OFSI has updated its table of penalties imposed for breach of financial sanctions restrictions and requirements to include a fine imposed over a year ago, but just publicised,
The payment services provider in question made a voluntary disclosure that it had made transactions totalling over £7m to accounts held at the Russian National Commercial Bank over a 3 month period in 2018. OFSI imposed a fine of over £36m, which included a 26.7% discount in respect of 8 transactions that were the subject of the voluntary disclosure. OFSI’s investigations had discovered 7 further transactions.
OFSI found that instructions had been given to the firm by a client, providing a Russian BIC. OFSI considered the firm knew or had reasonable cause to suspect that the payments would breach financial sanctions requirements, given the information it had about the transactions. The firm then made further payments to the same BIC despite having told the client that it would not do so. The client was itself authorised and was also fined by OFSI.
The firm had requested a Ministerial Review of the decision, and this upheld OFSI’s decision. A further appeal was withdrawn.