Changeflow GovPing Trade & Sanctions OFSI Fines Apple Irish Subsidiary £390,000 for ...
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OFSI Fines Apple Irish Subsidiary £390,000 for Russian Sanctions Breaches

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Summary

The UK's Office of Financial Sanctions Implementation (OFSI) imposed a £390,000 monetary penalty on Apple Distribution International (ADI), an Irish subsidiary of Apple Inc., on 19 March 2026. The penalty addresses two payments totaling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. The case highlights enforcement risks for technology companies processing payments involving sanctioned entities.

Published by Crowell & Moring on cmtradelaw.com . Detected, standardized, and enriched by GovPing. Review our methodology and editorial standards .

What changed

OFSI published details of a £390,000 penalty imposed on Apple Distribution International (ADI) for breaches of UK financial sanctions relating to Russia. The penalty stems from two payments totaling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. Although the underlying facts are relatively straightforward, the case provides several compliance takeaways for entities operating in the technology and payments sectors. Organizations processing payments or providing services to entities in sanctioned jurisdictions should ensure robust sanctions screening procedures and maintain awareness of indirect exposure through subsidiaries or payment processors.

What to do next

  1. Monitor OFSI guidance on financial sanctions compliance
  2. Review payment processing procedures for sanctioned jurisdictions

Archived snapshot

Apr 14, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

The UK’s Office of Financial Sanctions Implementation (OFSI) has published details of a £390,000 penalty it imposed on ADI, an Irish subsidiary of Apple Inc., on 19 March 2026. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. Although the underlying facts are relatively simple, there are several interesting takeaways from OFSI’s penalty notice.

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Last updated

Classification

Agency
Crowell & Moring
Published
April 19th, 2026
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Technology companies
Industry sector
5112 Software & Technology
Activity scope
Payment processing Sanctions compliance
Geographic scope
United Kingdom GB

Taxonomy

Primary area
Sanctions
Operational domain
Compliance
Compliance frameworks
OFAC Sanctions
Topics
International Trade Financial Services

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