Author: Joshua L. Ray 9 August 2021
With the Office of Financial Sanctions Implementation (OFSI) having fined a fintech company £50,000 for sanctions breaches, Rahman Ravelli’s Joshua Ray outlined the possible implications for other businesses.
Josh was asked for his thoughts on the case by Thomson Reuters’ Regulatory Intelligence. He told them that whether OFSI’s action would encourage more companies to self-disclose their own sanctions breaches would depend on the individual circumstances of each case.
He added that any such company would have to weigh up the size of any potential fine and the reputational damage that could be suffered due to being named as a sanctions violator.
In the case that prompted the Regulatory Intelligence article, the company TransferGo had a £50,000 penalty imposed on it for contravening Regulation 4 of the Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 (the UK regulations). The penalty related to 16 transactions where TransferGo gave instructions for payments totalling £7,764.77 to be made to accounts held at the Russian National Commercial Bank between March 2018 and December 2019.
Josh’s comments featured on Thomson Reuters Regulatory Intelligence. (Subscription required)
Joshua Ray represents individuals and corporates in complex investigations, prosecutions and regulatory actions regarding market manipulation and multijurisdictional matters involving fraud, bribery and money laundering.