UNICORN PRIVATE Sanctions fines in Ireland: cases and penalties
Irish companies fined by foreign authorities. No conviction or fine by Irish authorities was found.
In short
Published cases on this page: 2. Authorities: 3. Years: 2023 to 2026.
In the United States (OFAC, BIS) and in the United Kingdom (OFSI, since 15 June 2022) civil liability is strict: a company can be fined even if it did not know that the counterparty was sanctioned.
Amounts are shown in the currency of the decision and are never converted.
Good to know
- No conviction or fine by Irish authorities was found, only investigations. The Director of Public Prosecutions did not prosecute the two cases referred by the Garda.
- The Irish companies listed were fined by the UK Treasury (OFSI) or by US authorities (OFAC and BIS).
Cases
Cases shown: 2 of 2
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| Apple Distribution International LimitedMonetary penalty | Ireland | Technology and software | OFSI (HM Treasury) | £390,000 | The Irish company ordered two payments of £635,618.75 to a Russian app developer owned by a UK-designated entity. Official source verified on November 13, 2026 | |
| Microsoft Corporation (also for Microsoft Ireland Operations Ltd.)Civil enforcement action (penalty or settlement) | Ireland | Technology and software | OFAC (US Treasury) + BIS (US Department of Commerce) | OFAC: $2,980,265.86 BIS: $624,013 |
Microsoft Ireland billed resellers for licences that ended up with sanctioned persons and users in Russia, Crimea, Cuba, Iran and Syria. Official source verified on November 13, 2026 |
Select a column heading to sort the table. Amounts are shown in the currency of the decision and are never converted.
Totals by year and by authority
Sums of the amounts imposed on companies in this list, by currency, never converted. Not included: breaches published without a fine, anti money laundering penalties, confiscations and amounts imposed on individuals. A total marked about or more than includes an amount that the source gives as approximate or as a minimum.
By year
| Year | Cases | Total |
|---|---|---|
| 2026 | 1 | £390,000 |
| 2023 | 1 | $3,604,278.86 |
By authority
| Authority | Cases | Total |
|---|---|---|
| BIS (US Department of Commerce) | 1 | $624,013 |
| OFAC (US Treasury) | 1 | $2,980,265.86 |
| OFSI (HM Treasury) | 1 | £390,000 |
Maximum penalties set by law
Maximums in the law, as verified on the official texts linked:
- European Union, Directive (EU) 2024/1226: each Member State must provide, for companies, maximum fines of no less than 5% of worldwide turnover or €40 million (1% or €8 million for some reporting obligations), and for individuals maximum prison terms of at least 5 years for the main offences above €100,000 and for military or dual-use goods. The offences require intent (serious negligence for military and dual-use goods). Transposition deadline: 20 May 2025. (Official source)
- Ireland: a typical statutory instrument provides, on indictment, up to €500,000 or 3 years in prison. The directive has not been transposed: reasoned opinion of the European Commission of 6 October 2026 (secondary source). (Official source)
Frequently asked questions
How much can a company be fined for sanctions breaches in Ireland?
European Union, Directive (EU) 2024/1226: each Member State must provide, for companies, maximum fines of no less than 5% of worldwide turnover or €40 million (1% or €8 million for some reporting obligations), and for individuals maximum prison terms of at least 5 years for the main offences above €100,000 and for military or dual-use goods. The offences require intent (serious negligence for military and dual-use goods). Transposition deadline: 20 May 2025. Ireland: a typical statutory instrument provides, on indictment, up to €500,000 or 3 years in prison. The directive has not been transposed: reasoned opinion of the European Commission of 6 October 2026 (secondary source).
Which companies have been fined in cases involving this country?
This page lists 2 published cases. The largest amounts are: Apple Distribution International Limited (OFSI (HM Treasury), March 30, 2026): £390,000; Microsoft Corporation (also for Microsoft Ireland Operations Ltd.) (OFAC (US Treasury) + BIS (US Department of Commerce), April 6, 2023): $3,604,278.86. No conviction or fine by Irish authorities was found, only investigations. The Director of Public Prosecutions did not prosecute the two cases referred by the Garda.
Has Ireland transposed the EU sanctions directive?
No: the European Commission sent Ireland a reasoned opinion on 6 October 2026 (secondary source). The penalties are set in the statutory instruments of each sanctions regime.
Who has fined Irish companies for sanctions breaches?
In this list only foreign authorities: OFSI in the United Kingdom fined Apple Distribution International Limited, and OFAC and BIS in the United States acted against Microsoft Corporation, also for Microsoft Ireland Operations Ltd.
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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.
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