Partner Chris Roberts has provided comment in The Lawyer, Business & Accountancy Daily, TheWealthNet and ICLG News on OFSI imposing a £165,000 fine on Deutsche Bank AG London Branch for breaches of the Russia financial sanctions regime.

Chris noted the practical implications of the news for corporates, stating: “This fine highlights OFSI’s willingness to enforce sanctions, underlining that effective enforcement is key to driving compliance. It also shows the need for firms to keep screening and due diligence processes up to date, particularly as sanctions regimes and ownership structures evolve.

“Whilst the transactions in question took place in 2022, these findings demonstrate the need for sanctions screening processes to be kept up to date to reflect not only regularly changing sanctions laws but also any changes in company ownership.”

Discussing other key takeaways from the fine, he added: “This outcome also reinforces the tangible benefits of early, complete and well‑framed self‑disclosure – OFSI’s application of a 45% discount highlights how proactive cooperation can materially mitigate enforcement exposure. Firms should take from this that transparency, coupled with a demonstrable commitment to remediation, is not simply expected but can meaningfully influence regulatory outcomes where breaches occur.”

Chris’ comments were published in The Lawyer, Business & Accountancy Daily, TheWealthNet and ICLG News, 19 May 2026.