On 13 October 2025, the Office of Trade Sanctions Implementation (“OTSI”) published a blog post highlighting a recent case involving suspected breach reports from a UK branch of a multinational bank, under the Russia (Sanctions) (EU Exit) Regulations 2019.
OTSI’s blog post notes that the UK branch of the bank identified payments linked to the trade of sanctioned goods from Russia to a third country, between April and June 2025. The blog post notes that “[f]or certain goods subject to UK sanctions, it is an offence for a UK person to facilitate the movement of those goods from Russia to anywhere in the world”. This facilitation “could include providing a bank account or handling a payment for the importing party”.
In the case study in question, the UK bank was acting as an intermediary in the transaction, and payment for the prohibited goods was routed to the UK branch. The payments were flagged through account screening, triggering enhanced due diligence. The bank ultimately did not process the payments and reported the matter to OTSI via OTSI’s online reporting tool. The online reporting tool allows businesses to submit their concerns, along with any relevant documents. OTSI concluded that the bank was not in breach of trade sanctions, as the payments were not processed.
Key takeaways
OTSI’s case study sets out a number of key compliance takeaways for businesses and financial institutions, including the following:
- Reporting and Disclosure
- Understand mandatory reporting obligations for regulated sectors and the benefits of voluntary disclosures.
- Use OTSI’s online reporting tool to promptly report potential breaches or near misses.
- Enhanced Due Diligence
- Conduct enhanced due diligence on clients and transactions involving high-risk jurisdictions.
- Repeat due diligence periodically, particularly when there are changes in transactional patterns.
For further details on this case study, please see the full OTSI blog here.
Please also see our previous blog posts on OTSI’s initial implementation of guidance on Russia trade sanctions and the establishment of OTSI as a new UK Government agency. Please note that OTSI’s Countering Russian sanctions evasion – guidance for businesses includes recommendations for enhanced due diligence under section 4, and for enforcement and reporting under section 5.
