Emma RadmoreOFSI has fined Sabre Global Technologies Limited, a travel technology firm, more than £1m for breach of Russian sanctions. It found the firm repeatedly made funds and economic resources available to a designated Russian airline over a 7 month period, and looked at payment routes that might get round UK sanctions.
Not only is the penalty the largest ever for breach of Russian sanctions (and the third under the new settlement regime), it is also the first issued for a circumvention offence.
OFSI assessed the case as “most serious”, given the company actively circumvented sanctions, continued to provide services to the sanctioned airline for months after the potential breaches had been noted, and directly undermined the sanctions regime. OSFI said the company had been experiencing staffing issues, not least that it did not have effective senior management oversight of sanctions and could not properly assess or mitigate its sanctions risks. Staffing changes and compliance issues had meant that the company had been slow to identify which of its companies held the contract with the sanctioned airline, and was more geared towards US than UK sanctions compliance – and its third-party sanctions software did not automatically flag the designation to the relevant team. It was the company’s bank that repeatedly flagged the issues to it. As a result of these flags, the company had initially engaged with its US bank to see whether payments could be received there because of sanctions problems with the UK bank account.
The company had eventually made a voluntary disclosure to OFSI and then been fully cooperative, so did get a voluntary disclosure discount. The total value of the breaches was assessed at more than £2,500,000.