OFSI issues first financial penalty for breach of Russia sanctions
On 29 August 2024 the Office of Financial Sanctions Implementation (OFSI) imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (ICSL), a property management company, for violating the UK's sanctions on Russia. ICSL had made or received a total of 26 payments in connection with property management services for a designated person, including collection of rent from tenants, paying for upkeep and maintenance of property and collecting its own management fees from the designated person’s client account. ICSL also failed to report to OFSI certain payments that were permitted under a general licence. This was the first time OFSI has imposed a financial penalty in connection with the UK's Russia sanctions regime.
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Office of Trade Sanctions Implementation officially launched
On 10 October 2024 the new Office of Trade Sanctions Implementation (OTSI) was officially launched. Part of the Department for Business and Trade, OTSI is responsible for enforcing the UK's trade sanctions regimes and issuing licences to permit otherwise prohibited activities. Under recently enacted legislation, OTSI has the power to investigate potential breaches of trade sanctions and take civil enforcement actions, including imposing monetary penalties. Liability for such breaches is strict, meaning OTSI can impose a penalty even when the person who breached sanctions did not know or suspect they were doing so. Criminal enforcement of trade sanctions remains the responsibility of HMRC, which also continues to enforce the UK's strategic export controls.
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