Sanctions 2026

UK Law and Practice Contributed by: John Binns, BCL Solicitors LLP

• Wise Payments Limited (for a GBP250 cash with - drawal by a DP) on 31 August 2023; • three charities (which failed to respond to informa - tion requirements under counter-terrorism sanc - tions regulations) on 14 March 2025; and • Vanquis Bank Limited (for making funds available to a person designated under counter-terrorism sanctions) on 8 September 2025. Notably, all these penalties were dwarfed by that imposed by the FCA against Starling Bank, in the sum of GBP29 million (primarily for its significant failures in sanctions compliance) on 2 October 2024. 2.2.4 Criminal Enforcement Action Criminal enforcement action for sanctions breaches has historically been rare in the UK but is increas - ing. The first convictions were obtained in April 2025 against Dmitrii Ovysannikov (a DP and the former governor of Sevastopol) and his brother, Alexei Ovy - sannikov, in connection with various transactions undertaken for Dmitrii’s benefit after he was removed from the EU’s sanctions list (though while he remained a DP in the UK). Dmitrii received a sentence of 40 months’ immediate imprisonment, while Alexei was sentenced to 15 months’ imprisonment, suspended for 15 months. Not-guilty verdicts were returned on separate charges of circumvention and against Dmi - trii’s wife, who told the jury she thought the EU delist - ing had also applied in the UK. In November 2025, charges were brought against an art gallery (Hauser & Wirth) and an art logistics com - pany, both based in London, for making luxury goods available to a person connected with Russia (PCWR). In July 2026 the prosecution was halted, due to lack of evidence that the buyer was indeed a PCWR with - in the meaning of the Russia sanctions regulations (which required, the court made clear, that they were ordinarily resident or located in Russia; Russian citi - zenship was not enough). Two more cases are ongoing at the time of publication of this guide (13 August 2026): • in April 2026, John Ormerod, a former DP under the Russia sanctions regulations, was charged with dealing with £200,000 of his own funds (on the day

of his designation) in breach of those regulations and thereafter transferring £100,000 of that sum (classed as money laundering under POCA); and • in June 2026, the captain of an interdicted Russian “shadow fleet” vessel was charged with breaching trade sanctions by supplying or delivering products from Russia to a third country. 2.2.5 Mitigation Co-Operation and Self-Reporting OFSI’s published guidance emphasises the positive impact on penalties when a perpetrator self-reports and co-operates with the ensuing investigation. A voluntary settlement regime and an Early Account Scheme (EAS) exist to ensure incentivisation of prompt co-operation, while fixed penalties can be applied to lower-level breaches. In practice, much will depend on: • the details of how the breach took place; • who was involved; • the quantum of assets that were handled or not reported; and • the extent to which any ongoing impact can be remedied. Preventative Procedures The guidance specifies that OFSI will consider any compliance procedures a business has established to prevent unintentional breaches of sanctions, even if those procedures ultimately fail to prevent a violation. Consequently, businesses may find significant value in designing and implementing these procedures, although monetary penalties can now be imposed on a “strict liability” basis (see 2.2.6 Strict Liability ). 2.2.6 Strict Liability Criminal offences in connection with financial sanc - tions require the perpetrator either to know that funds or economic resources are owned, held or controlled by a DP (or an entity they own or control) or to have reasonable cause to suspect that this was the case. Trade sanctions offences are subject to defences where the perpetrator can show they did not have the requisite knowledge or reasonable cause to sus - pect. These provisions, however, are disapplied for the purposes of monetary penalties regimes.

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