JFSC update 3 March 2025 its sanction 2014-2025 Case studies updated

The breach of sanctions carries high reputational and economic risks. As a result, greater scrutiny has been placed on compliance with sanctions legislation in recent years.

The JFSC has outlined 17 case studies below to illustrate what can happen in international [UK & US] sanctions breach scenarios.

JFSC update its sanction Case studies 3 March 2025

1. Case Study: Integral Concierge Services Limited - 2024

1. Integral Concierge Services Limited (ICSL) faced a £15,000 financial penalty from the OFSI for breaching Russia sanctions regulations.
2. The company collected rent and management fees from a designated person's client account without the necessary licenses and did not meet reporting obligations under general permits for utility payments.
3. This case underscores the critical need for businesses to recognise and mitigate their exposure to sanctions risks regardless of size.
4. Enforcement of financial sanctions - GOV.UK = https://www.gov.uk/government/collections/enforcement-of-financial-sanctions#integralconciergeserviceslimited

2. Case Study: Wise Payments Limited- 2023

1. For the first time, OFSI used its new Disclosure enforcement power against Wise Payments Limited (Wise), a UK company regulated by FCA, to make funds available to a designated person. Despite the low breach value of £ 250, OFSI considered that Wise's systems and controls, specifically its policy surrounding debit card payments and lack of resources at weekends to review sanctions alerts, were inappropriate for managing sanctions risk.
2. To ensure restriction of all access to funds or economic resources of designated persons “without delay”, a supervised person should maintain proportionate sanctions screening and dedicated sanctions alert review functions whenever business is being conducted, including, for example, at weekends. 
3.  OFSI Disclosure Notice  = https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1181392/Wise_Payments_Limited_Disclosure_Notice_31AUGUST23.pdf

3. Case Study: Microsoft - 2023

1. Microsoft entered a US$3,300,000+ settlement agreement concerning 1,339 apparent US sanctions and export controls violations of restrictions on Cuba, Iran, Syria and Russia.  
2. Microsoft sold software licenses, activated software licenses, and/or provided related services to their customers from servers and systems located in the United States and Ireland.  
3. US Department of Treasury  = https://ofac.treasury.gov/media/931591/download?inline

4. Case Study: British American Tobacco Plc - 2023 

1. British American Tobacco Plc (BAT), a tobacco and cigarette manufacturer headquartered in London, UK, agreed to pay US$508,612,492 to settle its potential civil liability for apparent violations of OFAC’s sanctions against the Democratic People’s Republic of Korea (DPRK) and proliferation of weapons of mass destruction. BAT’s Singapore subsidiary and the DPRK company established a joint venture in breach of sanctions restrictions. 
2. BAT provided the joint venture with professional services and supplied it with machines, equipment, tobacco and other materials to produce cigarettes in breach of sanctions restrictions. 
3. US Department of Treasury  https://ofac.treasury.gov/media/931666/download?inline

5. Case study: Hong Kong International Wine and Spirits Competition Ltd – 2022

1. OFSI imposed a monetary penalty of £30,000 on the Hong Kong International Wine and Spirits Competition Ltd (HKIWSC) for contravention of sanctions regulations. 
2. The delicate concerns are receiving competition entry fees and wine bottles from a designated Crimean winery.  
3. HKIWSC also made available publicity to the designated winery. The type of publicity and its value were not specified in the OFSI’s penalty report - the OFSI has determined that publicity is an intangible economic resource and that a designated person could likely use it to increase wine sales.  
4. OFSI Penalty Report  https://safe.menlosecurity.com/https:/assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1106745/Notice_of_Imposition_of_MP_-_HKIWSC.pdf

6. Case study: Tracerco Limited – 2022

1. OFSI imposed a monetary penalty of £15,000 on Tracerco Limited (Tracerco), a UK-registered company that provides measuring products and services to the oil and gas industry.
2. Tracerco made two payments to Syrian Arab Airlines (SAA), a designated person, by booking the flights for their employee through a UAE travel agency.
3. Therefore, Tracerco made funds available for the benefit of a person designated under the Syrian sanction regime in breach of sanctions restrictions. 
4. OFSI Penalty Report https://safe.menlosecurity.com/https:/assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1086645/29.06.22_Tracerco_monetary_penaly_notice.pdf

7. Case study: TransferGo Limited – 2021

1. OFSI imposed a monetary penalty of £50,000 on TransferGo, a FinTech company, for breaches of sanctions restrictions.  The penalty related to 16 transactions where TransferGo issued instructions to make payments to bank accounts held at the Russian National Commercial Bank.  TransferGo made funds available to designated persons without licenses to carry out these actions. 
2. OFSI Penalty Report  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1008859/050821_-_TransferGo_Penalty_Report.pdf

