Partner Neil Dooley analyses OFSI enforcement action against Apple over sanctions breach, in Bloomberg and the legal press

Partner Neil Dooley comments on the UK Office of Financial Sanctions Implementation’s decision to fine Apple Distribution International for breaching Russian sanctions, and considers what this signals about sanctions compliance and enforcement.

Neil’s comments were published in Bloomberg, The Register, Law360, ICLG and Solicitors Journal, 30 March 2026.

“Today’s announcement illustrates the importance of companies having robust sanctions policies to ensure payments are not made inadvertently to sanctioned entities.

“Whilst there is no suggestion that Apple sought to circumvent sanctions, it is apparent that they were slow to update their payment systems and failed to spot several red flags surrounding the payments made by it in mid-2022 to an entity that had until May 2022, been owned by Sberbank, Russia’s largest bank and one of the first entities to be sanctioned in February 2022.

“When they became aware of the potential sanctions breach, Apple notified OFSI and it is then clear there were significant communications over 3 years to “negotiate” the fine, taking into account various mitigating factors including that Apple had self-reported the potential breach and had undertaken remedial measures to improve sanctions compliance.

“By settling with OFSI, Apple was able to secure a 35% reduction in the fine imposed. This settlement will be seen as a template for dealing with sanctions breaches and is a salutary lesson to the market that prompt disclosure of potential sanctions issues to OFSI is encouraged and can help limit reputational damage.”