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

1. Rushed operational payments executed without full compliance review.
2. Finance staff oversight — sanctioned counterparties were not flagged before settlement.
3. 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

1. Embed sanctions screening tools in all payment workflows.
2. Develop “exit jurisdiction playbooks” to guide compliant wind-downs in sanctioned countries.
3. Require second-line review of all payments tied to high-risk regions.
4. Expand training beyond compliance teams — operations, HR, and legal staff must also understand sanctions exposure.
5. 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