OFSI fines Deutsche Bank London branch over Russia sanctions breaches

LONDON, May 19, 2026 — The UK Office of Financial Sanctions Implementation has imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch after finding it breached the Russia (Sanctions) (EU Exit) Regulations 2019 by processing two payments to Okko LLC, a company wholly owned by designated person JSC New Opportunities.

OFSI said the payments, made in June and July 2022, totaled £635,618.75. The bank processed them on behalf of a customer incorporated in Ireland. Okko was not a customer of Deutsche Bank’s London branch, but the beneficiary of the transactions.

JSC New Opportunities was designated by the UK on June 29, 2022. OFSI said Okko became subject to sanctions restrictions from that point because it was owned or controlled by a designated person. The first payment was processed the same day as the designation and had a value date of June 30, 2022, while the second was processed on July 27, 2022 with a value date of July 28, 2022.

According to OFSI, Deutsche Bank screened Okko for both payments, but no alert was generated because the third-party screening data used by the bank did not include information on Okko’s ownership at the time. OFSI said the breaches occurred after the Policing and Crime Act 2017 strict liability amendments took effect on June 15, 2022.

The authority said Deutsche Bank voluntarily disclosed the transactions on Sept. 20, 2022. OFSI later issued a notice of intent to impose a penalty in September 2025, upheld that decision in December 2025 after receiving representations, and then entered settlement discussions with the bank in March 2026 under transitional arrangements following a new enforcement framework introduced in February.

OFSI assessed the case as “serious” rather than “most serious.” It set a baseline penalty of £300,000 and applied a 45% discount for voluntary disclosure and settlement, resulting in the final £165,000 penalty. OFSI said it did not treat an earlier payment made in April 2022 as a breach because it occurred before the strict liability regime took effect.