Industrial Policy & Trade Monitor· 2679 actions· ✨ 92 recent

On 30 July 2025 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, published a civil monetary penalty of £300,000 against Markom Management Limited (MML UK), a London-incorporated provider of corporate-services and management functions to its parent Markom Management Cyprus. The penalty (decision dated 10 January 2025) relates to MML UK instructing the transfer of £416,590.92 from a Moscow-based bank account of its parent's client to a person designated under an EU Regulation 269/2014 asset freeze (Russia/Crimea-related), at a time when MML UK had knowledge of the recipient's designated status. OFSI initially proposed £400,000; MML's representations secured a reduction to £300,000, which was subsequently upheld on ministerial review under s.147 of the Policing and Crime Act 2017. At the time of publication this was the third-largest OFSI civil monetary penalty imposed since the powers were introduced under Part 8 of the Policing and Crime Act 2017, and the twelfth use of those powers in total.

OFSI imposed a £465,000 civil monetary penalty on Herbert Smith Freehills CIS LLP (the firm's Moscow subsidiary, "HSF Moscow") for six payments totalling £3,932,392.10 made to three Russia-designated persons — Alfa-Bank JSC, PJSC Sovcombank, and PJSC Sberbank — during the wind-down of the Moscow office in May 2022, in breach of the Russia (Sanctions) (EU Exit) Regulations 2019. The penalty is the first OFSI enforcement action against the legal-services sector and the first against a Big Law firm; OFSI signalled further professional-services enforcement is in the pipeline. HSF London's voluntary disclosure and full cooperation secured a 50% penalty reduction from an initial £930,000 basis.