The Office of Financial Sanctions Implementation (OFSI), part of the Treasury, has imposed a penalty of £165,000 on the London branch of Deutsche Bank AG after it broke the Russia (Sanctions) (EU Exit) Regulations 2019.

In this case, Deutsche Bank was responsible for processing payment transactions for one of its customers, a non-UK person incorporated in the Republic of Ireland and subsidiary of a multinational firm headquartered outside of the UK. The payments were processed using the SWIFT messaging network with a third party firm providing sanction screening. Due to various timing issues, the sanctions risk was not identified.