Lessons to be learnt from HSF Moscow sanctions penalty
The Office of Financial Sanctions Implementation (OFSI) previously announced a £465,000 penalty against Herbert Smith Freehills CIS LLP (HSF Moscow) for breaching UK financial sanctions on Russia. In this blog post, OFSI examines what lessons other businesses should take from this case. OFSI identified inadequate due diligence and sanctions screening as primary causes of the sanctions breach and highlighted three main compliance lessons: understanding sanctions risk exposure, adherence to internal procedures and proper assessment of ownership and control structures.