United Kingdom – Page 2 – European Sanctions Enforcement

August 4, 2025August 4, 2025 by Mark Handley

United Kingdom – OFSI imposes a fine of £300,000 for breach of EU Russian sanctions

OFSI has published a Penalty Notice fining a UK company Markom Management Limited (“MML”) £300,000 for breaches of The Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014.

The fine was for issuing a payment instruction to return an overpayment of £416,590.92 to a Russian bank account belonging to a designated person.

The fine was initially set at £400,000, but was reduced through the ministerial review process.

This penalty is noteworthy for a number of reasons:

This enforcement action dates from events in 2018. While underscoring the slowness of OFSI’s enforcement steps it also reinforces the lack of a limitation period for the UK’s sanctions, and the fact that the UK continues to enforce the EU sanctions that were in place before Brexit.
The self-reporting by MML was considered insufficient to trigger a discount to the imposed penalty.
The conduct that warranted the penalty was a person in the UK sending a payment instruction to a bank in Russia to transfer funds to another bank in Russia. This is a reminder of the broad reach of the UK’s criminal jurisdiction when it comes to communications sent in or out of the jurisdiction. This penalty notice sits uneasily alongside the recent civil decision in Celestial Aviation Trading Ireland Ltd & Ors v Volga-Dnper Logistics BV [2025] EWHC 1156 (Comm).

July 8, 2025November 3, 2025 by Mark Handley

United Kingdom – £1.1m penalty for exports to Russia

HM Revenue and Customs has issued a Notice to Exporters reporting on the imposition of a civil compound penalty against an unnamed company for making “goods available to Russia in breach of” the UK’s Russian sanctions.

The compound penalty is stated to be £1,160,725.67.

No other information has been published on the identity of the offender, the nature of the offending or the goods that were exported, whether there was a self-report, or the nature of the cooperation that secured a civil penalty.

July 1, 2025July 1, 2025 by Mark Handley

United Kingdom – individual charged with providing funding to sanctioned Donetsk/Luhansk militias

It is being reported by Reuters, (and others) that a UK-Russian dual national, Mikhail Vlasov, has today appeared in court in London charged with 8 counts of breaching the UK’s Russian sanctions.

It is alleged that Mr Vlasov sent cryptocurrency (valued at £4,000) to separatist militias in Russian-occupied Ukraine that are designated persons under the UK’s sanctions.

He has pleaded not guilty to all charges.

This is the second criminal prosecution under the UK’s post-2022 Russian sanctions.

June 30, 2025June 30, 2025 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.

June 30, 2025June 30, 2025 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.

June 25, 2025June 25, 2025 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.

May 8, 2025May 8, 2025 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.

April 14, 2025April 14, 2025 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.

April 10, 2025April 10, 2025 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.

April 10, 2025April 10, 2025 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“.