Deutsche Bank AG London Branch Fined £165,000 for Russia Sanctions Breaches

The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, has imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch (DBLB) for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The penalty, announced on 30 April 2026, relates to two payments totalling £635,618.75 processed in June and July 2022 to Okko LLC (Okko), a Russian media streaming company wholly owned by the designated person JSC New Opportunities.

DBLB processed the payments on behalf of a corporate customer using the SWIFT messaging network. Although sanctions screening was conducted, no alert was generated because the third-party screening lists used by DBLB did not, at that time, capture data regarding Okko's ownership. Okko had previously been owned by PJSC Sberbank, which was designated by the UK on 6 April 2022, before being sold to JSC New Opportunities in May 2022. JSC New Opportunities was itself designated on 29 June 2022 — the same day the first breach payment was processed.

OFSI assessed the case as "serious" rather than "most serious", weighing the high value of the payments and the strategic importance of Russia sanctions against mitigating factors. These included DBLB's voluntary disclosure on 20 September 2022, the limited window to halt the first payment following designation, and significant subsequent enhancements to DBLB's sanctions compliance framework. The case was resolved through settlement under OFSI's new enforcement framework introduced in February 2026, with a 45% discount applied to the £300,000 baseline penalty.

OFSI used the case to underline three compliance lessons: firms must maintain robust screening systems and recognise the limitations of third-party tools, particularly where sanctions apply through ownership and control; onboarding procedures and risk-based customer reviews should be strengthened, especially for customers operating in higher-risk jurisdictions; and prompt, detailed voluntary disclosure remains central to securing the maximum available discount.

Read the penalty notice here.