UNICORN PRIVATE Sanctions fines for law firms, accountants and consultants
In short
Published cases on this page: 3. Authorities: 2. Years: 2025 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 accounting firm in the strict sense was found: the cases concern a fiduciary and accounting services company, a law firm and a consultancy.
Cases
Cases shown: 3 of 3
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| FTI Consulting, Inc.Civil enforcement action (penalty or settlement) | United States | Professional services (law, accounting, consulting) | OFAC (US Treasury) | $1,050,000 | The firm extended prohibited credit to the sanctioned Russian bank VTB by issuing invoices that were paid late or not at all. Official source verified on November 13, 2026 | |
| Markom Management LimitedMonetary penalty | United Kingdom | Professional services (law, accounting, consulting) | OFSI (HM Treasury) | £300,000 | The firm instructed a bank to transfer £416,591 from a client's account to a designated person, knowing who the recipient was. Official source verified on November 13, 2026 | |
| Herbert Smith Freehills CIS LLP (Moscow)Monetary penalty | United Kingdom | Professional services (law, accounting, consulting) | OFSI (HM Treasury) | £465,000 | While closing its Moscow office, the firm made six payments worth £3.9m (rent, fees, overdraft) to designated Russian banks. 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 | $1,050,000 |
| 2025 | 2 | £765,000 |
By authority
| Authority | Cases | Total |
|---|---|---|
| OFSI (HM Treasury) | 2 | £765,000 |
| OFAC (US Treasury) | 1 | $1,050,000 |
Frequently asked questions
Have companies in this sector been fined for sanctions violations?
This page lists 3 published cases. The largest amounts are: Herbert Smith Freehills CIS LLP (Moscow) (OFSI (HM Treasury), March 20, 2025): £465,000; Markom Management Limited (OFSI (HM Treasury), July 31, 2025): £300,000; FTI Consulting, Inc. (OFAC (US Treasury), June 1, 2026): $1,050,000. No accounting firm in the strict sense was found: the cases concern a fiduciary and accounting services company, a law firm and a consultancy.
Can a company be fined without knowing that the counterparty was sanctioned?
In the United States and in the United Kingdom, yes, for civil penalties. OFAC states that a US person may be held civilly liable even without having knowledge or reason to know of the violation; BIS civil liability is also strict; since 15 June 2022 OFSI no longer has to prove that a person knew or had reasonable cause to suspect. In the EU the directive requires intent, and serious negligence is enough for military and dual-use goods. In Canada a wilful violation is required. Example from this list: Pegasus Worldwide Logistics (OFAC, 9 October 2026) arranged a shipment of equipment from a sanctioned Chinese supplier without noticing, because of gaps in its checks.
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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.
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