8. Case study: Standard Chartered Bank – 2020

1. OFSI imposed monetary penalties of £7,693,233.50 and £12,778,576.33 on Standard Chartered Bank (SCB) for making funds available to a designated person without a licence. The SCB breached a prohibition imposed by financial sanctions legislation and had reasonable cause to suspect that it breached that prohibition dealing with loans to Denizbank A.Ş. 
2. OFSI Penalty Report https://safe.menlosecurity.com/https:/assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/876971/200331_-_SCB_Penalty_Report.pdf

9. Case study: Standard Chartered Bank – 2019

1. In April 2019, the London-based Standard Chartered Bank (SCB) was ordered by the US and UK authorities to pay US$1.1bn due to poor money-laundering controls and for significant violations of US sanctions laws and regulations against Iran. 
2. FCA decision notice https://www.fca.org.uk/publication/decision-notices/standard-chartered-bank-2019.pdf
3. OFAC settlement agreement https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/scb_settlement.pdf
4. Department of Justice statement https://www.justice.gov/opa/pr/standard-chartered-bank-admits-illegally-processing-transactions-violation-iranian-sanctions

10. Case study: British Arab Commercial Bank Plc – 2019

1. In September 2019, a London-based British Arab Commercial Bank Plc (BACB), a commercial bank with no offices, business, or presence under U.S. jurisdiction, entered into a US$4,000,000 settlement agreement with OFAC for processing 72 violations of the US Sudanese Sanctions Regulations totalling US$190,700,000. 
2. Civil penalties statement https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20190917_bacb.pdf

11. Case study: Telia Carrier UK Limited - 2019

1. In September 2019, OFSI issued a penalty notice of £146,341 to Telia Carrier UK Limited (Telia) for breaches of the EU Syria sanctions regime, then implemented in the UK by the Syria (European Union Financial Sanctions) Regulations 2012. Telia had indirectly facilitated international telephone calls to SyriaTel, an entity designated under the above regime. This resulted in the company repeatedly making funds and economic resources indirectly available to the designated entity over an extended period. 
2. OFSI report https://www.legalrisk.co.uk/2019/10/hm-treasury-monetary-penalty-of-146341-imposed-on-telia-carrier-uk-limited/

12. Case study: Travelex (UK) Ltd - 2019

1. In March 2019, the OFSI issued a monetary penalty against Travelex (UK) for contravention of the EU Egypt financial sanctions regime. 
2. OFSI report https://www.gov.uk/government/publications/imposition-of-a-monetary-penalty

13. Case study: Raphaels Bank - 2019

1. In January 2019, the OFSI issued a monetary penalty against Raphaels Bank for contravention of Regulation 3 of the Egypt (Asset-Freezing) Regulations 2011. 
2. OFSI report https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/804117/190502_Raphaels_revised_notice.pdf

14. Case study: UniCredit Bank AG -2019

1. UniCredit Bank AG, a financial institution headquartered in München, Germany, and a subsidiary of the UniCredit Group, agreed with OFAC to settle US$553,380,759 for 2,158 violations of primarily the US Weapons of Mass Destruction Proliferators Sanctions Regulations. 
2. Civil penalties statement https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20190415_uni_webpost.pdf

15. Case study: Royal Bank of Scotland Group -2016 

1. In August 2010, the Financial Services Authority (FSA) fined members of the Royal Bank of Scotland Group (RBSG) £5.6m for failing to have adequate systems and controls to prevent breaches of UK financial sanctions. RBSG failed to adequately screen their customers and payments  against the UK Consolidated List. 
2. FSA decision notice  http://webarchive.nationalarchives.gov.uk/20100104225141/http:/www.fsa.gov.uk/pubs/other/rbs_group.pdf

16. Case study: Barclays Plc - 2016

1. In 2016, Barclays Bank Plc (Barclays), a financial institution headquartered in London, agreed to remit $2,485,890 to settle with OFAC concerning 159 violations of the US Zimbabwe sanctions regime, failing to identify beneficial owners of their customers. 
2. Civil penalties statement https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20160208_barclays.pdf

17. Case study: BNP Paribas - 2014

1. In June 2014, BNP Paribas (BNP), a French bank, agreed to enter a guilty plea to conspiring to evade sanctions by processing billions of dollars of transactions through the US financial system on behalf of Sudanese, Iranian, and Cuban entities subject to US economic sanctions. BNP agreed to pay a settlement of US$8.9 bn imposed by the US authorities. 
2. Department of Justice statement https://www.justice.gov/opa/pr/bnp-paribas-agrees-plead-guilty-and-pay-89-billion-illegally-processing-financial

Other sources

18. All current OFSI enforcement cases are available on the GOV UK website.=https://www.gov.uk/government/collections/enforcement-of-financial-sanctions
19. UK judgements on sanctions cases  Judgments Archive - UK Sanctions.=https://www.europeansanctions.com/judgment/jurisdictions/united-kingdom/#judgments-uk
20. US sanctions enforcement cases can be found on the OFAC website.= https://ofac.treasury.gov/civil-penalties-and-enforcement-information

Source

https://www.jerseyfsc.org/industry/international-co-operation/sanctions/case-studies/