OFSI Fines UK Firm £300,000 for Breach of Russia Sanctions

The Office of Financial Sanctions Implementation (OFSI) has fined UK company Markom Management Ltd (MML) £300,000 for breaching sanctions imposed over Russia’s annexation of Crimea.

OFSI found that in February 2018, MML instructed the transfer of £416,590.92 to a designated person under the Ukraine (EU Financial Sanctions) Regulations. The payment, sent via Gazprombank in Moscow, made funds directly available to the sanctioned individual.

The penalty, initially set at £400,000, was reduced after MML’s representations but upheld following a ministerial review in June 2025. OFSI said MML prioritised payment speed over compliance, failed to seek legal advice, and operated with inadequate sanctions controls.

OFSI urged all UK businesses to assess their sanctions risk, ensure policies are fit for purpose, and promptly report breaches. Voluntary disclosure in serious cases can reduce penalties by up to 50 per cent.

Further guidance is available at: https://www.gov.uk/ofsiMaintain effective systems and controls to identify and report suspected breaches promptly.

Read the penalty notice here.