OFSI Issues First-Ever Information Offence Penalty

On 11 April 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) imposed a £5,000 monetary penalty on Svarog Shipping & Trading Company Limited, a UK-registered entity operating in the maritime oil shipment sector. This marked the first time OFSI has penalised a company solely for committing an information offence by failing to respond to a statutory Request for Information (RFI) within the required timeframe, and without providing a reasonable excuse.

This case serves as a wake-up call for firms operating in sanctions-exposed sectors. It illustrates how non-responsiveness to OFSI requests can trigger enforcement action, even when no breach of sanctions has otherwise occurred.

What is an OFSI Request for Information?

OFSI uses its statutory powers to issue RFIs under relevant sanctions legislation, including the Russia (Sanctions) (EU Exit) Regulations 2019. RFIs are a critical tool for:

• Investigating whether financial sanctions have been breached

• Monitoring compliance with sanctions regulations and OFSI-issued licences

Each RFI will specify the legal basis for the request, the information required, and the timeframe for response. A failure to comply, without reasonable excuse, constitutes an offence — one which OFSI is now prepared to penalise publicly.

The Facts: What Went Wrong at Svarog?

On 26 January 2024, OFSI issued an RFI to Svarog as part of a wider sanctions compliance investigation. Despite reminders, Svarog failed to meet the statutory deadline. A response was eventually received only after OFSI contacted the firm’s auditors. Although Svarog apologised, it did not offer a valid justification for the delay.

OFSI concluded that this amounted to an information offence. While no substantive financial sanctions breach was identified, the failure to respond on time impeded OFSI’s broader investigatory efforts. A £5,000 civil penalty was deemed appropriate.

Compliance Lessons for Industry

• Timely Responses to OFSI RFIs Are Mandatory

Regulated firms must treat OFSI RFIs with the same seriousness as direct enforcement action. Delay or non-response not only undermines regulatory objectives but also wastes public resources. Svarog’s failure delayed a complex investigation and required unnecessary third-party engagement.

• Engage Proactively with OFSI

If a firm is unable to meet an RFI deadline or is unclear about how to respond, it should contact OFSI immediately. Ignoring an RFI will not be viewed favourably. OFSI’s guidance encourages early engagement, clear communication, and full disclosure of any mitigating circumstances.

• Implement Strong Internal Controls & Monitoring

Firms must establish clear internal escalation routes and assign responsibility for monitoring communications from OFSI. Keeping contact details up to date and training relevant staff on how to identify and respond to RFIs is essential, especially in high-risk sectors like maritime, energy, or finance.

• Understand Broader Sanctions Reporting Obligations

An RFI is just one of many compliance touchpoints. Other reporting failures including non-reporting, late reporting, or incomplete reporting on frozen assets or licence conditions can also attract enforcement. Both individuals and entities must understand their full obligations under UK financial sanctions law.

Conclusion: A Warning Shot for Sanctions Compliance

This case is more than a procedural technicality. It represents a significant regulatory signal: OFSI will act when its investigative processes are obstructed, regardless of whether a sanctions breach is ultimately found.

Firms should treat this enforcement action as a call to review their sanctions compliance frameworks. Responding to OFSI RFIs is not optional. Delays not only expose firms to civil penalties but may also indicate wider weaknesses in sanctions governance and regulatory engagement.

As financial sanctions enforcement evolves, proactive, transparent, and timely communication with regulators must become the industry standard.

Read the penalty notice here.