On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK.
The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights) (“EU Regulations”). MML was found to have issued a transfer instruction to refund an overpayment in the amount of approximately GBP 416,590 from a Moscow-based bank account of a client of its parent company, Markom Management Cyprus (“MMC”), to a designated person under the EU Regulations.
MML notified OFSI of its breach on 19 October 2018 (approximately 8 months after the transfer in question) following an internal review commissioned as a result of third party activity. OFSI’s notice does not expand further on the third party activity in question, but OFSI’s engagement with the third party is referenced as the reason for OFSI’s civil investigation into MML not commencing until June 2021. The same third party activity is also cited as the reason for OFSI not considering MML’s disclosure to OFSI to be eligible for a voluntary disclosure discount, even though it OFSI makes clear that it was materially complete– whilst not made expressly clear, this is presumably because the existence of that third party activity meant MML’s disclosure was not deemed to be truly voluntary.
Following OFSI initially issuing a notice to impose a monetary penalty totalling GBP 400,000, MML submitted representations and OFSI considered it appropriate to revise the penalty amount to GBP 300,000. MML exercised its right to ministerial review under s .147 of the Policing and Crime Act 2017. The penalty amount of GBP 300,000 was upheld on review.
Key takeaways from the notice include:
- the emphasis placed by OFSI on the importance of voluntary disclosures being both timely and truly voluntary in order for discount credit to be granted.
- the extended period from commencement of investigation to resolution (in excess of four years).
- the willingness of OFSI to pursue enforcement actions where there is sufficient UK nexus, even if the majority of the conduct takes place outside of the UK.
- the importance of all firms, of whatever size, having an understanding of the impact of sanctions on their business and implementing appropriate, risk based sanctions procedures.
To read the full decision, click here.
