Top Performing Posts - 2nd Place

Hi ,

Hope you’re having a good week.

This week I’m on holiday so I’ve lined up my top 3 performing LinkedIn posts from the last few months in case you may have missed any.

Enjoy and I’ll respond to mail when I’m back!

In second place are my four takeaways from the OFSI Herbert Smith Freehills Russian subsidiary Enforcement Action.

UK Sanctions body OFSI penalises leading London Law Firm’s former Moscow operation (not the UK parent firm) with £465k fine:

• 2nd largest UK Sanctions penalty issued by OFSI

• 1st OFSI fine for a Legal Firm

• 1st OFSI fine in 2025

Here’s 4 things to be aware of for AML Heads, Sanctions Heads and MLROs:

1. Don’t shortcut your screening processes - even for small bank fees Despite a locally embedded screening process being in place, the law firm’s Moscow’s finance team failed to check payments against Alfa-Bank, Sovcombank, and Sberbank designations. One oversight involved an overdraft bank fee of £39.71 to Sberbank that led to a breach.

2. Consider any type of financial relationship - even life insurance policies While very senior staff at the Moscow firm recognised that Sovcombank was sanctioned, the operation failed to identify the sanctioned status of the life insurance entity Sovcombank Life. This life insurance entity sent the Moscow operation three separate invoices resulting in payment of £3,903.76

3. Be very careful about hasty collaborations with other firms 

   Following the London Law Firm's decision to close their Russian subsidiary post the Ukraine invasion, the Moscow office entered into a contract with a local firm. This local firm also had an account with the designated entity Alfa-Bank. The London Law Firm didn't know about this second account, nor the £3.9 million that was paid by the Moscow operation to local law firm's account with Alfa-Bank.

4. Self-disclosure reduces fines 

   The total value of the breaches was £3,932,392.10, the initial penalty OFSI felt reasonable and proportionate was £930,000, reduced with a 50% discount to £465,000 due to the London Law Firm's voluntary, unprompted and complete self-disclosure

See you Friday for my top performing post of recent months.

Paul