Last revised: 21 March 2025
The breach of sanctions carries high reputational and economic risks. As a result, greater scrutiny has been placed on compliance with sanctions legislation in recent years. To illustrate what can happen in international sanctions breaches scenarios, we have outlined some brief case studies below.
All current OFSI enforcement cases are available on GOV UK website.
UK judgements on sanctions cases Judgments Archive - UK Sanctions.
US sanctions enforcement cases can be found on OFAC website.
Case Study: Herbert Smith Freehills (HSF Moscow) - 2025
HSF Moscow, a subsidiary of a UK-based law firm, has been penalized with a fine exceeding £460,000 for making funds available to a designated person during the process of closing its Moscow office. The payments included life insurance and redundancy compensation for employees, and occurred within a seven-day timeframe as the firm began winding down its Russian operations in 2022. The OFSI determined that these transactions reflected a concerning pattern of non-compliance with the UK sanctions regime imposed on Russia.
Case Study: Integral Concierge Services Limited - 2024
Integral Concierge Services Limited (ICSL) faced a £15,000 financial penalty from the OFSI for breaching Russia sanctions regulations. The company collected rent and management fees from a designated person's client account without the necessary licenses and did not meet reporting obligations under general licenses for utility payments. This case underscores the critical need for businesses, regardless of size, to recognize and mitigate their exposure to sanctions risks.
Enforcement of financial sanctions - GOV.UK
Case Study: Wise Payments Limited- 2023
For the first time OFSI used its new Disclosure enforcement power against the Wise Payments Limited (Wise), a UK company regulated by FCA, for making funds available to a designated person. Despite the low breach value of £ 250, OFSI considered that Wise's systems and controls, specifically its policy surrounding debit card payments, and lack of resources at weekends to review sanctions alerts, were inappropriate for managing sanctions risk. To ensure restriction of all forms of access to funds or economic resources of designated person “without delay”, a supervised person should maintain proportionate sanctions screening and dedicated sanctions alert review functions whenever business is being conducted, including, for example at weekends.
Case Study: Microsoft - 2023
Microsoft entered a US$3,300,000+ settlement agreement concerning 1,339 apparent US sanctions and export controls violations of restrictions on Cuba, Iran, Syria and Russia. Microsoft sold software licenses, activated software licenses, and/or provided related services to their customers from servers and systems located in the United States and Ireland.
Case Study: British American Tobacco Plc - 2023
British American Tobacco Plc (BAT), a tobacco and cigarette manufacturer headquartered in London, UK, agreed to pay US$508,612,492 to settle its potential civil liability for apparent violations of OFAC’s sanctions against the Democratic People’s Republic of Korea (DPRK) and proliferation of weapons of mass destruction. In breach of sanctions restrictions, BAT’s Singapore subsidiary and the DPRK company established a joint venture. BAT provided the joint venture with professional services and supplied it with machines, equipment, tobacco and other material to produce cigarettes in breach of sanctions restrictions.
Case study: Hong Kong International Wine and Spirits Competition Ltd – 2022
OFSI imposed a monetary penalty of £30,000 on the Hong Kong International Wine and Spirits Competition Ltd (HKIWSC) for contravention of sanctions regulations. The fine related to receiving competition entry fees and wine bottles from a designated Crimean winery. HKIWSC also made available publicity to the designated winery. The type of publicity and its value was not specified in the OFSI’s penalty report. However, the OFSI has determined that publicity to be an intangible economic resource and could be likely used by a designated person to increase its wine sales.
Case study: Tracerco Limited – 2022
OFSI imposed a monetary penalty of £15,000 on Tracerco Limited (Tracerco), a UK registered company, which provides measuring products and services to the oil and gas industry. Tracerco made two payments to Syrian Arab Airlines (SAA), a designated person, by booking the flights for their employee through an UAE travel agency. Therefore, Tracerco made funds available for the benefit of a person designated under the Syrian sanctions’ regime in breach of sanctions restrictions.
Case study: TransferGo Limited – 2021
OFSI imposed a monetary penalty of £50,000 on TransferGo, a FinTech company, for breaches of sanctions restrictions. The penalty related to 16 transactions where TransferGo issued instructions to make payments to bank accounts held at the Russian National Commercial Bank. In carrying out these actions, TransferGo made funds available to designated persons, without a license.
Case study: Standard Chartered Bank – 2020
OFSI imposed monetary penalties of £7,693,233.50 and £12,778,576.33 on Standard Chartered Bank (SCB) for making funds available to a designated person, without a licence. The SCB breached a prohibition imposed by financial sanctions legislation and had reasonable cause to suspect that it was in breach of that prohibition dealing with loans to Denizbank A.Ş.
Case study: Standard Chartered Bank – 2019
In April 2019, the London-based Standard Chartered Bank (SCB) was ordered by the US and UK authorities to pay US$1.1bn due to poor money-laundering controls and for significant violations of US sanctions laws and regulations against Iran.
Department of Justice statement
Case study: British Arab Commercial Bank Plc – 2019
In September 2019, a London-based British Arab Commercial Bank Plc (BACB), a commercial bank with no offices, business, or presence under U.S. jurisdiction, entered into US$4,000,000 settlement agreement with OFAC for processing 72 violations of the US Sudanese Sanctions Regulations totalling US$190,700,000.
Case study: Telia Carrier UK Limited - 2019
In September 2019, OFSI issued a penalty notice of £146,341 to Telia Carrier UK Limited (Telia) for breaches of the EU Syria sanctions regime, then implemented in the UK by the Syria (European Union Financial Sanctions) Regulations 2012. Telia had indirectly facilitated international telephone calls to SyriaTel, an entity designated under the above regime. This resulted in the company repeatedly making funds and economic resources indirectly available to the designated entity over an extended period.
Case study: Travelex (UK) Ltd - 2019
In March 2019, the OFSI issued a monetary penalty against Travelex (UK) for a contravention of the EU Egypt financial sanctions regime.
Case study: Raphaels Bank - 2019
In January 2019, the OFSI issued a monetary penalty against Raphaels Bank for a contravention of Regulation 3 of the Egypt (Asset-Freezing) Regulations 2011.
Case study: UniCredit Bank AG -2019
UniCredit Bank AG, a financial institution headquartered in München, Germany, and a subsidiary of the UniCredit Group, agreed with OFAC to settle US$553,380,759 for 2,158 violations of primarily the US Weapons of Mass Destruction Proliferators Sanctions Regulations.
Case study: Royal Bank of Scotland Group -2016
In August 2010, the Financial Services Authority (FSA) fined members of the Royal Bank of Scotland Group (RBSG) £5.6m for failing to have adequate systems and controls in place to prevent breaches of UK financial sanctions. RBSG failed to adequately screen their customers and payments against the UK Consolidated List.
Case study: Barclays Plc - 2016
In 2016, Barclays Bank Plc (Barclays), a financial institution headquartered in London, agreed to remit $2,485,890 to settle with OFAC concerning 159 violations of the US Zimbabwe sanctions regime, failing to identify beneficial owners of their customers.
Case study: BNP Paribas - 2014
In June 2014, BNP Paribas (BNP), a French bank, agreed to enter a guilty plea to conspiring to evade sanctions by processing billions of dollars of transactions through the US financial system on behalf of Sudanese, Iranian, and Cuban entities subject to US economic sanctions. BNP agreed to pay a settlement of US$8.9 bn imposed by the US authorities.
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