The Kremlin, sanctions evasion and preventing wrongdoing

Two transactions conducted unilaterally by institutions in Russia – but involving the UK operations of Sberbank – have led to assets being realised for the benefit of Russian parties. As the British sanctions watchdog examines the incidents, all financial services firms should see this as a wake-up call that they must be able to demonstrate adequate procedures against potential sanctions violations. Angelika Hellweger reports.

Angelika Hellweger (angelika.hellweger@rahmanravelli.co.uk) is legal director at Rahman Ravelli. She is a dual-qualified Austrian counsel and English solicitor who specialises in international, high-level economic crime investigations and large-scale commercial disputes.

The fact that the Kremlin's biggest bank has been reported to the Treasury’s sanctions watchdog, the Office for Sanctions Implementation (OFSI), for actions involving its UK arm is noteworthy in itself. Yet this may say just as much about the need to take the right approach to the United Kingdom’s sanctions regime as it does about the financial institution accused of wrongdoing.