OFSI's record Russian sanctions £4.7 million penalty signals new sanctions enforcement landscape

By Mark Beardsworth, Duncan Grieve, Nikara Rangesh and Sharon Takhar

The Office of Financial Sanctions Implementation (OFSI) recently imposed a record £4.73 million penalty on Citibank NA London for multiple breaches of the Russia (Sanctions) (EU Exit) Regulations 2019 and the Global Anti-Corruption (GAC) Sanctions Regulations 2021. This penalty was imposed on 11 August 2026 in relation to 970 payments made between February 2022 and July 2025 with a total value of circa £19.7 million.