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Sanctions fines in the United Kingdom: companies fined and amounts

Monetary penalties imposed by OFSI (HM Treasury), compound settlements agreed with HMRC, and UK companies fined by US authorities.

In short

Published cases on this page: 17. 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

  • OFSI publishes some breaches without a fine: Wise Payments Limited and Vanquis Bank Limited are listed as breaches published, no fine.
  • Svarog Shipping & Trading Company Limited was fined for not answering an OFSI information request on time, not for a breach of an asset freeze.
  • Airbus Operations Limited concerns export control record keeping, not sanctions.
  • HMRC compound settlements are settlements, not convictions. HMRC also publishes settlements without the name of the company.
  • OTSI, the UK authority for trade sanctions, had not published any penalty as of 13 November 2026.
  • No named UK case was found for crypto, insurance, asset managers, logistics and freight forwarders, ship brokers, metals and import-export traders.

Cases

Cases shown: 17 of 17

SectorWhat happened
Illumina Cambridge LimitedCompound settlement (not a conviction)United KingdomElectronics and dual-use goodsHMRC £7,438,840.13 The company was involved in moving sanctioned goods between two overseas group companies, with the goods going to Russia. Official source verified on November 13, 2026
Citibank, N.A., London BranchMonetary penaltyUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) £4,732,830.58 The bank processed 970 payments worth £19.7m that dealt with frozen funds or made funds available to designated persons, including companies owned by Sovcomflot and designated Russian banks. Official source verified on November 13, 2026
Airbus Operations LimitedCompound settlement for export control breaches (not sanctions)United KingdomAerospace and defenceHMRC £6,409,388 The company repeatedly failed to keep the required records of transfers of controlled technology under its export licences. Official source verified on November 13, 2026
Petrofac Facilities Management LimitedCompound settlement (not a conviction)United KingdomMachinery and industrial equipmentHMRC £569,157.07 While leaving Russia, the company supplied sanctioned industrial goods to persons connected with Russia and gave technical assistance for them. Official source verified on November 13, 2026
Sabre Global Technologies LimitedMonetary penaltyUnited KingdomTechnology and softwareOFSI (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
Deutsche Bank AG London BranchMonetary penaltyUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) £165,000 On a client's instruction the branch made two payments of £635,618.75 to Okko LLC, a company owned by a designated entity; its screening data did not show the ownership. Official source verified on November 13, 2026
Apple Distribution International LimitedMonetary penaltyIrelandTechnology and softwareOFSI (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
Bank of Scotland PLCMonetary penaltyUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) £160,000 The bank processed 24 payments of £77,383 to or from the account of a designated person, missed because of a spelling variation of the name. Official source verified on November 13, 2026
Colorcon LimitedMonetary penaltyUnited KingdomManufacturing for exportOFSI (HM Treasury) £152,750 Its Moscow office paid staff and suppliers through accounts at designated Russian banks (Alfa, Promsvyazbank, Sberbank, VTB): 79 payments worth £128,278 were breaches. Official source verified on November 13, 2026
Vanquis Bank LimitedBreach published, no fineUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) Breach published, no fine A designated person kept full access to their account for eight days after designation and withdrew cash. Official source verified on November 13, 2026
Markom Management LimitedMonetary penaltyUnited KingdomProfessional 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
Company not namedCompound settlement (not a conviction)United KingdomExporter (sector not published)HMRC £1,160,725.67 A UK company made goods available to Russia in breach of the Russia sanctions regulations. Official source verified on November 13, 2026
Svarog Shipping & Trading Company LimitedPenalty for not answering an information requestUnited KingdomLogistics and shippingOFSI (HM Treasury) £5,000 The company failed to answer an OFSI information request on time during an inquiry into its dealings with a Sovcomflot subsidiary. Official source verified on November 13, 2026
Herbert Smith Freehills CIS LLP (Moscow)Monetary penaltyUnited KingdomProfessional 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
Integral Concierge Services LimitedMonetary penaltyUnited KingdomProperty and concierge servicesOFSI (HM Treasury) £15,000 The company kept managing a UK property for a designated client and handled 26 payments worth £15,487, including rent. Official source verified on November 13, 2026
Wise Payments LimitedBreach published, no fineUnited KingdomCrypto and paymentsOFSI (HM Treasury) Breach published, no fine Wise allowed a £250 withdrawal from the business account of a company owned by a person designated the day before. Official source verified on November 13, 2026
British American Tobacco p.l.c.Civil enforcement action (penalty or settlement)United KingdomManufacturing for exportOFAC (US Treasury) $508,612,492 BAT moved about $250m from a North Korean joint venture through North Korean banks, and its Singapore subsidiary was paid for tobacco sold to the North Korean embassy. 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

YearCasesTotal
20268£20,866,136.37
20255£2,083,475.67
20241£15,000
20231$508,612,492

By authority

AuthorityCasesTotal
OFSI (HM Treasury)10£7,386,501.17
HMRC4£15,578,110.87
OFAC (US Treasury)1$508,612,492

Maximum penalties set by law

Maximums in the law, as verified on the official texts linked:

  • United Kingdom, OFSI (financial sanctions): civil penalty up to the greater of £1,000,000 or 50% of the value of the breach; criminal offences up to 7 years in prison. Civil liability is strict since 15 June 2022. (Official source 1) (Official source 2)
  • United Kingdom, OTSI (trade sanctions): civil penalty up to the greater of £1,000,000 or 50% of the value since 10 October 2024, with strict civil liability; under customs law (CEMA section 68) up to 14 years in prison since 22 February 2024 (previously 7 or 10 years). (Official source 1) (Official source 2)

Frequently asked questions

How much can a company be fined for breaching UK sanctions?

United Kingdom, OFSI (financial sanctions): civil penalty up to the greater of £1,000,000 or 50% of the value of the breach; criminal offences up to 7 years in prison. Civil liability is strict since 15 June 2022. United Kingdom, OTSI (trade sanctions): civil penalty up to the greater of £1,000,000 or 50% of the value since 10 October 2024, with strict civil liability; under customs law (CEMA section 68) up to 14 years in prison since 22 February 2024 (previously 7 or 10 years).

Which companies have been fined in cases involving this country?

This page lists 17 published cases. The largest amounts are: Illumina Cambridge Limited (HMRC, Compound settlement (not a conviction), September 8, 2026): £7,438,840.13; Airbus Operations Limited (HMRC, Compound settlement for export control breaches (not sanctions), July 30, 2026): £6,409,388; Citibank, N.A., London Branch (OFSI (HM Treasury), September 2, 2026): £4,732,830.58; British American Tobacco p.l.c. (OFAC (US Treasury), April 25, 2023): $508,612,492. OFSI publishes some breaches without a fine: Wise Payments Limited and Vanquis Bank Limited are listed as breaches published, no fine.

Can a UK company be fined without knowing that the counterparty was sanctioned?

Yes, for civil penalties. Since 15 June 2022 OFSI no longer has to prove that a person knew or had reasonable cause to suspect a breach (Economic Crime (Transparency and Enforcement) Act 2022, section 146(1A) of the Policing and Crime Act 2017). Civil liability is also strict for the trade sanctions enforced by OTSI.

Who fines companies for sanctions breaches in the UK?

OFSI (HM Treasury) for financial sanctions; OTSI, which can impose civil penalties for trade sanctions breaches since 10 October 2024; and HMRC, which enforces trade sanctions and export controls under customs law and can agree compound settlements. Criminal cases are decided by the courts.

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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.

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