The UK's Office of Financial Sanctions Implementation has today issued a Penalty Notice against Colorcon Limited, in relation to its Moscow branch office making 79 unlicensed payments to the company's employees and suppliers who had accounts with designated Russian banks.
The payments were made between 23 March and 2 December 2022. The company self-reported to OFSI on 21 April 2023, but OFSI's Notice states that the four month delay in reporting meant that the reporting was not "prompt".
After assessing a range of aggravating and mitigating factors OFSI determined that the appropriate penalty should be £235,000 to which it applied a 35% discount for reporting (down from a 50% discount available for "prompt" reporting).
The Notice also points out that further payments were made while a "wind-down" general licence was in place, but that the reporting requirements under this general licence were not complied with. No fine was issued for this breach.
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.
