How many UK-sanctioned monetary penalties have been issued since the Russia-Ukraine conflict?

On 4 November 2024, HM Revenue and Customs (HMRC) published a note stating it issued a compound settlement offer to a UK exporter in August regarding the EXPORT OF GOODS in breach of The Russia (Sanctions) (EU Exit) Regulations 2019. OFSI said:-

• In August 2024, £58,426.45 was paid for goods exported in breach of the Russia (Sanctions) (EU Exit) Regulations 2019. The name of the fine was not published.

Additionally, £1.9m worth of fines was levied on three other UNNAMED COMPANIES for breaching rules on EXPORT CONTROLS. According to the notice in August and September 2024, the following was issued:

• August 2024 = £402,417.75 was paid relating to the unlicensed exports of military goods controlled by the Export Control Order 2008
• August 2024 = £37,743.34 was paid relating to the unlicensed exports of dual-use goods controlled by Retained Regulation 428/2009
• September 2024 = £1,480,785.44 was paid relating to the unlicensed exports of military goods controlled by the Export Control Order 2008

Also, on 27 September 2024, the Office of Financial Sanctions Implementation (OFSI) announced.

• That it had issued its first monetary penalty for a breach of UK financial sanctions imposed against Russia following its invasion of Ukraine in February 2022.
• OFSI imposed a £15,000 penalty on Integral Concierge Services Limited (ICSL), a property management company, about the payments it made or received concerning services provided to a designated person.
• Importantly, part of the penalty was imposed on a strict liability basis.

The UK has sanctioned monetary penalties since the Russia-Ukraine conflict.

• Between 2021-2022: OFSI issued two fines with a combined value of £86,393.45 for breaches of financial sanctions.   
• Between April 2022 and 2023, OFSI issued two monetary penalties worth £45,000.
• Since February 2022 [2022-2024], HMRC has issued SIX compound settlements against UK companies that have breached the Russia sanctions regulations for a total of £1,363,129, including one in August 2023 for £1 million.

SOURCES

1. https://www.gov.uk/government/publications/notice-to-exporters-202317-a-compound-settlement/nte-202311-a-compound-settlement
2. https://www.gov.uk/government/publications/notice-to-exporters-202429-compound-settlement-for-breaches-of-russian-sanctions-august-2024/4aaf2dcb-e79b-407c-bd7b-a2ea4c245c7f
3. https://www.export.org.uk/insights/trade-news/hmrc-hits-four-more-companies-with-substantial-fines-for-breaches-of-export-controls-and-sanctions/
4. OFSI Issues First Monetary Penalty for Breach of Sanctions Imposed on .... https://www.skadden.com/insights/publications/2024/10/ofsi-issues-first-monetary-penalty.
5. Penalty issued for breaches linked to Russia's invasion of Ukraine. https://www.gov.uk/government/news/penalty-issued-for-breaches-linked-to-russias-invasion-of-ukraine.
6. OFSIs annual review - our five key takeaways - Ashurst. https://www.ashurst.com/en/insights/ofsis-annual-review---what-are-our-five-key-takeaways/.
7. UK sanctions watchdog flops in the face of Russia’s war. https://www.politico.eu/article/britain-ofsi-miss-opportunity-sanctions-watchdog-step-up-in-face-russia-war/.