UNICORN PRIVATE Sanctions fines for technology and software companies
In short
Published cases on this page: 3. 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.
Cases
Cases shown: 3 of 3
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| Sabre Global Technologies LimitedMonetary penalty | United Kingdom | Technology and software | OFSI (HM Treasury) | £1,000,920.59 | Sabre kept receiving payments from, and giving booking-system access to, the designated Ural Airlines after its designation. Official source verified on November 13, 2026 | |
| 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 | 2 | £1,390,920.59 |
| 2023 | 1 | $3,604,278.86 |
By authority
| Authority | Cases | Total |
|---|---|---|
| OFSI (HM Treasury) | 2 | £1,390,920.59 |
| BIS (US Department of Commerce) | 1 | $624,013 |
| OFAC (US Treasury) | 1 | $2,980,265.86 |
Frequently asked questions
Have companies in this sector been fined for sanctions violations?
This page lists 3 published cases. The largest amounts are: Sabre Global Technologies Limited (OFSI (HM Treasury), June 17, 2026): £1,000,920.59; 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.
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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