A corporate services provider, a designated person and a refund. It matters because nothing in it is a scheme, and every element of it is what a professional services firm is exposed to.
The overpayment
Markom Management Limited was a UK-incorporated company providing fiduciary, management, administration, bookkeeping and accounting services to companies in several jurisdictions. It belonged to a group with a Cyprus sister company, Markom Management Cyprus, which served companies registered and operating in Cyprus.
On 19 February 2018 a person designated under the EU Ukraine measures paid a client of the Cyprus company under a sale and purchase agreement. The money moved between two accounts at Gazprombank in Moscow and did not involve Markom, so the transfer itself was not prohibited. The next day Markom’s senior managers were told the payment included an overpayment of RUB 33,000,000, about £416,590. Markom then instructed Gazprombank to transfer that amount from the client’s account back to the designated person’s account. That instruction was the breach.
The informal working model
The notice’s account of why this happened is the useful part. The client had once been a Markom client and Markom staff remained its point of contact for execution of payments, because they could communicate in Russian. OFSI described “informal transnational working practices” between the UK and Cyprus companies and found no policy or control to manage the sanctions risk they created.
OFSI rejected Markom’s stated misunderstanding of the regulations: it had not sought legal advice and was “prioritising making the Payment in haste, thereby demonstrating disregard for sanctions compliance”. It also noted that the designated person received a benefit that let them avoid a net loss of funds, and that the payment was made “with a clear view of the recipient”.
Timing
Markom notified OFSI through its lawyers in October 2018 after finding the breach in an internal review commissioned because of third-party activity. OFSI did not begin its civil investigation until June 2021, and did not treat the disclosure as eligible for a discount. The penalty was proposed at £400,000 in August 2024 and imposed at £300,000 in January 2025, and a ministerial review upheld it in June 2025 — seven years after the payment.