First UK Sanction (OFSI) monetary penalty

On 21 January 2019, OFSI imposed its first monetary penalty. The penalty is £5,000 on Raphaels Bank in the UK for violating EU Egypt sanctions, namely dealing with £200 in funds belonging to a designated person.

OFSI reduced the penalty by 50% from £10,000 because Raphaels Banks itself disclosed the breach and cooperated with OFSI.

The penalty imposed on R. Raphael & Sons plc trading as Raphaels Bank (Raphaels Bank)

1. On Monday, 21 January 2019 the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, issued a monetary penalty of £5,000.00 per s146 of the Policing and Crime Act 2017 against Raphaels Bank for a contravention of regulation 3 of the Egypt (Asset-Freezing) Regulations 2011 (S.I. 2011/887).
2. The value of the transaction was £200.00. Raphaels Bank dealt with funds belonging to a person designated under the above regime.
3. Raphaels Bank disclosed to the OFSI when they became aware that a breach of financial sanctions had taken place.
4. OFSI reduced the penalty by 50% from £10,000.00 following our published guidance on case assessment, in consideration of Raphaels Banks’ disclosure and cooperation.
5. OFSI imposed the monetary penalty because it was satisfied, on the balance of probabilities, that Raphaels Bank breached a prohibition that is imposed by or under financial sanctions legislation, and knew, or had reasonable cause to suspect, that they were in breach of the ban.

See OFSI Notice here

To read Guidance on Penalties click here