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OFSI ·

OFSI fines Deutsche Bank London Branch for Russia sanctions breach

UK bank sanctions teams must evidence ownership checks before funds release

Financial Services Sanctions
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OFSI imposed a £165,000 penalty on Deutsche Bank AG London Branch for making funds available to Okko LLC, an entity wholly owned by designated person JSC New Opportunities, without a licence.
Why it matters
The penalty makes ownership/control screening the central control failure, not direct name-list matching alone. UK-exposed banks must verify whether a beneficiary is owned or controlled by a designated person before payment release, even when a third-party screening vendor does not generate the ownership-linkage alert.
Implications
  • — UK bank sanctions-screening teams must treat ownership and control links to designated persons as blocking inputs before payment release.
  • — Payment operations teams at UK bank branches must route beneficiary ownership exceptions to sanctions review before value-date settlement.
  • — Legal and sanctions-compliance teams must preserve voluntary-disclosure, settlement and licence-decision evidence when historical breaches involving designated-person ownership are identified.
Who is affected
  • — UK bank sanctions-screening teams
  • — Payment operations teams at UK bank branches
  • — Legal and sanctions-compliance teams at financial institutions
What to watch
  • — Penalty imposed: April 30, 2026
  • — Penalty published: May 19, 2026
  • — Regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019
  • — Strict-liability amendments to PACA effective from June 15, 2022
View on OFSI
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