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UK and EU sanctions enforcement in 2024: FCA’s Starling fine, OFSI’s limited impact, fragmented EU practice, and practical guidance on disclosure, internal investigations, remediation and co‑operation

Published on: 15 November 2024

Published by a Law360 reporter
Legal News
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Article summary

In October 2024, the Office of Financial Sanctions Implementation (OFSI) revealed that 42 UK companies are being investigated for breaching the Russian oil price cap. Even so, the heftiest UK sanction for compliance failings this year did not come from OFSI; that distinction sits with the Financial Conduct Authority (FCA). On 4 October 2024, the FCA imposed a £28.9m penalty on Starling Bank for what were characterised as 'shockingly lax' sanctions screening practices and 'systemic issues' within the bank's financial sanctions framework. By comparison, OFSI's first penalty for contravening the financial restrictions introduced after Russia's invasion of Ukraine (a £15,000 fine against London-based Integral Concierge Services Ltd in September 2024) appears decidedly modest. With that context, this article examines the UK and EU's stance on sanctions enforcement. Taken together, these events set the scene for a comparison of approaches across the UK and the EU.

UK enforcement track record

Russia’s invasion of Ukraine spurred the UK and EU to roll out unprecedented volumes of sanctions. Nevertheless, both jurisdictions display mixed records on enforcement, with a noticeable increase in activity during the second half of 2024, and enforcement momentum appearing to quicken as the year progressed...

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