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ARTICLE · 05 OCTOBER 2022

Compliance DIY: OFSI's Latest Enforcement Action And Taking Responsibility For Your Own Sanctions Risk

Mayer Brown
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On 27 September 2022, HM Treasury's Office of Financial Sanctions Implementation (OFSI) announced the imposition of a £30,000 civil monetary penalty against Hong Kong International...

GlobalInternational Law
Jason Hungerford
Jason Hungerford
Paul Whitfield-Jones
Paul Whitfield-Jones
James Ford
James Ford
Mihira Patten
Mihira Patten
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On 27 September 2022, HM Treasury's Office of Financial Sanctions Implementation (OFSI) announced the imposition of a £30,000 civil monetary penalty against Hong Kong International Wine and Spirits Competition Ltd (the Company), a UK company, for breaches of sanctions relating to Ukraine.1 This is OFSI's eighth civil monetary penalty to date and demonstrates that companies must consider intangible benefits – specifically, in this case, publicity – as economic resources subject to assets freeze regulations. OFSI's commentary on the case also reinforces application of financial sanctions to all sectors and that companies are responsible for their own compliance with them.

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