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.
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.
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.
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).
The UK’s HMRC has issued a press release announcing the conviction and sentencing of Steven Gates for unlicensed exports of eight military-grade rifle sights to a buyer in Hong Kong.
Customs declarations were also falsified to say the sights were camera equipment.
One export was prevented in February 2022 by Border Force staff at Manchester Airport, and another in April 2023.
Searches at his house revealed evidence of another 10 exports.
Mr Gates has been sentenced to jail for 2 years and one month.
Importantly, the press release notes that HMRC is “pursuing 51 criminal investigations in 2024/2025 compared with give in 2021/22”.
It is being reported, following a Freedom of Information request to HM Treasury, that the UK’s Office of Financial Sanctions Implementation has between 1 and 5 investigations ongoing in relation to possible breaches of the asset freezes imposed by the UK’s Cyber sanctions regime.
The breaches are all said to relate to the financial services sector, but no further information was released so as to not prejudice ongoing or future investigations.
The report notes that an earlier Freedom of Information request was refused but an internal review lead to the release.
The UK’s Office of Financial Sanctions Implementation (“OFSI”) has issued a Penalty Notice to the Bank of Scotland fining the bank £160,000.
The bank opened an account for a designated person in February 2023 and then allowed 24 transactions to and from that account to take place between 8 and 24 February totalling over £77,000.
The bank’s screening system missed the fact that the person was designated, using the spelling in the person’s passport that had a different transliteration from cyrillic than used in the UK’s Consolidated List. One of OFSI’s complaints in the Penalty Notice is that the screening tool was insufficiently able to create a “match” despite the spelling variations.
The designation was first identified because the person was identified as a PEP and adverse media searches then revealed the designation. This was not then escalated to be resolved.
OFSI also noted that the in-house training to the Bank’s staff “was out of date and did not reflect risks associated with the contemporary sanctions landscape, such as the heightened risk posed by Russia sanctions post-2022”.
After an investigation into a different account, the Bank identified this particular account as belonging t a designated person and reported a suspected breach to OFSI on 10 March 2023 and an actual breach to OFSI on 16 March 2023.
The fine was first set at £175,000, including a 50% discount for prompt self-reporting, but this was reduced by OFSI, after further representations from the bank, to £160,000.
In the Penalty Notice’s “Notes on Compliance” attention is drawn to the failure to use a sufficiently robust screening tool, the lack of a clear escalation procedure, and the poor training.
The Penalty Notice does not name the designated person, but similarities indicate that this notice relates to the UK’s conviction of Dmitri Ovsiannikov (see our earlier post).
Further to our earlier post, it is being reported that the trial in the UK’s criminal prosecution the art gallery Hauser and Wirth, and shipping company, Artay Rauchwerger Solomons, has been scheduled for January 2028.
The companies are charged in relation to allegedly making a luxury good, a work of art, available to a person connected with Russia.
The next hearing is scheduled for 5 May 2026 at which the defendants will be able to enter their pleas.
The Office of Trade Sanctions Implementation has published a report on its first year of operations.
In relation to enforcement it says that it has “a number of investigations underway”, and that it has “referred a significant number of cases to HMRC and other government partners”.
No other information is provided, although further information is promised in the 2026 Annual Report.
The UK’s Gambling Commission has fined Done Brothers (Cash Betting) Limited, trading as Betfred £825,000.
While much of the fine relates to player welfare and AML issues, it is being reported that part of the fine relates to the lack of an “effective policy for identifying and handling customers who might be subject to financial sanctions”.
This is not the first fine by the Gambling Commission related to sanctions compliance, as two other operators were fined in April 2024.
