion.

February 27, 2026February 27, 2026 by Mark Handley

United Kingdom – Office of Trade Sanctions Implementation has “about five cases close to conclusion”

In oral evidence given yesterday to the UK Parliament’s Business and Trade Subcommittee on Economic Security and Export Controls, the Minister for Trade stated (at around 16:18 in the video) in relation to the enforcement efforts at the Office of Trade Sanctions Implementation:

“We have got about five cases which are quite close to conclusion and could lead to substantial measures being taken. … Significant numbers of cases have been either closed because there is nothing to pursue, or have been referred directly to HMRC or soe other government departments to be able to take further action. … I think we have got pretty effective enforcement of our sanctions regime. I would argue that its more effective than any other country that I have yet seen. …

We’ve had 185 potential breaches that were reported, 5 as I say are at a late stage, 117 closed, 57 reported to HMRC“.

HMRC gave evidence that in 2025 it had had 42 referrals from OTSI, of which 19 are still under review, 8 concluded with no further action taken, 9 cases were linked to pre-existing HMRC investigations, 1 case was referred to the National Crime Agency, and 5 cases that were subject to a “de-confliction” process between OTSI and HMRC to work through enforcement responsibility.

HMRC also stated that it currently had 21 live criminal investigations for export control offences (note that as per an earlier previous post HMRC very recently stated it had 51 investigations in 2024/2025).