Overview
In an article published by WorldECR titled, "UK payment-solutions company becomes sixth company to receive OFSI monetary penalty for sanctions breaches," Steptoe partner Alexandra Melia discusses the implications of the HM Treasury’s Office of Financial Sanctions Implementation’s (OFSI) GBP 36,393.45 monetary penalty against Clear Junction Limited for multiple breaches of The Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014.
The Clear Junction case represents the sixth use of OFSI's civil monetary penalty powers since they were introduced under Part 8 of the Policing and Crime Act 2017. Melia discusses how several useful hints as to OFSI's enforcement priorities can be discerned from the Clear Junction case.
The full article is also available in the March 2022 issue of WorldECR (subscription required). It was originally published on Steptoe's International Compliance Blog.
