HMRC settles with Petrofac unit for £569k over Russia sanctions breaches during its Russian divestment
UK exporters winding down Russia operations must screen goods and technical assistance against the Russia Regulations at the point of divestment — HMRC settled with a Petrofac unit for £569,157.07 over breaches committed during its Russian exit
- — UK exporters divesting or winding down Russian operations must apply full sanctions screening to goods and assistance transferred during the exit itself — HMRC treated breaches committed in the course of PFML's 2022–23 Russian divestment as settleable offences, showing the wind-down phase is a live compliance risk, not a clean exit.
- — Trade-sanctions and export-control teams must screen for the G7 Dependency and Further Goods category under the Russia Regulations and block making such goods available to Russia-connected persons or for use in Russia — PFML's two Regulation 46Y(2)(c) breaches turned on exactly these prohibitions.
- — Compliance teams must extend controls beyond physical goods to technical assistance connected to them — PFML's separate Regulation 46Z(1)(b) breach was for providing technical assistance in respect of the goods, a distinct offence from supplying the goods.
- — Exporters that discover an inadvertent or controls-driven breach should weigh voluntary disclosure — HMRC states compound settlements are available where the breach was inadvertent or due to internal-control weaknesses and was self-reported, but are not normally offered where the breach was intentional.
- — UK exporters divesting or winding down operations in Russia
- — Trade-sanctions and export-control compliance teams at UK exporters
- — Compliance teams managing technical-assistance controls alongside goods controls
- — Legal and compliance functions weighing voluntary disclosure of export-control breaches