UK Sanctions Enforcement Action Case Studies and Lessons
Summary
The UK government has published a collection of case studies and lessons learned from sanctions enforcement actions taken by various bodies, including OFSI, NCA, OTSI, and HMRC. This resource aims to inform industry stakeholders about compliance requirements and potential penalties under UK sanctions regulations.
What changed
This collection consolidates case studies and lessons from UK sanctions enforcement actions, providing insights for industry stakeholders. It details monetary penalties, prosecution outcomes, and disclosure notices issued by the Office of Financial Sanctions Implementation (OFSI), the National Crime Agency (NCA), the Office of Trade Sanctions Implementation (OTSI), and HM Revenue & Customs (HMRC). The content includes specific enforcement decisions, blog posts highlighting key lessons from cases like Svarog and HSF Moscow, and annual reviews detailing enforcement trends and disclosure powers.
Regulated entities, particularly those involved in financial services, trade, and international transactions, should review these case studies to understand common pitfalls and best practices in sanctions compliance. The information is intended to help prevent future breaches and mitigate risks. While no specific compliance deadline is provided for reviewing this guidance, understanding these enforcement actions is crucial for maintaining compliance with UK sanctions regimes and avoiding potential penalties, which can include significant monetary penalties and criminal prosecution.
What to do next
- Review published OFSI, NCA, OTSI, and HMRC enforcement actions and case studies.
- Identify key compliance lessons and update internal policies and procedures accordingly.
- Ensure personnel are aware of sanctions regulations and enforcement trends.
Penalties
Monetary penalties, prosecution outcomes, disclosure notices, and potential criminal breaches of financial sanctions.
Source document (simplified)
Collection
Sanctions enforcement action
Case studies and key lessons that industry can learn from enforcement actions taken by the enforcement bodies under UK sanctions regulations.
From: Foreign, Commonwealth & Development Office, HM Revenue & Customs, National Crime Agency, Office of Financial Sanctions Implementation and Office of Trade Sanctions Implementation Published 3 November 2025 Last updated 6 January 2026
— See all updates Get emails about this page This page lists published monetary penalties, prosecution outcomes and disclosure notices imposed by:
- Office of Financial Sanctions Implementation (OFSI), responsible for civil enforcement of financial sanctions and the Oil Price Cap
- National Crime Agency (NCA), responsible for investigating and prosecuting criminal breaches of financial sanctions and transport sanctions
- Office of Trade Sanctions Implementation (OTSI), responsible for civil enforcement of trade sanctions relating to UK services and international trade where the goods and services do not cross the UK border
- HM Revenue and Customs (HMRC), responsible for the enforcement of trade sanctions within its role as the UK’s customs body It also lists case studies, blogposts and annual reviews containing key lessons from enforcement actions in the relevant year.
OFSI enforcement actions: decisions and monetary penalties
Each enforcement notice published by OFSI has a section entitled ‘Notes on compliance’, which highlights important compliance lessons for a wide range of industry stakeholders.
Financial sanctions enforcement: decisions and monetary penalties imposed
- 26 January 2026
- Collection
OFSI enforcement actions: blogposts and annual reviews
OFSI also publishes blogposts outlining their enforcement actions and assessment process.
Svarog penalty: a lesson in information offences (8 May 2025)
HSF Moscow penalty: key lessons for industry (4 April 2025)
OFSI uses disclosure power for first time (31 August 2023)
OFSI annual reviews
OFSI’s annual reviews contain details about their enforcement actions, including disclosure notices (from 2023), naming a firm publicly but with no monetary penalty, and civil monetary penalties (from 2024).
OFSI also issues warning notices, and warning notices with a referral to the regulator. Data about these enforcement actions are recorded in all annual reviews.
-
- 15 October 2025
- Collection
NCA enforcement actions - press notices
Operation Destabilise: NCA exposes billion-dollar money laundering network that purchased bank to fund Russian war effort
21 November 2025
Operation Destabilise: NCA disrupts $multi-billion Russian money-laundering networks, resulting in 84 arrests
4 December 2024
OTSI enforcement actions: blogposts and updates
OTSI publishes updates on its activities and blogposts outlining key compliance and enforcement lessons.
What does good breach reporting look like? (16 December 2025)
One year of the Office of Trade Sanctions Implementation (OTSI)
- 4 December 2025
- Corporate report
Compliance clarity: lessons in trade sanctions breach detection
- 13 October 2025
- Guidance
HMRC enforcement actions: case studies
£1.1 million compound settlement for sanctions breach
- 3 November 2025
- Case study
HMRC enforcement actions: enforcement notices
May 2025 - £1,160,725.67 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019. This is the largest compound settlement HMRC has concluded for a Russia sanctions offence.
NTE 2025/18: compound settlement for breaches of export control - GOV.UK
August 2024 - £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2024/29: compound settlement for breaches of Russian sanctions – August 2024 GOV.UK
September 2023 - £1,000.00 was paid relating to the export of goods in breach of The Iran (Sanctions) (Human Rights) (EU Exit) Regulations 2019.
NTE 2023/23: compound settlement - GOV.UK
August 2023 - £67,001.31 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2023/23: compound settlement - GOV.UK
August 2023 - £1,000,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2023/17: a compound settlement - GOV.UK
April 2023 - £217,012.50 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2023/09: Compound penalties issued - GOV.UK
September 2022 - £19,689.20 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2022/31: UK exporters issued compound settlements for unlicensed strategic exports - GOV.UK
August 2022 - £1,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2022/31: UK exporters issued compound settlements for unlicensed strategic exports - GOV.UK
Strategic Export Controls - annual reports
The Export Control Joint Unit and the Department for Business and Trade’s annual reports contain sections on compliance and enforcement.
United Kingdom strategic export controls annual report
- 18 July 2025
- Collection
Updates to this page
Published 3 November 2025 Last updated 6 January 2026 show all updates
1.
6 January 2026
Links added for the One year of the Office of Trade Sanctions Implementation (OTSI) review and OTSI blog on breach reporting.
2.
4 December 2025
Added link to NCA press release about Operation Destabilise.
3.
3 November 2025
First published.
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