OFSI has imposed a £1,000,920.59 monetary penalty on Sabre Global Technologies Limited (SGTL), its largest monetary penalty in relation to Russia sanctions since the 2022 invasion.
Between May and December 2022, SGTL continued to provide services to a designated entity and sought to receive payments after designation, including exploring alternative payment routes which amounted to circumvention of UK sanctions.
This case was assessed as “most serious” with aggravating factors including deliberate circumvention, high breach value, repeated and extended breaches, and substantial risk of harm to the objectives of the UK’s Russia sanctions regime.
SGTL made a voluntary disclosure to OFSI, cooperated with the subsequent investigation, and have undertaken remediation to improve their future compliance with sanctions.
This was the third penalty resolved under transitional arrangements in OFSI's new settlement policy, introduced in February 2026. OFSI applied a 20% discount to reflect SGTL’s voluntary disclosure and settlement of the case under the transitional arrangements and imposed a final penalty of £1,000,920.59. This demonstrates how proportionate and effective enforcement outcomes can support the rapid communication of compliance lessons to industry.
Key compliance lessons for firms include:
- Attempting to reroute or restructure payment pathways to bypass sanctions controls may constitute circumvention and aggravate the seriousness of any case.
- Digital services, software, and data tools can constitute “economic resources” under UK sanctions law and should be assessed accordingly.
- Firms should maintain up-to-date policies, procedures, and training, supported by competent senior oversight and clear accountability.
- Sanctions policies for firms operating in the UK must be tailored to the UK’s sanctions regime.
- Firms must report suspected breaches to OFSI promptly and comprehensively.
- Where uncertainty exists, firms should seek appropriate specialist legal advice.
