The clearest published example of what circumvention looks like when it is written down by a regulator: not a shell company, but a compliance team looking for a different bank account.
What happened
Sabre Global Technologies supplies a travel-industry distribution system and had a contract with JSC Ural Airlines running from 2007. The UK designated Ural Airlines on 19 May 2022 and Sabre’s lawyers told it the same day. OFSI’s notice records three separate breaches:
- Making funds available (regulation 13). In April to June 2022 Sabre invoiced Ural Airlines and instructed that payment be made into its account, $906,576.30 (£744,305.13) in total. Because those payments discharged Ural Airlines’ own debts, OFSI treated them as a significant financial benefit to the designated person.
- Making economic resources available (regulation 14). Sabre allowed Ural Airlines to keep using its system from the designation date until 6 December 2022.
- Circumvention (regulation 19). This is the one that matters here.
The second bank account
Three payments from Ural Airlines were held or refused by Sabre’s UK bank between June and July 2022. In July and August, according to the notice, Sabre “explored alternative routes to receive funds and engaged with its US bank to determine whether payments from Ural Airlines could be received into their US bank account, explicitly referencing prior sanctions problems with its UK bank account.” Internal emails said that if a test payment succeeded, Sabre expected Ural Airlines to pay the full outstanding amount that way. On 21 September 2022 Ural Airlines sent a $200 test payment to the US account. OFSI found its object or effect was to circumvent the prohibitions.
The detection story is in the sequence: the UK bank’s sanctions team stopped the money, and the customer’s next question was which other bank would not. Banks that see a client’s payments held elsewhere and then appear as the alternative route are being tested in exactly this way.
The compliance failures behind it
OFSI’s account of why nobody stopped it is unglamorous. The senior officer responsible misunderstood which Sabre entity held the contract and did not escalate on leaving the role. The company lacked a permanent chief legal officer and chief compliance officer for a period. Its sanctions documentation emphasised US requirements over UK ones, and its third-party screening software did not automatically flag the designation to the compliance team.
Sabre made a voluntary disclosure on 31 October 2022, and the penalty was settled in May 2026, the first months under OFSI’s new settlement framework.