Increased Risk of UK Sanctions Enforcement–An Analysis of Recent Sanctions Enforcement Action within the United Kingdom | HUB

On 30 September 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) revealed a penalty discover relating to a breach of UK monetary sanctions by Colorcon Limited (Colorcon). This resolution is a part of a wider pattern of accelerating scrutiny in relation to UK sanctions enforcement.

Recent enforcement actions 

Colorcon

In its most up-to-date enforcement resolution, OFSI imposed a £152,750 high quality on UK-registered Colorcon for making funds to accounts held at sanctioned banks when closing its Moscow workplace. Out of the 123 funds made, solely 44 had been permitted beneath a basic licence for firms winding down their Russian operations—the entire quantity transferred in breach was £128,277.

Whilst Colorcon’s staff weren’t sanctioned, the truth that they held accounts at sanctioned banks meant that the transfers made funds out there to Designated Persons (DPs).

Colorcon notified OFSI of the breaches 4 months after their discovery. Although OFSI acknowledged the corporate’s full disclosure and subsequent cooperation, the delay meant the disclosure couldn’t be thought-about immediate. Accordingly, a 35% low cost was utilized to the penalty as a substitute of the utmost 50% out there for voluntary disclosures.

Vanquis Bank

On 8 September 2025, OFSI issued a Disclosure Notice—a type of nonmonetary penalty—in opposition to Vanquis Bank Limited (Vanquis) for making funds out there to a DP.

The day earlier than notifying Vanquis of the DP’s particulars, OFSI prewarned it {that a} suspected buyer was to be designated beneath terror financing dangers. Despite receiving a prenotification from OFSI, the financial institution didn’t prohibit the client’s account for eight days following the designation. During that point, the DP managed to withdraw £200 in money and made a £8.99 transaction. Vanquis notified OFSI of the breach 13 days after the designation. 

OFSI concluded {that a} Disclosure Notice was a proportionate response attributable to Vanquis’s voluntary reporting and cooperation, in addition to the low worth of the breach. However, OFSI remarked that Financial Conduct Authority (FCA)-regulated our bodies are anticipated to know sanctions dangers and make use of acceptable management measures.

Markom Management 

On 31 July 2025, OFSI revealed a £300,000 penalty discover in opposition to UK-incorporated Markom Management Limited (MML) relating to a fee of £416,590 to a DP.

MML varieties a part of the Markom Group, which incorporates Markom Management Cyprus (MMC). Following an overpayment involving MMC, MML instructed Gazprombank to switch RUB 33 million (or £416,590) from MMC’s account to the DP’s account. This fee made funds straight out there to a DP, designated for his or her monetary connections to these concerned within the destabilisation of jap Ukraine.

MML notified OFSI eight months after the breach, which was recognized because of third-party exercise. The breach was aggravated by MML’s lack of insurance policies or controls to handle sanctions dangers associated to casual transactions throughout the Markom Group. 

Key compliance classes

The current enforcement motion within the United Kingdom highlights classes to be realized by these topic to compliance with the UK sanctions regime, together with:

• Regularly reassess your sanctions compliance insurance policies and processes in order that they adequately handle your stage of publicity to sanctions dangers. Having a compliance course of is not going to be a mitigating issue if it isn’t match for objective.
• Do not solely depend on third events to undertake your sanctions screening with out information or understanding of their processes.
• Apply screening to each inside and exterior transactions.
• Disclose a breach to OFSI as rapidly as attainable however guarantee acceptable authorized recommendation is sought on this regard.
• If you search to rely on a basic or particular licence, make sure you determine the bounds of the licence and any associated reporting necessities so that you’re not vulnerable to conducting transactions or endeavor prohibited actions outdoors of its scope.
• Ensure acceptable insurance policies and procedures are in place, notably for organisations regulated by knowledgeable physique, such because the FCA.
• Immediately take acceptable steps and screening measures in the event you obtain a prenotification from OFSI {that a} buyer or affiliate could also be designated within the close to future.
• Reply promptly to OFSI in the event you obtain a request for info.

Conclusion

Considering the examples above, OFSI’s most up-to-date selections sign a extra forceful method to UK sanctions enforcement. Businesses are anticipated to be proactive of their compliance, with an emphasis positioned on immediate and voluntary disclosure. 

Keeping in thoughts OFSI’s ongoing session on strengthening its enforcement powers, it’s doubtless that compliance and reporting obligations will considerably improve sooner or later. Accordingly, organisations ought to act as quickly as attainable to make sure their compliance processes are enough.

If you’ve any questions or wish to talk about what the sanctions enforcement regime means for you, please don’t hesitate to contact the authors listed above.