OFSI, the UK’s sanctions implementation office, publishes each monetary penalty and each disclosure of a breach it did not fine on one page of the gov.uk site. That page has 21 entries going back to January 2019. This note counts them. The figures come from a script in this site’s repository that reads that page weekly, and the data is available as a spreadsheet.
The basic shape
| Actions listed | 21 |
| With a monetary penalty | 18 |
| Disclosures only, no penalty | 3 (Vanquis Bank, Wise Payments, and a group of charities) |
| Total penalties | about £28.1m |
| Smallest | £5,000 (two actions) |
| Median | about £150,000 |
| Largest | £20.47m (Standard Chartered) |
Standard Chartered’s figure is the sum OFSI prints on its page, rounded to £20.47m; the notice itself gives £20,471,809.83. The dates in the dataset are the date OFSI lists an action, which can differ from the date the penalty was imposed. Citibank London is listed on 2 September 2026 and was imposed on 11 August.
Banks dominate the money
Six of the 21 actions are against banks, and they account for about £25.5m of the £28.1m, or 91%. Technology companies come next at £1.39m across two actions (Sabre and Apple Distribution International), then a law firm at £465,000, a fiduciary services company at £300,000 and a pharmaceutical company at £152,750. Thirteen sectors appear in all, including hospitality, telecommunications, energy, property, fintech and maritime.
The spread is the more useful fact. Most of the actions are against firms that are not banks and not obviously exposed to sanctions risk: a wine and spirits competition organiser, an energy-sector company, a concierge service. Civil enforcement has been strict liability since 15 June 2022, and the list reads like it.
When
Eleven of the 21 were listed in 2025 or 2026. The five in 2026 include three of the largest six penalties. Before 2022 the list is thin: three in 2019, one in 2020 and two in 2021. That fits the reasoning in the note on OFAC’s 283 penalties: a record is shaped as much by when enforcement capacity and legal powers arrived as by when the violations occurred. Several of the 2025 and 2026 actions, among them the ones written up as cases on this site, concern conduct from 2022, the year of the Russia designations, and took up to four years to conclude.
One procedural change sits inside those later dates. On 9 February 2026, OFSI introduced a settlement framework letting a penalty case be resolved by agreement rather than fully adjudicated, in exchange for a further discount on top of the existing voluntary-disclosure reduction. Apple Distribution International’s £390,000 penalty, listed the following month, is the first case resolved this way.
What the small ones show
The two £5,000 penalties are worth reading. One, against Svarog Shipping in 2025, was for failing to answer an OFSI request for information within the deadline. It arose from a larger investigation, and OFSI concluded Svarog had not otherwise breached sanctions. The other, in 2019, was against a firm in the banking sector, Raphael & Sons, for dealing with funds belonging to a designated person. Separately, a group of charities is listed as a disclosure for the same failure to respond that Svarog was penalised for. A failure to respond is a distinct offence, and these entries show it is enforced.
What this does and does not establish
It is a count of what OFSI has published, not of what it has found. Cases settled without publication, investigations still open, and breaches reported to OFSI and dealt with by correspondence do not appear. The dataset also holds only the fields OFSI’s page holds: sector, penalty, reason and regulation. For the underlying facts, the cases we have written up link the notice for each.