Sanctions and export control | UK Regulatory Outlook June 2026

OFSI issues £1m penalty for  Russia sanctions breaches in first circumvention case 

The Office of Financial Sanctions Implementation (OFSI) has issued a £1,000,920.59 fine against technology firm Sabre Global Technologies Limited (SGTL) for breaching financial sanctions against Russia.

The breaches related to services provided by SGTL to a designated entity for seven months after it was designated in May 2022. SGTL had been repeatedly notified of the designation by its UK bank and, after three payments were blocked for sanctions concerns, the company explored alternative options for receiving payment from the designated person, which OFSI considered amounted to circumvention.

OFSI assessed the case as “most serious”. Aggravating factors included deliberate circumvention, high breach value, repeated and extended breaches, and a substantial risk of harm to the objectives of the UK’s Russia sanctions regime; the designated entity operated in the strategically significant transport sector.

This was the third penalty resolved under transitional arrangements in OFSI's new settlement policy, introduced in February. OFSI applied a 20% discount to reflect SGTL’s voluntary disclosure and settlement of the case, imposing a final penalty of £1,000,920.59, which is the largest monetary penalty in relation to Russia sanctions since the 2022 invasion of Ukraine.

OFSI's penalty notice set out the following compliance lessons for firms: 

• Attempts to reroute or restructure payment pathways to bypass sanctions controls may constitute circumvention and significantly aggravate the seriousness of any case.
• Digital services, software and data tools can constitute “economic resources” under UK sanctions law, and where uncertainty exists, firms should seek appropriate specialist legal advice to ensure products and services are assessed accordingly.
• Firms should maintain up-to-date policies, procedures and training, supported by competent senior oversight and clear accountability.
• Sanctions policies must be tailored to the UK sanctions regime; firms should conduct appropriate testing of their sanctions screening systems and take appropriate action in response to any sanctions red flags.
• Firms must report suspected breaches to OFSI comprehensively and as soon as reasonably practicable. 

See the official press release.