HM Treasury’s Office of Financial Sanctions Implementation (OFSI) has imposed a GBP 465,000 monetary penalty on Herbert Smith Freehills CIS LLP (HSF Moscow) for breaches of UK financial sanctions on Russia linked to its invasion of Ukraine. The penalty relates to six payments totalling GBP 3,932,392.10 made over seven days as the firm wound down its Russian offices, which OFSI found made funds directly available to designated persons subject to an asset freeze. The designated persons were Alfa-Bank JSC, PJSC Sovcombank and PJSC Sberbank. OFSI treated the payments as demonstrating a pattern of failings. HSF London voluntarily disclosed the breaches on behalf of HSF Moscow, and a 50% reduction was applied to the final penalty amount. OFSI’s public notice stresses the action is against HSF Moscow and that it found no fault with HSF London.
HM Treasury 2025-03-20
HM Treasury’s Office of Financial Sanctions Implementation fines Herbert Smith Freehills CIS LLP GBP 465000 for making payments to sanctioned Russian banks
HM Treasury’s Office of Financial Sanctions Implementation (OFSI) fined Herbert Smith Freehills CIS LLP (HSF Moscow) GBP 465,000 for breaching UK financial sanctions on Russia. The penalty concerns six payments totaling GBP 3,932,392.10 to designated persons under asset freeze, including Alfa-Bank JSC, PJSC Sovcombank, and PJSC Sberbank. HSF London disclosed the breaches, resulting in a 50% penalty reduction, with OFSI clarifying no fault with London.