| Link(s): | DB_Penalty_Notice.pdf |
Context
OFSI has imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch (DBLB) for breaches of the Russia financial sanctions regime. Between June and July 2022, DBLB processed two payments totalling £635,618.75 to an entity wholly owned by a designated person.
Key points to note
This is the second OFSI monetary penalty case resolved through settlement, demonstrating how proportionate and effective enforcement outcomes can support the rapid communication of compliance lessons to industry. It also underlines the importance of firms maintaining effective sanctions controls, particularly where ownership and control structures determine whether restrictions apply.
Key lessons for firms include the importance of:
- maintaining suitably robust sanctions screening systems and processes, commensurate with their level of exposure to sanctions risk;
- having strong onboarding procedures and regular, risk‑based customer reviews especially in higher risk jurisdictions; and
- complete, detailed, and prompt voluntary disclosure of potential breaches to OFSI.
A 45% discount was applied, reflecting voluntary disclosure and settlement.