Sanctions apply to all professional services, not just banks. In 2025, a well-known international law firm faced enforcement action after it processed payments to sanctioned Russian banks while closing its Moscow office.
What Happened?
- During its 2022 Russia office wind-down, the firm made six payments totaling nearly £4 million to sanctioned Russian banks (including Sberbank and Alfa-Bank).
- The payments were processed under operational pressure, without sufficient compliance oversight.
- The firm later self-reported the issue to the UK’s Office of Financial Sanctions Implementation (OFSI), admitting the breaches stemmed from human error.
Red Flags That Were Missed
- Rushed operational payments executed without full compliance review.
- Finance staff oversight — sanctioned counterparties were not flagged before settlement.
- No automated controls — systems failed to block prohibited transactions in real time.
The Consequences
- OFSI imposed a £465,000 fine, reduced from almost £1 million thanks to voluntary disclosure and cooperation.
- The case served as a public warning: law firms and professional services are equally responsible for sanctions compliance.
Lessons for Compliance Teams
- Sanctions don’t stop at banks: Law firms, auditors, and corporates face the same obligations.
- Human error isn’t a shield: Automated and layered controls must backstop individual mistakes.
- Transparency helps: Early self-reporting significantly reduces penalties and reputational fallout.
- Exit planning is critical: Shutting down operations in high-risk jurisdictions is when controls are most likely to fail.
Practical Tips
- Embed sanctions screening tools in all payment workflows.
- Develop “exit jurisdiction playbooks” to guide compliant wind-downs in sanctioned countries.
- Require second-line review of all payments tied to high-risk regions.
- Expand training beyond compliance teams — operations, HR, and legal staff must also understand sanctions exposure.
- Simulate crisis exits (fire-drill exercises) so teams can practice compliance under pressure.
Takeaway:
This case proves that sanctions compliance is universal. Whether you’re a global bank or a global law firm, every payment must withstand scrutiny. Strong systems, disciplined oversight, and a