UK fines Citibank’s London branch £4.7M for breaching Russia sanctions

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Citibank’s London branch just got handed a £4,732,830.58 penalty by the UK’s Office of Financial Sanctions Implementation for repeatedly violating Russia sanctions. The fine, imposed on August 11 and publicly announced on September 2, covers hundreds of prohibited transactions that flowed through the bank’s systems after Russia invaded Ukraine in February 2022.

970 payments, £19.72 million, one very slow compliance system

OFSI’s investigation found that Citibank N.A. London Branch processed 970 payments totaling approximately £19.72 million in violation of sanctions that prohibit dealing with frozen funds or making money available to designated individuals.

The bulk of those transactions took place between February and November 2022, a period when Western governments were rapidly designating Russian individuals and entities. Some of the violations stretched all the way into 2025. Those later breaches primarily involved corporate clients linked to a designated Russian individual and transactions connected to PJSC Sovcomflot, Russia’s largest shipping company. Internal bank charges on restricted accounts also contributed to the tally.

OFSI was clear that Citibank didn’t intend to breach sanctions. The regulator characterized the failures as a matter of broken controls rather than deliberate evasion. Still, it described the control failings as “material and significant” across multiple business areas.

Self-disclosure earned Citi a 40% discount

Citibank voluntarily disclosed the majority of the breaches to OFSI and cooperated fully throughout the investigation. That cooperation bought the bank a meaningful discount: 20% off the penalty for voluntary disclosure and another 20% for agreeing to settle.

A total 40% reduction means the original, undiscounted figure would have been closer to £7.9 million.

The UK’s sanctions enforcement machine is getting louder

The specific violations in Citi’s case fell into several categories: delayed restrictions on accounts belonging to designated persons, correspondent banking payments routed to designated Russian banks, and internal charges applied to accounts that should have been frozen.

The breaches were governed by two separate legal frameworks: the Russia (Sanctions) (EU Exit) Regulations 2019, which is the UK’s primary Russia sanctions regime, and the Global Anti-Corruption Sanctions Regulations 2021.

The fact that some of Citi’s violations continued into 2025, roughly three years after the initial wave of designations, is perhaps the most uncomfortable detail for the bank. It suggests that even after the compliance surge of 2022 and subsequent remediation efforts, gaps persisted in the system long enough to generate additional breaches.

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