ARTICLE
9 September 2025

OFSI Issues Disclosure Notice For Bank That Allowed Designated Person To Use Funds

DM
Duane Morris LLP

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The Office of Financial Sanctions Implementation ("OFSI") has today issued a Disclosure Notice against Vanquis Bank Limited.
United Kingdom International Law

The Office of Financial Sanctions Implementation ("OFSI") has today issued a Disclosure Notice against Vanquis Bank Limited.

Vanquis failed to react quickly enough to the designation of one of its customers under the UK's anti-terrorism sanctions permitting a withdrawal (of £200) a day after the designation, and a purchase (of £8.99) five days after designation.

OFSI had written to Vanquis in advance of the designation to warn it that an unnamed customer of the bank was about to the designated. A day after the designation the Bank had flagged the possible match with a customer, but it took 8 days to confirm the match.

Just 5 days after the match was confirmed Vanquis reported the breach to OFSI.

In the overall circumstances, including the low value of the breaches, OFS declined to impose a fine.

It is worth noting that OFSI describes the breaches as VBL itself "made funds available to a designated person", rather than facilitating or some other categorisation.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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