OFSI has announced that on 8 March 2019, it imposed a monetary penalty of £10,000 against Travelex (UK) Limited for contravening the EU Egypt financial sanctions regime, in relation to a payment of £204 belonging to a designated person. OFSI used its powers under the Policing and Crime Act 2017
It follows, and is connected with the same facts as, the fine imposed on Raphaels Bank earlier this year. Unlike the case of Raphaels Bank, no discount on the potential fine was applied. OFSI said the firm had had direct, in-person contact with the individuals in the UK, and had access to the person’s passport which had clear details on it. Therefore Travelex knew or had reasonable cause to suspect they were in breach of sanctions, which should have had the effect of freezing the funds. OFSI commented that, no matter the value of the transaction, it directly contravened the policy intention of the asset freeze.