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OFSI’s report of a sanctions breach that went unpunished is considered by Aziz Rahman and Zulfi Meerza

Authors: Azizur Rahman, Zulfi Meerza  13 September 2023

Aziz Rahman and Zulfi Meerza wrote an assessment of the Office of Financial Sanctions Implementation’s (OFSI’s) first report of a sanctions breach where a fine was not imposed.

In their piece, which was published by Thomson Reuters Regulatory Intelligence, Aziz and Zulfi detail how Wise Payments breached UK sanctions by permitting an employee of a company belonging to a designated person to withdraw £250 from a cash machine. 

They explain the sequence of events in the case and the mitigating factors that led to OFSI deciding not to issue a fine. He emphasises that the case is significant for being OFSI’s first use of its power, under the Economic Crime Act 2022 (ECA), to publicise details of financial sanctions breaches committed after 15 June 2022 where a monetary penalty has not been imposed. 

The article considers OFSI’s track record of enforcement action. It also warns that while the Wise Payments case did not involve huge amounts of money or penalties, companies need to view it as a reminder of the need for sanctions compliance.

The full article can be read here.

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Azizur Rahman

Senior Partner

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Aziz Rahman is Senior Partner at Rahman Ravelli and its founder. His ability to coordinate national, international and multi-agency defences has led to success in some of the most significant corporate crime cases of this century and top rankings in international legal guides. He is recognised worldwide as one of the most capable legal experts regarding top-level, high-value commercial and financial disputes.

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Zulfi Meerza

Senior Associate Solicitor

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Zulfi’s in-depth expertise in business crime investigations and serious regulatory matters makes him a logical choice to advise and represent corporates, board members, senior business figures and high net worth individuals throughout the life of a case.

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