HM Treasury’s Office of Financial Sanctions Implementation (OFSI) has imposed a GBP 300,000 monetary penalty on Markom Management Limited (MML) for breaching UK financial sanctions imposed against Russia following the 2014 annexation of Crimea, linked to a payment of GBP 416,590.92 to a designated person subject to an asset freeze. The breach arose from MML instructing that the payment be made from another company’s bank account, with knowledge that the recipient was a designated person, and without adequate sanctions compliance and controls. OFSI highlighted expectations for firms of all sizes to assess sanctions risk exposure, maintain processes to identify and report suspected breaches, and manage the risks of making payments in haste; it also reiterated that the UK will continue to prioritise sanctions enforcement through public penalties as well as non-public actions such as warning letters and referrals. Separately, OFSI launched a consultation on 22 July on proposals to improve enforcement processes, including measures that, if implemented, would double the value of penalties for the worst sanctions breaches and potentially speed up the resolution of certain penalty cases.