A case about a beneficiary the bank screened and correctly did not match, because the fact that made it prohibited was in a register the screening list did not hold.
The chain of ownership
Okko is a Russian online streaming platform. Sberbank acquired it in 2018. The UK designated Sberbank on 6 April 2022. On 17 May 2022 Sberbank sold Okko to JSC New Opportunities, which was not itself designated when it bought it. The UK designated JSC New Opportunities on 29 June 2022 at 11:00 BST, and the statement of reasons noted that in May 2022 companies offering digital services previously owned by Sberbank had been sold to it. From that moment Okko was again subject to the prohibitions, as a company owned by a designated person.
The two payments
Deutsche Bank’s London branch processed payments on behalf of a customer, a non-UK company, to Okko: £356,429.27 on 29 June 2022, the day of the designation, and £279,189.48 on 27 July 2022. Okko was the customer’s customer, not the bank’s.
The bank screened the beneficiary both times and no alert fired. Its third-party vendor’s lists had incorporated the designation of JSC New Opportunities, but “did not include data in relation to Okko’s ownership.” The company on the list and the company being paid were joined only by an ownership relationship that nothing in the screening pipeline recorded.
Why the penalty was small and still published
OFSI’s own findings are mixed, which is what makes the notice useful. It records that Deutsche Bank “had neither intent, knowledge nor cause to actually suspect” the ownership link, that the bank had no general legal requirement to conduct due diligence on its customer’s customers, and that the direct cause was in screening. It still found aggravating factors: the amount, that the payments went directly to a wholly owned subsidiary of a designated person, and weaknesses in how the bank had assessed this customer, which was instructing several Russian payments in mid-2022 and relying on a self-certification model for ownership risk that the bank had not examined.
Payment A landed on the day of designation, so OFSI acknowledged only a narrow window in which it could have been cancelled. It treated Payment B, a month later, as the significant one. The 2026 settlement of £165,000 was reached under transitional arrangements for the new framework, after the bank had asked for ministerial review.
The notice does not allege that the sale of Okko was structured to evade. The sequence is what matters for detection: an asset moves out of a designated owner’s hands and into the hands of an entity that is designated a few weeks later, and a screening system built on names alone sees neither event.