- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Neil Hodge2024-08-28T16:03:00
Sanctions imposed against Russia following the 2022 invasion of Ukraine are being undermined by the U.K.’s poor track record of enforcement, according to a report by campaign group Spotlight on Corruption.
The report, titled “All bark and no bite?: Taking stock of the U.K.’s enforcement of sanctions,” said that up until publication on July 24, there had been no fines for breaches of financial sanctions imposed since 2022; no convictions for sanctions evasion since 2012; and no assets permanently seized through civil or criminal action related to sanctions violations–despite the U.K. government having appropriate legal powers.
The report pointed out at the time that the HM Treasury’s Office of Financial Sanctions Implementation (OFSI) has only “named and shamed” one firm, a nonmonetary penalty against Wise Payments in August 2023, and is yet to issue a single fine for post-invasion breaches of Russian financial sanctions in spite of reporting 172 live investigations by the end of March 2023.
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The U.S. Treasury Department, in coordination with the United Kingdom, is clamping down harder on Russia’s ability to wage war against Ukraine by banning the import of Russian-origin aluminum, copper, and nickel.
The recent decision by the U.K. Office of Financial Sanctions Implementation to disclose details of how Wise Payments failed to stop an individual from obtaining cash while subject to Russian sanctions has ignited debate about whether the agency is taking the right enforcement approach.
U.K.-based foreign exchange service Wise Payments was cited for breaching the country’s sanctions levied against Russia as part of the Office of Financial Sanctions Implementation’s first use of its disclosure enforcement powers acquired last year.
Raymond James & Associates and its subsidiary agreed to pay more than $1.9 million to settle allegations levied by the Financial Industry Regulatory Authority that it didn’t have an effective system to handle customer complaints, along with millions of direct mutual fund transactions not reasonably being supervised.
A subsidiary of Bank of America agreed to pay $3 million and take remedial measures to resolve allegations that its surveillance system didn’t detect manipulative trading, the Financial Industry Regulatory Authority said.
The Department of Justice declined to prosecute Boston Consulting Group for allegedly bribing Angolan officials in violation of the Foreign Corrupt Practices Act, citing the firm’s prompt self-disclosure and timely remediation.
