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OFSI imposes 2nd sanctions penalty

This one makes more sense – because it has much more detail than the Raphaels Bank one, to which is it related…

Unfortunately, the notice doesn’t cut and paste at all, so let me give you the highlights:

  • Travelex (UK) Ltd was fined 10,000 GBP for processing that same 204 GBP payment for someone designated under the Egypt sanctions program
  • They self-reported, but received no adjustment of the penalty for it
  • “Travelex had direct, in-person, contact with a designated person (DP), in the UK, and dealt with funds belonging to that person despite having access to their passport, which clearly identified the individual by both name, date of birth and nationality”
  • “Travelex were aware of financial sanctions risks and their obligations, and despite this they dealt with funds belonging to a DP. The regime under which the individual was designated is one where sanctions are applied because of the misappropriation of Egyptian State funds. Travelex’ s actions allowed the individual to utilize funds that should have been frozen. No matter the value of the transaction, the breach directly contravened the policy intention of the asset freeze.”

Eh… something tells me that, had this been OFAC, they would have gotten a Cautionary Letter, at worst. You would think the intent of this program is to prevent capital flight, not prevent someone sending their relative a few hundred pounds.

What do you think?


OFSI Imposition of Monetary Penalty

Categories: Civil Monetary Penalties Egypt Sanctions Enforcement Actions OFSI Updates


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