United Kingdom – European Sanctions Enforcement

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.

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.