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ARTICLE · 12 AUGUST 2021

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OFSI Takes Aim At FinTech Company In Its Latest Enforcement Action

Mayer Brown
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On 5 August 2021, HM Treasury's Office of Financial Sanctions Implementation (OFSI) announced the imposition of a £50,000 civil monetary penalty against TransferGo Limited (TransferGo), a FinTech company,...

European UnionTechnology
Jason Hungerford
Jason Hungerford
Paul Whitfield-Jones
Paul Whitfield-Jones
James Ford
James Ford
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On 5 August 2021, HM Treasury's Office of Financial Sanctions Implementation (OFSI) announced the imposition of a £50,000 civil monetary penalty against TransferGo Limited (TransferGo), a FinTech company, for multiple breaches of EU sanctions relating to Ukraine that were in force in the UK prior to Brexit.  This is OFSI's fifth civil monetary penalty to date and may reflect a growing sanctions enforcement focus beyond "traditional financial institutions" – both in the United Kingdom and the United States – to FinTech companies and payment services providers.

The Facts

In March 2014, the European Union (including the UK) imposed restrictive measures against certain persons responsible for actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine under Council Regulation (EU) No 269/2014 (the EU Regulation).  On 30 July 2014, the Russian National Commercial Bank (RNCB) was designated as an EU asset freeze

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