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OFSI’s largest Russian sanctions penalty: Takeaways and practical tips

Neoclassical stone carvings and sculptures decorate the main entrance of the HM Treasury building at 1 Horse Guards Road in the historic Whitehall district of the city
OFSI is part of the HM Treasury. Photo: Claudiac8/Getty Images

Mark Beardsworth, Signature Litigation; Duncan Grieve, Signature Litigation

5 min read

Penalties may be imposed without showing that the person or company knew, or had reasonable cause to suspect, they were in breach.

On August 11, 2026, OFSI imposed its largest Russian sanctions penalty to date – £4.7m ($6.2m) – on Citibank for 970 payments worth approximately £19.7m ($26m) made between February 2022 and July 2025. Whilst the payments are historic, dating back to the flurry of sanctions issued in 2022 following the Russian invasionUK financial sanctions general guidance.

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