OFSI hits wine company with £30,000 sanctions penalty

In a notice of 26 September, the UK’s Office of Financial Sanctions Implementation (‘OFSI’) said that in April it had imposed ‘a monetary penalty of £30,000.00 in accordance with s146 of the Policing and Crime Act 2017 (“PACA”) against a UK registered company, Hong Kong International Wine and Spirits Competition Ltd (‘HKIWSC’), for contravention of regulations 3(1) and 6(1) of the Ukraine (European Union Financial Sanctions) (No.2) Regulations 2014 and articles 2(1) and 2(2) of the Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights).’.

The fine is the first that OFSI has announced that it has imposed under the Russia sanctions since the invasion of Ukraine in February.

OFSI said that the penalty related to three payments and 78 wine bottles the company received from a designated entity for entry into competitions between September 2017 and August 2020 and that the ‘cumulative value of tangible economic resources and funds received by HKIWSC is estimated at £3,919.62.’

Additionally, ‘HKIWSC made publicity, considered an intangible economic resource, available to that designated entity [and] HKIWSC did not make a voluntary disclosure in this case, and therefore a penalty reduction discount was not applied.’