127 UK companies admit to breaching British sanctions against Russia since Feb 2022

A total of 127 companies had voluntarily disclosed sanctions violations to the UK government as of May 17, according to a freedom of information request submitted to HM Treasury by Pinsent Masons

The UK has placed more than 1,600 individuals and companies [including two dozen banks and more than 100 oligarchs] under sanctions since Russia’s full-scale invasion of Ukraine in February 2022. Issues around a lack of transparency over the ultimate beneficial owners and controllers of companies, as well as Russian shareholders that may sit behind companies, can make it harder for UK companies to ensure they have not breached sanctions.

Stacy Keen, financial crime partner at law firm Pinsent Masons, which made the FOI request, said:-

• The sanctions’ breadth had created a big test for British business, given how much more integrated Russia was with the global economy compared with other regimes under sanctions, such as Iran and North Korea.
• The Russian sanction packages have been felt more keenly outside of Russia in a heightened way that others just haven’t in the past
• Russian individuals and entities had a footprint outside of Russia that perhaps if you look at the Iranian regime or the Syrian regime — there just wasn’t those interlinks between the economies
• Business should consider admitting breaches to ensure the greatest leniency,
• Sanctions penalties can range from no action or a warning letter, to a civil penalty or criminal prosecution. Financial penalties have no cap.

HM Treasury’s Office of Financial Sanctions Implementation is responsible for monitoring breaches. And by voluntarily admitting breaches and co-operating with investigations, businesses can reduce government penalties.

A person close to the OFSI said the unit was “not trying to unduly penalise honest mistakes” and takes into account relevant efforts and checks made as potential mitigating factors when assessing a breach.

Source

1. https://www.msn.com/en-us/money/companies/ft-127-uk-companies-admit-breaching-russia-sanctions/ar-AA1ju2PX
2. https://www.solicitorsjournal.com/sjarticle/127-uk-companies-admit-to-breaching-sanctions-against-russia-since-invasion
3. https://uk.style.yahoo.com/over-100-uk-companies-admit-174239960.html?guccounter=1&guce_referrer=aHR0cHM6Ly9lZGdlc2VydmljZXMuYmluZy5jb20v&guce_referrer_sig=AQAAAMJmVPAqA1Raemv-bSPVcsYocvutdCQrGVLhRybv_xQECmbRd7b7sVeu2JlGK_s6_XTMovzhRViVl4hr0JLgcwVSSZm0_w64WH_TUV3FQvJJDMjUmZwgP5vO2U4Fqai1SbIxD4wbVlK5wa_f3vvgDEgtMVKcPrVgDB2HDTH6M6xT
4. https://www.ft.com/content/233891c0-2c8c-484a-88d3-86ba252d5b31