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Imposition of Monetary Penalty – Clear Junction Limited

Link(s):https://assets.publishing.service.gov.uk/ Clear_Junction_Penalty_Report_21.02.22.pdf

Context

OFSI has imposed a monetary penalty against Clear Junction Limited, a Fintech company, for contravention of regulation 4 of the Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 – in particular making funds available to a designated person, without a licence.

Key points to note

  • The penalty amounts to £36,393.45 and relates to 15 transactions made to accounts held at the Russian National Commercial Bank between March 2018 and June 2018. The funds were made available to a person designated under the above-mentioned regime.
  • The penalty was imposed because OFSI was satisfied that Clear Junction had breached prohibitions imposed by financial sanctions legislation and either knew, or had reasonable cause to know, that it was breaching those prohibitions.

Next actions

Whilst we have included this item for information and awareness we suggest firms ensure that any sanctions procedures remain robust and staff have appropriate training.