The UK Office of Foreign Sanctions Implementation (OFSI) has imposed a monetary penalty of £50,000 on Fintech company TransferGo for making payments to accounts at the Russian National Commercial Bank (RNCB) – sanctioned since July 2014 for allegedly profiting from Russia’s annexation of Crimea – in breach of Regulation 4 of The Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014.
This is the first penalty imposed by OFSI since its amended Monetary Penalties guidance (1 April 2021), which significantly revised OFSI’s case assessment factors, including expectations for self-disclosure.
According to OFSI, between March 2018 and December 2019,TransferGo made a total of 16 payments valued at £7,764 to accounts held at RNCB. RNCB was designated for its role in supporting the Russian government by providing significant banking services in Crimea following the annexation. The Economic Secretary of the Treasury upheld OFSI’s monetary penalty of £50,000 – over six times the value of the breach.
See our analysis here.
TransferGo demonstrated a poor understanding of financial sanctions throughout its engagement with OFSI.